2024-cv-03490

COMPLAINT filed by EnchantedMob, Inc., Mob Entertainment, Inc.; Filing fee $ 405, receipt number AILNDC-21914442.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by EnchantedMob, Inc., Mob Entertainment, Inc.

Notice of Claims involving Trademarks by EnchantedMob, Inc., Mob Entertainment, Inc.

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Quinn Bradley Guillermo

MAILED trademark report to Patent Trademark Office, Alexandria VA

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2).

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Zach Belanger regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Exhibit 4 - Parts 1-8 regarding declaration 16

Exhibit 4-1

Exhibit 4-2

Exhibit 4-3

Exhibit 4-4

Exhibit 4-5

Exhibit 4-6

Exhibit 4-7

(Exhibit 4-8)

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 13 is granted. Plaintiff's motions for leave to file under seal 3 and for election service of process 18 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 5/6/2024. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

Registry Deposit Information Form by EnchantedMob, Inc., Mob Entertainment, Inc.

SURETY BOND in the amount of $ 125,000.00 posted by EnchantedMob, Inc., Mob Entertainment, Inc. (Document not imaged)

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for preliminary injunction[24]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by EnchantedMob, Inc., Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/14/2024, answer due 6/4/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction against certain defendants [24] is taken under advisement. Any objection or response is due before 5/21/24. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement, by 5/17/2024, the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before May 21, 2024. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

CERTIFICATE of Service by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 27

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [24] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 5/28/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 5/23/2024. Mailed notice

NOTICE of Correction

NEW PARTIES: Changsha Fun Doers International Trade Co., Ltd., Dongguan Meiyu Plastic Products Co., Ltd., Dongguan Ouyi Industrial Co., Ltd., Dongyang Chenchen Jewelry Factory, Ezhou Tongguodou Trading Co., Ltd., Fuzhou Rongwan E-Commerce Co., Ltd., Fuzhou Xuance Trade Co., Ltd., Guangzhou Kawei Technology Co., Ltd., Guangzhou Kingkong Industrial Co., Ltd., Guangzhou Wah Lai Toys Co., Ltd., Henan Jingyu Network Technology Co., Ltd., Henan Yokids Group, Huizhou Linda Toys Co., Ltd., Jiangsu Aurora International Trade Co., Ltd., Nanchang Monse Import And Export Company Limited, Nanning Maggie Trading Co., Ltd., Quanzhou Guanghe Mingliang Trading Co., Ltd., Shandong Kids Keen Toys Co., Ltd., Shandong Mengai Trading Co., Ltd., Shanghai Fuyou Products Co., Ltd., Shanghai Weipinhui Trading Co., Ltd., Shenzhen Enmei Trading Co., Ltd., Shenzhen Hongdingtian Technology Co., Ltd., Shenzhen Hongyi New Energy Technology Co., Ltd., Shenzhen Kakakele Technology Limited, Shenzhen Lanbowan Technology Co., Ltd., Shenzhen Nanshan District Rongdila Trading Firm, Shenzhen Newstar Electronic Technology Co., Ltd., Shenzhen Tianchenxing Technology Co., Ltd., Shenzhen Yixin Mei Industry Co., Ltd., Wuhan Lulu Tech Co., Ltd., Wuxi Yuntianming Import And Export Co., Ltd., Xiaoyao International Trading (shanghai) Co., Ltd, Yangzhou Beyman Toys Co., Ltd., YANGZHOU DUNYU ARTS&CRAFTS CO.,LTD, Yangzhou Hamaqi Import&export Co., Ltd., Yangzhou Henghao International Trade Co., Ltd., Yangzhou Kusibei Toy Co., Ltd., Yangzhou Laixi Rabbit International Trade Co., Ltd., Yangzhou Merry Plush Toys Co., Ltd., Yangzhou New Sunrise Arts&Crafts Co., Ltd., Yangzhou Rytanda Toys Co., Ltd., Yangzhou Whitebeard Toys Co., Ltd., Yiwu Fuguan Household Products Co., Ltd., Yiwu Haiti E-Commerce Firm, Yiwu Jianyu E-Commerce Firm, Yiwu Ke Huan Trading Co., Ltd., Yiwu Tuoyu Crafts Co., Ltd., Yiwu Yanqing Trading Co., Ltd., Yizheng Jian Lin Arts Company, Zhongshan Yingtongxin Handicarft Co., Ltd., A1SA0HSANAJYXS, A2Z0S7KX58V6Q4, A302WSAXH7Y74J, Acfigure, AdasJunJun, bowanyuyiyouxiangongsi, Chenglan Shop, Chen-WHD, cleverinks, congtaiquyingshangmaoyi, Faly, Greenforest E-commerce, HeJinShiHaoLingBaiHuoShangHang, hengbaihuoshangdian, hezelongxingshangmaoyouxiangongsi, jinjiangshichidianzhencuiyanbaihuoshanghang, Jujuque, kaidu2021, KezeSHop, kunmingyuxinpanshangmaoyouxiangongsi, Li - Fu Lin, linlaishangmaoyouxiangong, mandalar, MISSTIAN, Mountains and Seas, NANfengTL, nilingstore, pangyi520, QILIUAE, Rtottsds, Saurion US, shangaoshuiyuan123, Shenghua Shop, shiliketuojianzhu, smiling plush toys1, SUJin, TwoPieceNice, wenwen-Z, wuhanshijunlidianzishangwuyouxiangongsi, Xmxioi, YangYue0528, YTSHANGMAO, yunchengjingjijishukaifaqushaoyaodianzishangwuyoux, YUXIANG-MY, zhengzhoucenshaoxinxikejiyouxiangongsi, zhengzhouchoulishangmaoyouxiangongsi, fairyn--68, Happy928, ings637, l25454, luiyuang, lunkan-46, qfeng_6, Shops in small towns, tang-1992, taozi2_31, wenn-2968, wuhuzengdongshan_0, xguan2088, xiaojia-41, xinleshang, xuel_39, xutan_0, yangyang463, yaoyao-22, yjfsme-31, yudayser, zha622-19, zhaoji_6437, zhiha9073, zhijiangshidaozhu0, DreamHome, Lifeboldly and MAOLILAI Co.Ltd added to case caption.

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

SUMMONS Returned Executed by Mob Entertainment, Inc., EnchantedMob, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/30/2024, answer due 6/20/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 33 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 99 and 125 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 36 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 62, 68, 77, 118, and 123 are dismissed from this case. Mailed notice

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Jennifer Van Nacht

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 39 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 61, 76 and 85. Mailed notice

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [41] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 55, 56, 60, and 64 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to a certain Defendant

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for entry of default, MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for entry of default, motion for default judgment, [44]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [43] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 93 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [44] is taken under advisement. Any objections or responses are due by 7/8/2024. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 6/27/2024. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, [48]

Exhibit A

Exhibit B

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [44] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 7/1/2024. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [50] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 93 and 116 are dismissed from this case. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order[52] in the amount of $100,000 as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 55, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants Nos. 3, 11, 18, 19, 20, 25, 31, and 38. Mailed notice

NOTICE of withdrawal of bond 29 by John Summerfield.