2024-cv-03800

COMPLAINT filed by EnchantedMob, Inc., Mob Entertainment, Inc.; Filing fee $ 405, receipt number AILNDC-21950758.

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

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiffs' motion for leave to file under seal [3] is granted. Schedule A and Exhibit 4 to the Declaration of Zach Belanger may be filed under seal pending further order of the Court. Mailed notice

AMENDED complaint by EnchantedMob, Inc., Mob Entertainment, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Schedule A regarding amended complaint, [12]

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[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Zach Belanger regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Exhibit 4 Part 1-1 regarding declaration[17]

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[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[14], motion for miscellaneous relief[19] before Honorable LaShonda A. Hunt on 5/21/2024 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiffs' ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14] and motion for electronic service of process [19] are granted. Plaintiffs' written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating Plaintiffs' interests in identifying defendants, stopping the infringement, and obtaining an accounting. The Court finds that (1) the submitted evidence establishes a likelihood of success on the merits (including evidence of active infringement and sales into Illinois); (2) the harm to Plaintiffs is irreparable and cannot be fully compensated by money damages; (3) an injunction is in the public interest because of the consumer confusion caused by counterfeit goods and infringement interferes with Plaintiffs' ability to control its intellectual property; and (4) there is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with these online marketplace defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the Court will revisit the asset freeze, joinder, and personal jurisdiction. A $1,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. No appearance is necessary on 5/21/24.Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable LaShonda A. Hunt on 5/16/2024.Mailed notice

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

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

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for preliminary injunction[26]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[26] before Honorable LaShonda A. Hunt on 5/29/2024 at 10:00 AM.

Exhibit A

SUMMONS Returned Executed by EnchantedMob, Inc., Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/23/2024, answer due 6/13/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's Motion for Preliminary Injunction 26 is taken under advisement. A telephonic motion hearing is set for 6/6/24 at 9:45AM. Attorneys/parties should appear for the hearing by calling the Toll-Free Number: 877-336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. The motion may be considered unopposed as to any Defendant who does not file an objection by 6/5/24, and/or appear at the telephonic hearing. For the reasons stated in the Court's initial order entering the TRO and the order extending the TRO, the TRO is extended to and including the date the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under Fed. R. Civ. P. 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Plaintiff must serve a copy of this minute order upon all affected Defendants within one business day of its entry on the docket and promptly file proof of that service. No appearance is necessary on 5/29/24. Mailed notice.

CERTIFICATE of Service by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. regarding order on motion for preliminary injunction, set/reset hearings, terminate hearings, 30

(Exhibit A)

MINUTE entry before the Honorable LaShonda A. Hunt: Telephonic motion hearing held. Before the Court is Plaintiff's motion for a preliminary injunction 26, which the Court now considers unopposed because no Defendant filed a notice of objection by the 6/5/24 deadline or appeared at the hearing. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk that Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court on the record and in connection with entry of the TRO 23, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 29 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter Preliminary Injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A to the Amended Complaint 13 are added to the court's docket within five business days. The Clerk is requested to unseal any previously sealed documents. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable LaShonda A. Hunt on 6/6/2024. Mailed notice.

MINUTE entry before the Honorable LaShonda A. Hunt: Preliminary injunctive relief has been entered against the remaining defendants who have not appeared in this case 33. Summons were executed on 5/23/24, and Defendants' responses to the complaint are due by 6/13/24 29. By 7/22/24, Plaintiff is ordered to file any motions for entry of default pursuant to Federal Rule of Civil Procedure 55(a). If there are any remaining defendants against whom default and default judgment are not being sought, Plaintiff is ordered to file by the same date a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. Mailed notice.

NEW PARTIES: Topmai home added to case caption.

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, [35]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[36]

Exhibit 1

NOTICE of Motion by Quinn Bradley Guillermo for presentment of motion for entry of default, motion for default judgment, [35] before Honorable LaShonda A. Hunt on 6/20/2024 at 10:00 AM.

Exhibit A

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

MINUTE entry before the Honorable LaShonda A. Hunt: Before the Court is Plaintiffs' motion for entry of default and default judgment 35 against the remaining defendants identified in Schedule A to the Amended Complaint 13. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default against all defendants on Schedule A to the Amended Complaint is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment by the defaulted Defendants must be filed on or before 7/2/24. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiffs must serve this minute order upon all remaining affected Defendants within one business day of its entry on the docket and must promptly file proof of that service. No appearance is necessary on 6/20/24. Mailed notice.

CERTIFICATE of Service by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. regarding set motion and R&R deadlines/hearings, terminate deadlines and hearings, 40

(Exhibit A)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable LaShonda A. Hunt: No remaining Defendant has responded to Plaintiffs' motion for entry of default judgment. Accordingly, the motion [35] is granted. Based on the evidence previously submitted by Plaintiffs and the admission of liability by virtue of the default, Plaintiffs have established that a permanent injunction should be entered. The infringement of Plaintiffs' marks irreparably harms Plaintiffs and confuses the public. Because this infringement was willful and considering the value of Plaintiffs' brand as well as the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $20,000 ($10,000 for trademark and $10,000 for copyright) is an appropriate award of statutory damages for infringement against each remaining defendant. Enter Final Judgment Order. Civil case terminated. Emailed notice.

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable LaShonda A. Hunt on 7/9/2024.

FULL SATISFACTION of Judgment regarding order 45 in the amount of $10,000 as to certain defendant

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. to amend/correct order[45]

NOTICE of Motion by Justin R. Gaudio for presentment of motion to amend/correct[47] before Honorable LaShonda A. Hunt on 9/23/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiffs' motion to amend [47] is granted to the extent paragraph 10 of the Default Final Judgment Order [45] is amended as requested in the motion. However, counsel is admonished to thoroughly review proposed orders before submitting them to the Court, as the "corrected" order also includes significant substantive changes to the final judgment amount, even though no such relief is sought in the current motion. Counsel must submit a corrected amended default final judgment order consistent with this ruling by 9/16/25. The motion hearing scheduled for 9/23/25 [48] is stricken. Mailed notice (gel,)

AMENDED Default Final Judgment Order. Signed by the Honorable LaShonda A. Hunt on 9/30/2025. Mailed notice. (jcc,)