2024-cv-04437

COMPLAINT filed by Grumpy Cat Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-22070696.

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Grumpy Cat Limited by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Grumpy Cat Limited by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Grumpy Cat Limited by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Grumpy Cat Limited by John Wilson

MOTION by Plaintiff Grumpy Cat Limited to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Grumpy Cat Limited

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MOTION by Plaintiff Grumpy Cat Limited for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Grumpy Cat Limited for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Grumpy Cat Limited in support of motion for temporary restraining order, 11

Declaration Bundesen Declaration

Exhibit 1

Exhibit 2 Part 1

Exhibit 2 Part 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 1 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 2 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 3 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 4 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 5 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 6 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 7 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 8 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 9 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 10 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 11 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 12 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 13 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 14 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 15 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 16 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 17 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 18 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 19 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 20 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 21 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 22 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 23 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 24 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 25 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 26 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 27 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 28 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 29 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 30 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 31 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 32 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 33 of Bundesen Declaration

Notice of Claims Involving Trademarks by Grumpy Cat Limited

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

EXECUTIVE COMMITTEE ORDER: GENERAL ORDER 24-0024: IT APPEARING THAT, the civil cases on the attached list have been selected for reassignment to form the initial calendar of the Honorable Georgia N. Alexakis; therefore IT IS HEREBY ORDERED that the attached list of 293 cases be reassigned to the Honorable Georgia N. Alexakis; and IT IS FURTHER ORDERED that all parties affected by this Order must review the Honorable Georgia N. Alexakis' webpage on the Court's website for the purpose of reviewing instructions regarding scheduling and case management procedures; and IT IS FURTHER ORDERED that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new district judge for twelve months from the date of this Order; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Georgia N. Alexakis to the Court's civil case assignment system during the next business day, so that she shall receive a full share of such cases; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Georgia N. Alexakis to the Court's criminal case assignment system twelve (12) months from the date of this order so that Judge Alexakis shall thereafter receive a full share of such cases. Case reassigned to the Honorable Georgia N Alexakis for all further proceedings. Honorable Andrea R. Wood no longer assigned to the case. Signed by Honorable Virginia M. Kendall on 8/23/2024.

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 11 before Honorable Georgia N Alexakis on 9/5/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's Motions for Leave to File Under Seal 7 and for Leave to File Excess Pages 10 are granted. Plaintiff's appearance at the 9/5/24 status hearing is stricken, and Plaintiff's Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and or Electronic Publication 11 is denied without prejudice. Plaintiff may submit an amended motion on or before October 4, 2024, that should be accompanied by the following materials: First, Plaintiff should complete the template found on Judge Jenkins' website linked under "Schedule A" Cases and add to the template a column that includes the date Plaintiff collected the evidence of each defendant's alleged infringement. Second, Plaintiff should submit a memorandum explaining why, based on its allegations, joinder of defendants is appropriate under FRCP 20, including by more deeply engaging with the materials that accompany its complaint and the TRO motion. Third, Plaintiff should submit a listing of all prior Schedule A cases filed in any court in the United States in which it was a plaintiff, a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case, and a certification that Plaintiff has not used any of the screenshot evidence supplied in support of this motion for TRO in any prior proceeding. No appearance is required on the motion.

MOTION by Plaintiff Grumpy Cat Limited for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Grumpy Cat Limited for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Grumpy Cat Limited in support of motion for temporary restraining order, 53

Declaration Bundesen Declaration

Exhibit 1

Exhibit 2 Part 1

Exhibit 2 Part 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 1 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 2 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 3 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 4 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 5 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 6 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 7 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 8 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 9 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 10 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 11 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 12 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 13 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 14 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 15 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 16 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 17 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 18 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 19 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 20 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 21 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 22 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 23 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 24 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 25 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 26 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 27 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 28 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 29 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 30 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 31 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 32 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 Part 33 of Bundesen Declaration

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Schedule A Supplement

DECLARATION of Michael A. Hierl regarding sealed document 88

MEMORANDUM by Grumpy Cat Limited Plaintiff's Memorandum in Support of Joinder

(Exhibit 1)

MINUTE entry before the Honorable Georgia N Alexakis: On 10/4/24, plaintiff filed a motion for a temporary restraining order and motion for leave to file excess pages [52, 53], but plaintiff did not notice up the motions for presentment pursuant to the Court's standing orders. If Plaintiff still wants the Court to resolve its motion for a temporary restraining order, it should notice up that motion for presentment for some date before 12/20/24. It should also file a supplement to its original motion to establish that any alleged infringing activity remains ongoing. If Plaintiff elects not to notice up its motion for a temporary restraining order, it should file a status report by 12/20/24.

AMENDED complaint by Grumpy Cat Limited against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Amended Schedule A

MOTION by Plaintiff Grumpy Cat Limited for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Grumpy Cat Limited for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Grumpy Cat Limited in support of motion for temporary restraining order, 95

Declaration Bundesen Declaration

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

NOTICE of Motion by Michael A. Hierl for presentment of motion for leave to file excess pages 94, motion for temporary restraining order, 95 before Honorable Georgia N Alexakis on 12/19/2024 at 09:00 AM.

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Exhibit 3 to Bundesen Declaration

MEMORANDUM by Grumpy Cat Limited Plaintiff's Supplemental Memorandum in Support of its Motion for Entry of a Temporary Restraining Order

(Exhibit A)

MINUTE entry before the Honorable Georgia N Alexakis:In light of the Court's standing order requiring three business days before presentment of the motion 94 95, the Court re-sets the motion hearing in this matter to 12/30/24 at 9:30 a.m.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MINUTE entry before the Honorable Georgia N Alexakis: Motion hearing held on 12/30/24. Plaintiff's motion for leave to file excess pages 94 is granted. For the reasons stated on the record, Plaintiff's motion for a temporary restraining order 95 is granted in part and denied in part. The Court grants Plaintiff's request for a temporary injunction, expedited discovery, and service of process by email and/or electronic publication. The Court denies plaintiff's request for a temporary asset restraint. Enter order as modified. Plaintiff's written submissions establish a likelihood of success on the merits, that the infringement is ongoing, that the harm to plaintiff is irreparable, and that an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. 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, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and any assets to be frozen. If any defendant were to appear and object, the court will take a fresh look at issues related to joinder, electronic service, and personal jurisdiction. The Court finds that security in the amount of $1,000 per defendant (a total of $2,000) is sufficient to secure the injunctive relief. Any motion to compel third-party platforms to provide information relevant to a temporary asset restraint is due on or before 1/30/25 and should be noticed up for presentment. Plaintiff's motion for leave to file excess pages 52 and motion for a temporary restraining order 53 are denied as moot.

SEALED Temporary Restraining Order Signed by the Honorable Georgia N Alexakis on 12/30/24.

MINUTE entry before the Honorable Georgia N Alexakis:The sealed temporary restraining order is amended. Enter amended order.

AMENDED Sealed Temporary Restraining Order Signed by the Honorable Georgia N Alexakis on 1/2/25.

SURETY BOND in the amount of $ 2,000.00 posted by Grumpy Cat Limited

MOTION by Plaintiff Grumpy Cat Limited for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 106 before Honorable Georgia N Alexakis on 1/14/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis:Plaintiff's ex parte motion to extend the temporary restraining order 106 is granted. The TRO is extended to 1/27/25 for the reasons stated in the order granting the initial TRO 101, 102. No appearance is required on 1/14/25.

MOTION by Plaintiff Grumpy Cat Limited for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

(Exhibit B)

SEALED DOCUMENT by Plaintiff Grumpy Cat Limited Sealed Exhibit A

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 110 before Honorable Georgia N Alexakis on 1/28/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Motion hearing held on 1/28/25. For the reasons stated on the record, Plaintiff's ex parte motion to extend the temporary restraining order as to the Defendants Identified in the amended Schedule A 110 is denied.

MOTION by Plaintiff Grumpy Cat Limited Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MOTION by Plaintiff Grumpy Cat Limited to expedite Plaintiff's Motion for Expedited Discovery

NOTICE of Motion by Michael A. Hierl for presentment of motion to expedite 115, motion for miscellaneous relief 114 before Honorable Georgia N Alexakis on 2/11/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's motion for expedited discovery 115 and electronic service of process 114 are granted. No appearance required on 2/11/25. The Court finds that expedited discovery is warranted to identify defendants. The Court also finds that electronic service does not violate any treaty and is consistent with due process because it is an effective way to communicate with the online marketplace defendants. The Court decides these issues, however, without the benefit of adversarial presentation. If any defendant were to appear and object, the Court will take a fresh look at the issues of electronic service and expedited discovery as well as any issues related to personal jurisdiction and joinder. Enter Order.

ORDER Signed by the Honorable Georgia N Alexakis on 2/10/25.

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

SUMMONS Returned Executed by Grumpy Cat Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 3/3/2025, answer due 3/24/2025.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff is directed to file a status report by 4/25/25, unless plaintiff moves for entry of default and default judgment by that date.

MOTION by Plaintiff Grumpy Cat Limited for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Grumpy Cat Limited for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

(Exhibit A)

MEMORANDUM by Grumpy Cat Limited in support of motion for default judgment, 124

Exhibit A

Exhibit B

Exhibit C

Exhibit D

(Exhibit E)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 124

(Exhibit Hierl Exhibit 1)

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants plaintiff's motion for leave to file a memorandum of law that exceeds the standard page limitation 123. With respect to plaintiff's motion for entry of default and default judgment, plaintiff seeks entry of default as to Defendant Nos. 21 and 31, the remaining defendants in this matter. These two defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default against Defendant Nos. 21 and 31 is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment by Defendant Nos. 21 and 31 must be filed on or before 5/6/25. Plaintiff must serve this minute order upon Defendant Nos. 21 and 31 within one business day of its entry on the docket and must promptly file proof of that service. On or before 5/6/25, plaintiff is directed to supplement its motion for entry of default judgment with a memorandum that provides the Court with any additional information that would permit it to conduct an individualized assessment of damages on a per-defendant basis, including but not limited to information gathered through third-party discovery 117 of each defendant's sales figures with respect to the infringing products at issue and the length of time each defendant sold those infringing products. The Court sets a hearing on plaintiff's motion seeking default judgment as to Defendant Nos. 21 and 31 for 5/8/25 at 9:30 a.m.

CERTIFICATE of Service by William Benjamin Kalbac on behalf of Grumpy Cat Limited

MOTION by Plaintiff Grumpy Cat Limited for extension of time to file Motion for Extension of Time

NOTICE of Motion by Michael A. Hierl for presentment of motion for extension of time to file 129 before Honorable Georgia N Alexakis on 5/13/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants plaintiff's motion for an extension of time through 5/13/25 to file the supplemental memorandum requested by the Court in support of plaintiff's motion for entry of default and default judgment 129. The Court re-sets the hearing on plaintiff's motion for entry of default and default judgment from 5/8/25 to 5/15/25 at 9:30 a.m. No appearance is required on 5/13/25. Mailed notice.

MEMORANDUM by Grumpy Cat Limited Plaintiff's Supplemental Memorandum in Support of a $50,000 Damage Award Per Defaulting Defendant

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

Exhibit F

(Exhibit Kalbac Exhibit 1)

MINUTE entry before the Honorable Georgia N Alexakis: Defaulting Defendants 21 and 31 have not responded to plaintiff's motion for entry of default judgment. Accordingly, the motion 124 is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's intellectual property rights irreparably harms plaintiff and confuses the public. Because this infringement was willful, and after considering the value of plaintiff's brand, the relatively low price-point of the infringing products, the amount of product available for sale, the length of time each defaulting defendant appears to have been engaged in infringing sales, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $10,000 is an appropriate award of statutory damages against each Defaulting Defendant. Enter Final Judgment Order, as modified by the Court. Civil case terminated.

FINAL JUDGMENT ORDER Signed by the Honorable Georgia N Alexakis on 5/14/25.

MAILED final trademark report with a copy of minute entry 133 and final judgment order 134 to Patent Trademark Office, Alexandria VA