2024-cv-04731

COMPLAINT filed by Collectanea J. Limited, a Hong Kong Limited Corporation; JURY DEMAND. Filing fee $ 405, receipt number AILNDC-22116605.

Exhibit One: Copyright Registration with Sample

Exhibit Two: Copyright Registrations with Samples

Exhibit Three: CBP Report

Exhibit Four: Law Review Article

(Exhibit Five: DHS Report)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation by Lydia Pittaway

SEALED DOCUMENT by Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation SCHEDULE A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collectanea J. Limited, a Hong Kong Limited Corporation

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 3).

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.

ATTORNEY Appearance for Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation by Michael Thomas Stanley

DECLARATION of YU CHUNG TING

Exhibit One: Registration "Six Steps Photo" with Sample

(Exhibit Two: Registration "Group Series" with Sample)

EXHIBIT THREE SCHEDULE A by Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation EXHIBITS THREE (SCHEDULE A) AND FOUR (EVIDENCE) TO THE DECLARATION OF YU CHUNG TING (DE 7). Modified on 7/29/2024.

(Exhibit Four (Evidence))

MOTION TO SEAL by Collectanea J. Limited, a Hong Kong Limited Corporation

PLAINTIFF'S MOTION FOR ELECTRONIC SERVICE OF PROCESS PURSUANT TO FED. R. CIV. P. 4(f)(3) by Collectanea J. Limited, a Hong Kong Limited Corporation

PLAINTIFF'S MOTION FOR LEAVE TO CONDUCT EXPEDITED THIRD-PARTY DISCOVERY AND MEMORANDUM OF LAW by Collectanea J. Limited, a Hong Kong Limited Corporation

MOTION by Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation for temporary restraining order

(Exhibit One: Declaration of L. Pittaway)

Motions D.E. 9, 10, 11, and 12 NOTICE of Motion by Michael Thomas Stanley for presentment of motion for temporary restraining order 12 before Honorable Jorge L. Alonso on 6/19/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Motion hearing previously set for 6/19/24 is stricken and reset to telephonic motion hearing on 6/25/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion to seal 9 is granted. Plaintiff's Motion for electronic service of process pursuant to Fed.R.Civ.P.4(f)(3) 10 is granted. Plaintiff's Motion for leave to conduct expedited third-party discovery and memorandum of law 11 is granted. Plaintiff's Ex Parte application for entry of a temporary restraining order, including a temporary injunction and a temporary asset restraint and incorporated memorandum of law 12 is granted. Enter Sealed Temporary Restraining Order. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 6/25/2024. Notice mailed by Judge's staff

MOTION by Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation for extension of time Plaintiff's Ex Parte Motion to Extend Time to Post Temporary Restraining Order Bond

NOTICE of Motion by Michael Thomas Stanley for presentment of extension of time 17 before Honorable Jorge L. Alonso on 7/16/2024 at 09:30 AM.

MOTION by Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation for temporary restraining order extension of an additional 14 days

NOTICE of Motion by Lydia Pittaway for presentment of motion for temporary restraining order 19 before Honorable Jorge L. Alonso on 7/16/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: The Court grants Plaintiff's motion to extend time to post bond 17 and grants Plaintiff's motion to extend the temporary restraining order 19 until 7/23/24. The Court sets a telephonic status hearing for 7/23/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

REGISTRY DEPOSIT Information Form by Collectanea J. Limited, a Hong Kong Limited Corporation (Received at the Intake Counter on 07/16/2024)

MOTION by Plaintiff Collectanea J. Limited for preliminary injunction

NOTICE of Motion by Lydia Pittaway for presentment of motion for preliminary injunction 23 before Honorable Jorge L. Alonso on 7/24/2024 at 09:30 AM.

CERTIFICATE of Service by Plaintiff Collectanea J. Limited

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing previously set for 7/23/24 is stricken. Telephonic motion hearing set for 7/24/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Notice mailed by Judge's staff

SUMMONS Returned Executed by Collectanea J. Limited as to Alibetr on 7/23/2024, answer due 8/13/2024; Alohoyoma on 7/23/2024, answer due 8/13/2024; Ankom on 7/23/2024, answer due 8/13/2024; Asingeloo US on 7/23/2024, answer due 8/13/2024; A-yixian on 7/23/2024, answer due 8/13/2024; Beads Hub on 7/23/2024, answer due 8/13/2024; beibeijiajia on 7/23/2024, answer due 8/13/2024; Cenminyuao-US on 7/23/2024, answer due 8/13/2024; Cybiufam-US on 7/23/2024, answer due 8/13/2024; CYQSHOPONE on 7/23/2024, answer due 8/13/2024.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction 23 is granted. Enter Preliminary Injunction Order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Telephonic status hearing set for 8/28/2024 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 7/24/2024. Notice mailed by Judge's staff

ATTORNEY Appearance for Defendants A-yixian, Alibetr, Cybiufam-US by Timothy Tiewei Wang

ATTORNEY Appearance for Defendants A-yixian, Alibetr, Cybiufam-US by Tong Jin

MOTION by Defendants A-yixian, Alibetr, Cybiufam-US to dismiss for lack of jurisdiction

Exhibit A

Exhibit B

Exhibit C

NOTICE of Motion by Tong Jin for presentment of motion to dismiss/lack of jurisdiction[32] before Honorable Jorge L. Alonso on 8/20/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 8/20/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's response to Defendants' Motion to dismiss for lack of personal jurisdiction and improper venue [32] shall be filed by 9/17/24; Defendants' reply shall be filed by 10/8/24. Status hearing previously set for 8/28/24 is stricken. Notice mailed by Judge's staff

MOTION by Plaintiff Collectanea J. Limited for entry of default as to Def. No. 2-4, 6-8, 10, MOTION by Plaintiff Collectanea J. Limited for default judgment as to Def. No. 2-4, 6-8, 10

(Exhibit One: Declaration of L. Pittaway)

NOTICE of Motion by Lydia Pittaway for presentment of motion for entry of default, motion for default judgment, 36 before Honorable Jorge L. Alonso on 9/19/2024 at 09:30 AM.

CERTIFICATE of Service by Plaintiff Collectanea J. Limited

MOTION by Plaintiff Collectanea J. Limited for extension of time to file response/reply as to motion to dismiss/lack of jurisdiction[32]

NOTICE of Motion by Lydia Pittaway for presentment of motion for extension of time to file response/reply[39] before Honorable Jorge L. Alonso on 9/19/2024 at 09:30 AM.

ATTORNEY Appearance for Defendant Asingeloo US by Adam Edward Urbanczyk

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 9/19/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MOTION by Defendant Asingeloo US for extension of time

NOTICE of Voluntary Dismissal by Collectanea J. Limited DEF. (NO. 7) beibeijiajia

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and final default judgment pursuant to Fed.R.Civ.P.55(a) and 55(b) [36] is granted. Enter Default Judgment Order. Plaintiff's Agreed motion for extension of time to respond to certain Defendants' motion to dismiss [D.E. 32] [39] is granted to 10/1/24; Defendants' reply shall be filed by 10/22/24. Defendant Asingeloo US's Motion for extension of time [43] is granted to 10/10/24. Telephonic status hearing set for 10/10/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Collectanea J. Limited DEF. (NO. 2) Alohoyoma

DEFAULT Judgment Order Signed by the Honorable Jorge L. Alonso on 9/19/2024. Notice mailed by Judge's staff

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Alibetr

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by A-yixian

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Cybiufam-US

MOTION by Plaintiff Collectanea J. Limited for extension of time to file response/reply *JOINT MOTION*

NOTICE of Motion by Lydia Pittaway for presentment of motion for extension of time to file response/reply[51] before Honorable Jorge L. Alonso on 10/2/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: The Court grants the parties' joint motion for extension [51]. Plaintiff shall respond to Defendants' motion to dismiss [32] by 10/15/24; Defendants shall reply by 10/29/24. Motion hearing date of 10/2/24 is stricken. Status hearing date of 10/10/24 is stricken. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Collectanea J. Limited against DEF. (NO. 4) Asingeloo US

NOTICE of Voluntary Dismissal by Collectanea J. Limited as to DEF. (NO. 1) Alibetr

ATTORNEY Appearance for Plaintiff Collectanea J. Limited by Larry Ford Banister, II

MOTION by Plaintiff Collectanea J. Limited for discovery (Jurisdictional), MOTION by Plaintiff Collectanea J. Limited for extension of time, MOTION by Plaintiff Collectanea J. Limited to compel (Complete Affiliate Disclosures), MOTION by Plaintiff Collectanea J. Limited to stay regarding MOTION by Defendants A-yixian, Alibetr, Cybiufam-US to dismiss for lack of jurisdiction [32]

MEMORANDUM by Collectanea J. Limited in support of motion for discovery, extension of time, motion to compel, motion to stay, [57]

Declaration

Declaration

Declaration

Errata

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for discovery, extension of time, motion to compel, motion to stay, [57] before Honorable Jorge L. Alonso on 10/23/2024 at 09:30 AM.

MOTION by Defendants Alibetr, A-yixian, Cybiufam-US to set a briefing schedule

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion by filer to set a briefing schedule[60] before Honorable Jorge L. Alonso on 10/23/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/23/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: The Court grants in part and denies in part without prejudice Plaintiff's motion for jurisdictional discovery and to compel affiliate disclosures [57]. Within 7 days of entry of this order. Defendants shall file updated affiliate disclosures, and any necessary supporting materials, that comply with Local Rule 3.2, which shall (1) fully identify Defendants' corporate or business structures and their affiliates, including the entities identified in the declarations Defendants submitted in support of their motion to dismiss [32-1 and 32-3], Wuhan Jiutian Qukong Technology Co., Ltd., and Wuhan Bufei Network Technology Co., Ltd., and any others plausibly relevant for jurisdictional purposes; and (2) address whether there is any state in the United States with which Defendants have sufficient minimum contacts to support personal jurisdiction. See Hangzhou Chic Intelligent Tech. Co. v. Partnerships, No. 20 C 4806, 2022 WL 1028834 (N.D. Ill. Apr. 6, 2022). Within 14 days of this order, Plaintiff shall file its response to Defendants' motion to dismiss [32], which may re-raise Plaintiff's arguments regarding whether jurisdictional discovery is warranted and the proper scope of such discovery. The Court will consider these arguments as part of its consideration of Defendants' motion to dismiss. Defendants may reply to Plaintiff's response brief within 14 days. Defendants' Motion to enter a briefing schedule [60] is denied as moot. The parties are directed to meet and confer regarding settlement before the response is filed. The Court will rule electronically on the motion. Notice mailed by Judge's staff

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by A-yixian

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Cybiufam-US

MOTION by Plaintiff Collectanea J. Limited to vacate order on motion for discovery, order on motion for extension of time, order on motion to compel, order on motion to stay, order on motion to set a briefing schedule, set motion and R&R deadlines/hearings, motion hearing, [63] PLAINTIFFS NOTICE OF SETTLEMENT AND MOTION TO VACATE BRIEFING SCHEDULE ON THE MOTION TO DISMISS

NOTICE of Motion by Michael Thomas Stanley for presentment of motion to vacate, [66] before Honorable Jorge L. Alonso on 11/13/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Notice of settlement and motion to vacate briefing schedule on the motion to dismiss [66] is granted. Motion hearing date of 11/13/24 is stricken. Defendants' Motion to dismiss for lack of personal jurisdiction and improper venue [32] is denied at moot. Telephonic status hearing set for 12/5/24 at 9:30 a.m. The parties are directed to file a joint status report by 12/2/24 unless a stipulation to dismiss is filed. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Collectanea J. Limited against Def. (No. 9) Cybiunfam-US

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collectanea J. Limited (Amended)

NOTICE of Voluntary Dismissal by Collectanea J. Limited against Def. (No. 5) A-yixian

MOTION by Plaintiff Collectanea J. Limited For Release of Bond

STATUS Report by Collectanea J. Limited

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion for release of injunction bond [72] is granted. This case is dismissed. Civil case terminated. Notice mailed by Judge's staff

MOTION by Plaintiff Collectanea J. Limited to amend/correct order on motion for miscellaneous relief, terminated case[74] Releasing Injunction Bond

NOTICE of Motion by Lydia Pittaway for presentment of motion to amend/correct[75] before Honorable Jorge L. Alonso on 3/13/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion Motion to amend minute order (D.E. 74) releasing injunction bond 75 is granted. Enter Amended Order on Plaintiff's Motion for Release of Bond. Motion hearing date of 3/13/25 is stricken. Notice mailed by Judge's staff

AMENDED ORDER On Plaintiff's Motion For Release Of Bond. Signed by the Honorable Jorge L. Alonso on 3/12/2025. Notice mailed by Judge's staff