2024-cv-04873

COMPLAINT filed by Art Licensing International, Inc.; Filing fee $ 405, receipt number AILNDC-22134191.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Art Licensing International, Inc. Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Christopher Romero

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Art Licensing International, Inc. by Yi Bu

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Young B. Kim. 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.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. If the template is not completed within 14 days of the filing date, the Court may dismiss this matter for failure to prosecute. Mailed notice Modified on 6/17/2024.

MAILED copyright report to Registrar, Washington DC

SEALED DOCUMENT by Plaintiff Art Licensing International, Inc. Schedule A Template Schedule of Defendants to the Complaint 1 and Schedule A 2

MOTION by Plaintiff Art Licensing International, Inc. for leave to file under seal

MOTION by Plaintiff Art Licensing International, Inc. for leave to file excess pages

MEMORANDUM in support of 16 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of of Keith A. Vogt's declaration

Declaration of Jack Appelman

(Exhibit 1, of Jack Appelman's declaration)

SEALED EXHIBIT by Plaintiff Art Licensing International, Inc. Sealed Exhibit 2, Declaration of Jack Appelman regarding memorandum in support of motion, 17

Exhibit 2-1

Exhibit 2-2

(Exhibit 2-3)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff is requested to send a proposed temporary restraining order to the Court's proposed order mailbox by June 28, 2024. Mailed notice.

SEALED ORDER written by the Honorable Lindsay C. Jenkins on 6/27/2024. Mailed notice.

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

SURETY BOND in the amount of $ 10,000 posted by Art Licensing International, Inc. (Document not Imaged)

MOTION by Plaintiff Art Licensing International, Inc. for extension of time for Temporary Restraining Order

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for an extension of the TRO [23] is granted. The TRO is extended to July 25. 2024. Mailed notice.

MOTION by Plaintiff Art Licensing International, Inc. for preliminary injunction

MEMORANDUM by Art Licensing International, Inc. in support of motion for preliminary injunction 25

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's declaration)

SUMMONS Returned Executed by Art Licensing International, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/11/2024, answer due 8/1/2024.

(Declaration of Service)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion [25] for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by July 16, 2024." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until 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 FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 25 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk 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 in connection with entry of the TRO, 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. The Clerk shall unseal any documents that are sealed. The Law Firm of Keith Vogt, Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Lindsay C. Jenkins on 7/17/2024. Mailed notice.

NEW PARTIES: Tsingsen, youmaou, haogaoshangmao, Sealeffort-Us, Kangmusi, VTOSEN-Direct, Setting sail, COOLDEER, CCHKanJun, QIUSUO, Niagara store, HUAYASHI ARTWORK, Wandesi, JFRGS, wuhaous, LOHOME, AYKDTFN, Belle boutique Store, OMICE-US, crafts2018, hao mol, Nafanio, nmingyubinshangmaoy and CHELIAOXT added to case caption.

NEW PARTIES: guangzhougongxiangchongmaoyi, ZSJ Department store, Mall Fun, xiangchengshifengjunbaihuopu, zzzjhhh, SHISHIJIANXING, ESOOR, FromCalifornia, luoguogen666, Onedaime, JohnMalkovichStore, balgaibna, liuchang888, SelmaGooch, Denise L Nicholson Ross, dingfan123, jiaxiuyun6666, dedegt344, PathumWan-Wear, adongjiayou, yangwang4294 and wangliang7890 added to case caption.

NEW PARTIES: john bresnan, LIUWENJIEJIE, jiangyu988924, anlizhaomi7685123, Qaali, surprise bo, CB, WQQQ9989, world 58, guozhipin, kljladfaf, du juan, Kolans Panfentsa cool, yikastalik, zhangchangjiang4013, Menq, zheng20170204, Lungee, Konghouyin, Pianaiyi, Zezelin and Shalombait added to case caption.

NEW PARTIES: GROCERRY, hejiaao1746, hcfkguk, RokkuRii, qianzhifei89067741, TELEIKESI, CGJ001, FSdfgx, Jinhuibao Shoes, FIYO DIY 08, taogebaihuo, wangluju, linshujiao, Master ZHANG, linlian7737, ti66922shop, qzchuanchuan, huahuabaihuo, autoroad, FIYO Diamond Painting, TOP 5D Diamond Painting, sweet0526, fanzhihang123, liufengyingdfs, weaeggeew, leslie store, cenzibaijia, csfusoudfcoisd, wuw9922shop, haodingpujiao, vcdfre33, wangzeqi0505, zhaozhuo4822 and The Jersey Zone added to case caption.

NEW PARTIES: xinhuanjai, Baymaxx, 2019fangstore, huangjianyus, The Crafty Cove, Wangmin12345, R2R3, Armandogy, dandanbaihuo, Songjinyun778, NEELLY, Canvas painting printed artwor, dsakk, MAIXIN, khjeewan, Defendant 7, Defendant 8, Defendant 18, Defendant 40, Defendant 123 and Defendant 124 added to case caption.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 124 102*superdeals_33

MOTION by Plaintiff Art Licensing International, Inc. for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Art Licensing International, Inc. in support of motion for default judgment 34

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 119 Canvas painting printed artwor

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 34 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before August 9, 2024. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service.

CERTIFICATE of Service by Plaintiff Art Licensing International, Inc. regarding text entry, 37

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 34 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 marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants (Plaintiff has failed to seek an accounting of profits), the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $50,000 is an appropriate award of statutory damages. Enter Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED DEFAULT JUDGMENT ORDER Signed by the Honorable Lindsay C. Jenkins on 8/12/2024. Mailed notice.

SATISFACTION of Judgment as to defendant no. 12 QIUSUO

SATISFACTION of Judgment as to defendant no. 118 NEELLY