2024-cv-05162

COMPLAINT filed by Sega Corporation, Sega of America, Inc.; Filing fee $ 405, receipt number AILNDC-22164978.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sega Corporation, Sega of America, Inc.

Notice of Claims Involving Trademarks by Sega Corporation, Sega of America, Inc.

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Alexander Whang

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.)

MEMORANDUM by Sega Corporation, Sega of America, Inc. Establishing that Joinder is Proper

Declaration of Martin F. Trainor

Exhibit 1

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[11]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Exhibit 3, Parts 1-12 regarding declaration[13]

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[15]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion for a temporary restraining order [11], motion for electronic service of process [15], and motion to file certain documents under seal [3]. Provided that Plaintiff provides the security described in paragraph 10 of the temporary restraining order, the temporary restraining order shall become effective on 7/2/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 6/26/2024. Mailed notice.

SUMMONS Issued as to Defendant The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ $10,000.00 posted by Sega Corporation, Sega of America, Inc.

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[20]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order [20]. The Temporary Restraining Order [18] shall now expire on 07/30/24 at 6:00 p.m. Mailed notice.

ATTORNEY Appearance for Defendant makemesurprise.com by Hua Chen

SUMMONS Returned Executed by Sega Corporation, Sega of America, Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 7/25/2024, answer due 8/15/2024.

Declaration of Sydney Fenton

Exhibit A

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for preliminary injunction[25]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction [25] is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint [2]; (2) Exhibit 3 to the Declaration of Paul Varley [14]; and (3) the TRO [18]. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 7/26/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain Defendant

NEW PARTIES: Shenzhen Jinghang Technology Co., Ltd., Gent-le, A.ZHAOZHUANG01, ALPXEL LTD, arpinz356, banana1211, BaweiWBA, beijingchangyueshundashangmaoyouxiangongsi, bhskuydeo, BOYUE INC, BOZICRE, C JIA-US, Cartoon household Store, CBYchuil24042, damingxianzhemaoyiyouxiangongsi, DINGPENG INC, dingqianghe, Dotrewes, EIKOU Shop, engJianGuangMuShangM, FANG LIAN, FULANJUAN, GaoJiaNi0706, GERIYIWANG, GuangZhouFengYangDianZiShangWuYouXianGongSi, guangzhoulianqianshangmaoyouxiangongsi, Guanlian E-commerce, GuanTiAodianzi, guchengxianruantishangmaoyouxiangongsi, GW Department Store, HaosHanMao, hchaobaihuo, hefeinianjuesidianzishangwuyouxiangongsi, hefeizhouxinghaoshangmaoyouxiangongsi, HENGFAQIAN, HONRG, HUJUNJIE, HUSEYIN UMUT GUNAYDIN, iceicepick, jiangdianmiss, jiaoxcuioaiau, jiayi-2, JIEYEE, JINGWEEN, JINXISHANG, kangjunshop, KGLBOY, KUNKUA, kunminglinniwoshangmaoyouxiangongsi, Lebowski & Co. STORE, LHcang, LinChaoyang, LIU1HONGMEI, liufurongdediandian, LIYUNBOO, Lunovation, LWTLKEEA-US, malashangmao, Mandaqueen, MENGLIANGUS, MI Sell, MinShaoDianZidd, Molandra, niangpushangmao, Nttlom, pingdingruiguangshangmaoyouxiangongsi, putianshichengxiangquyerenmaoyiyouxiangongsi, QUANDANG, Responding, RonKon, Sannelchel, Saybz Decor Store, SHI1YUANQING, shijianjingvt, ShiKeDirect, Slestping, SUBALACI, sunfaye, Super party, Terri Hinchey, Tiorga, UITSSA, UMIT CAN YALCIN, USLEH, utminhshop, vfgsbuighvsihgjdf, VINDIJA US, WANG2JIANHAO, WENWAN US, Wu J J, wuhanyulangaokeji, XDJQJGSNC, xiangyangshilengyingxishangmaoyouxiangongsi, xiangyangshisongqinghuishangmaoxing(gerenduzi), XiaoNongMaoYi, xintaishikuwanshangmaoyouxiangongsi, XTNBX, Xuntuan, Yayiha, YERHFHSDSSS, yiwushilouyimaoyiyouxiangongsi, YueJi US, Zhang Xiang Shop, ZHENFULAITIE, ZHONGYINGXUE, ZHU1HONGHE, zzshdz, A3IB2P3Q3PYUT, A2F1V19O1J4Y7I, AH8IM1WASMW0H, clockcanvas, ezovoze, ezzystore, foxbackdrop, Inxiz Store, TeeDucky, trilogygift, uhoodie, Ahe E-commerce Co., Ltd, Bnostalgia Co.Ltd, ruhuashiyu, Siqiy, WEI XU, Quanzhou Economic And Technological Development Zone Tiyou Trading Co., Ltd., babyhoome, chenxinjieyishuhaibao, dingyuhaimaoyi, ErikaReyna, GANNLEA, hefeifenggeshangmaoyouxiangongsi, Huadong Shop, JFKDSUSDH, Jnshengyao, LANJGJIAYAN, lianpinshangmaoyouxiangongsi, make.anni, Sylvia&Vicky Studio, SYUJ, tongshanxianzhitongbodianzishangwuyouxiangongsi, Vanezza Clothes Store, XU - CHAO, yongjitaiyiwangluokejiyouxiangongsi, zhanghongqinyingzenan, A1X8I37P8P43LW, 59vibefashion, aminibi, Carneyforia, casecentro, casemiya, caserare, Dolerstore, Edson Marques, fantasypillow, favomerch, ilybag, ipeepz, KAMANDAKA, merchprintz, MICESTATION, Oxvistore, PERSPIRATURE, plushyspace, safespecial, saloreea, Storebunch, Teeruto, velturas, vintagebrassstore, Younghoodie, BEAU HOME, Customgic, feirentiyu, GoodGoods, jinanyunwenxin, Jingyu Cases, putianshichengxiangquhengtuomaoyi, WuHanShiXiongAnHan and Raposurf added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

WAIVER OF SERVICE returned executed by makemesurprise.com. makemesurprise.com waiver sent on 7/19/2024, answer due 9/17/2024.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

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; andIT 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 Franklin U. Valderrama no longer assigned to the case. Signed by Honorable Virginia M. Kendall on 8/23/2024.

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal, Defendants No. 8, 61, 107, 109 and 126 chenxinjieyishuhaibao, zzshdz, MI Sell, "'(), beijingchangyueshundashangmaoyouxiangongsi are dismissed with prejudice.

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal, Defendants No. 6, 30, 101, 118, 145 uhoodie, yiwushilouyimaoyiyouxiangongsi, GW Department Store and banana1211, 59 vibefashion are dismissed with prejudice.

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal, Defendants No. 19, 99, 137, 155 Yayiha, ilybag, EIKOU Shop and Sylvia&Vicky Studio are dismissed with prejudice.

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal, Defendants No. 40, 56, 72, 89, 146 and 151, aminibi, Lunovation, Saybz Decor Store, jiangdianmiss, Wenwan US and Dolerstore are dismissed with prejudice. Plaintiff's status report on the status of the remaining Defendants is due by 9/10/24.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of dismissal under Rule 41(a)(1), Defendant No. 36 HONRG is dismissed with prejudice.

STATUS Report by Sega Corporation, Sega of America, Inc.

Exhibit A

MINUTE entry before the Honorable Georgia N Alexakis: The Court has reviewed plaintiffs' status report [14]. Plaintiff is directed to file any motion for entry of default and for default judgment with respect to any non-responsive defendants on or before 10/8/24 and to notice this motion up for presentment before the Court.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of dismissal, Defendants No. foxbackdrop [114], ipeepz [156], Younghoodie [169] and clockcanvas [111] are dismissed with prejudice.

MOTION by Defendant makemesurprise.com for extension of time to file answer regarding complaint[1] UNOPPOSED

NOTICE of Motion by Hua Chen for presentment of motion for extension of time to file answer[48] before Honorable Georgia N Alexakis on 9/24/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Defendant No. 153, Fantasypillow's unopposed motion for an extension of time until 10/8/24 to respond to the complaint [48] is granted. No appearance is required on the motion.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for entry of default, MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, [53]

Exhibit 1

Exhibit 2

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[54]

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment, [53] before Honorable Georgia N Alexakis on 10/21/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis:Pursuant to the notice of voluntary dismissal, Defendants No. 144, No. 12 C JIA-US and No. 153 fantasy pillow are dismissed with prejudice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal per Federal Rules of Civil Procedure 41(a)(1), Defendant No. 67 putianshichengxiangquyerenmaoyiyouxiangongsi and No. 127 dingyuhaimaoyis are dismissed with prejudice.

MINUTE entry before the Honorable Georgia N Alexakis: Motion hearing held on 10/21/24. For the reasons stated on the record, plaintiff's motion for entry of default and default judgment [53] is entered and continued. Plaintiff's supplemental memorandum is due by 11/18/24.

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, [53] Supplemental

Declaration of Martin F. Trainor

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment, [53] before Honorable Georgia N Alexakis on 11/25/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis:Motion hearing held on 11/25/24. Defendants were not present. Plaintiff's motion for entry of default and for default judgment [53] is granted. Enter default judgment order. The ten thousand dollar ($10,000) surety bond posted by plaintiff is hereby released to plaintiff or its counsel, TME Law, P.C., and the Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to plaintiff or its counsel. Civil case terminated.

DEFAULT JUDGMENT ORDER Signed by the Honorable Georgia N Alexakis on 11/25/24.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Sega Corporation and Sega of America, Inc. to Tme Law, P.c. 10 South Riverside Plaza 875 Chicago, IL 60606 via certified mail #9589 0710 5270 0579 7825 33 (Text entry; no document attached.)

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7825 33 (Received by mail in the Clerk's Office on 12/17/24.)