2024-cv-06187

COMPLAINT filed by TV Tokyo Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-22271852.

Exhibit 1

(Exhibit 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by John Wilson

MOTION by Plaintiff TV Tokyo Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SCHEDULE A by Plaintiff TV Tokyo Corporation Sealed Schedule A Modified on 9/5/2024.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 TV Tokyo Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff TV Tokyo Corporation 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 TV Tokyo Corporation in support of motion for temporary restraining order, 11

Declaration Saiki Declaration

Exhibit 1

Exhibit 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 1 of Saiki Declaration Modified on 9/5/2024.

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 2 of Saiki Declaration Modified on 9/5/2024.

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 3 of Saiki Declaration Modified on 9/5/2024.

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 4 of Saiki Declaration Modified on 9/5/2024.

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 5 of Saiki Declaration Modified on 9/5/2024.

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 6 of Saiki Declaration Modified on 9/5/2024.

EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 7 of Saiki Declaration Modified on 9/5/2024.

Notice of Claims Involving Trademarks by TV Tokyo Corporation

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Plaintiff's motion for leave to file under seal 7. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants 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 11, and motion to exceed page limitation 10. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 7/29/2024 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.

TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 7/25/2024. Mailed notice. (jcm) Modified on 9/5/2024.

SURETY BOND in the amount of $ 10,000 posted by TV Tokyo Corporation. (Document not imaged)

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order 27. The Temporary Restraining Order 25 shall now expire on 08/26/2024 at 6:00 p.m. Mailed notice.

ATTORNEY Appearance for Defendants Zisu, Cold Blade by Lance Y. Liu

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, Dnna Huang, DORTELLA, Feast of Yan, Feperig, gardner ruirui, Grand Di, Harbin Shang, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, kaisher, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, shangde hongtao, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, tina guo, Tsun Ki-sung, Wenchentel, Yaeerang, yuanyixindianzi, ZaiPingQin by Adam Edward Urbanczyk

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendants mincl, taoshangjing, Taizhou Yusu Trading Co., Ltd., shanghailange yanjingyouxia ngongsi, wulinsheng by Adam Edward Urbanczyk

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto (Text entry; no document attached.)

MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Certain Defendants

MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction 35

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 35

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

SUMMONS Returned Executed by TV Tokyo Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 8/26/2024, answer due 9/16/2024.

MOTION by Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Harbin Shang, Herlloy, Jagogh Yson, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Taizhou Yusu Trading Co., Ltd., Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, kaisher, mincl, shangde hongtao, shanghailange yanjingyouxia ngongsi, taoshangjing, tina guo, wulinsheng, yuanyixindianzi to set a briefing schedule UNOPPOSED

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion for preliminary injunction 35. The Court orders Plaintiff to resubmit a proposed order to the Court's proposed order inbox (Proposed_Order_Valderrama@ilnd.uscourts.gov) for the pending motion for preliminary injunction which excludes all Defendants that have appeared through counsel in this matter to date. The Court takes the motion under advisement. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is certain Defendants' unopposed motion to set briefing schedule 40. For the reasons stated in the unopposed motion, the Court grants the motion. Certain Defendants' response to the motion for preliminary injunction due 09/03/2024; Plaintiff's reply due 09/09/2024. Mailed notice.

RESPONSE by Cold Blade, Zisuin Opposition to MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Certain Defendants 35

MOTION by Defendants Zisu, Cold Blade to dismiss for Misjoinder

ATTORNEY Appearance for Defendant Newfancy by Christopher Paul Keleher

ATTORNEY Appearance for Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Harbin Shang, Herlloy, Jagogh Yson, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Taizhou Yusu Trading Co., Ltd., Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, kaisher, mincl, shangde hongtao, shanghailange yanjingyouxia ngongsi, taoshangjing, tina guo, wulinsheng, yuanyixindianzi by Brian Swift

RESPONSE by Taizhou Yusu Trading Co., Ltd., mincl, shanghailange yanjingyouxia ngongsi, taoshangjing, wulinshengin Opposition to MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Certain Defendants 35

Exhibit 1

(Declaration of Juhua Wu)

RESPONSE by Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, kaisher, shangde hongtao, tina guo, yuanyixindianziin Opposition to MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Certain Defendants 35

Exhibit 1

Declaration of Yanmei Tang

(Declaration of Ke Xiang)

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Defendants Zisu and Cold Blade's motion to dismiss for misjoinder 45. The Court sets the following briefing schedule: Plaintiff's response due 09/24/2024; Defendants' reply due 10/08/2024. Mailed notice.

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 35 is granted as to all defendants but appeared Defendants who have appeared via counsel. Enter Preliminary Injunction Order as amended. The following documents are to be unsealed: (1) Schedule A to the Complaint 8 ; (2) Exhibit 2 to the Declaration of Hiroaki Saiki [13-19]; and (3) the TRO 25. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. As for the Defendants who have appeared, the Court sets the following briefing schedule on the motion for a preliminary injunction: Defendants' response due 09/24/2024; Plaintiff's reply due 10/08/2024. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 9/4/2024. Mailed notice.

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Defendant Newfancy To Modify Asset Restraint (OPPOSED)

Exhibit Store principal declaration

Exhibit Amazon balance screenshot

Exhibit Payoneer balance screenshot

Exhibit Defendant order spreadsheet

(Exhibit Amazon order screenshot)

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Harbin Shang, Herlloy, Jagogh Yson, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Taizhou Yusu Trading Co., Ltd., Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, kaisher, mincl, shangde hongtao, shanghailange yanjingyouxia ngongsi, taoshangjing, tina guo, wulinsheng, yuanyixindianzi for leave to file excess pages

MINUTE entry before the Honorable Franklin U. Valderrama: The Court sets the following briefing on Defendant Newfancy's motion To Modify Asset Restraint 54 : Plaintiff's response due on or before 9/18/2024; Defendant's reply due on or before 9/25/2024. Mailed notice.

NEW PARTIES: ZZW store, ZYDERG, Zuo Bao-US, zhuosenbaihuodian, zhenzhenyouqunbaihuo, ZhangQiXun, zhangjinyangzhanpengshangmao, ZHANG2JING, Yunlong Oriental Pearl, Yujoe-US, YUGLS, Yug exports, Yosimi Bautista, yide business, yehuangkeji, YANNINGBM, yangqiuyang, XinDianXinShangDian, xiaocaioutlet, xianningdiaoyingdianzishangwuyouxiangongsi, XianBiaoYang store, XCS STORE, wuyueqibg, wudaoshi, weiranmaoyigongsi, WCaiYi, WanXiaoFeng, WANGJIJIYA, Waicmt, VINTECHKING, VA STOREX04, Tiantongjiu, tianshushangmaohsng, The anime century, Temporary Er Er, TeKX, SXXXSMH, STORE GURUS, STA Online, SmilingTown, Shuweier, SHOW SHOW, shenyangshisujiatunyanshubaihuodian, shandongzhengtawangluokejiyouxiangongsi, Seven Chakra Tree, Seeing the experience, runzongchangwanghaoely, Relabtaby, putianchengxiangchangyuxibaihuoshanghang, Pulle Attic, PNJGoldent, PINYUSHIPIN, pingdingshanyanshangmao, PerfectMT, PengzhiStore, ouyangmeilidexiaodian, Nostalgia Home, Newfancy, NAN bandshop, NAMNPH, You guys, YanJinWei, xiapinfo, XC cos, wenlinruiwangluokeji, Wadaliy, Vendiarit, USJICHENG TRADING, TomBeauty, TANYSSHUYAOHUDSHDFF, Tabitha Tam, suixianyibibaihuodiangetigongshanghu, Sudersana, Star-wish, Star Air, Spencer Jin, Sound Crane, SHUI LIAO, Saili, Said, RUILIHIAO, PUYA, Pakeliza, Naralimn, My Erika, Mw4n, MR.LAMP, MOEYI, mkpstuff, MITHOUSE, Mind logs, Mincl Glasses, MIAOXF Store, MIANHUATANGPET, Metal Dragon 77th, Meta Second, Merlun, Merkowski, meiruo, Martin Peng, Marpo Jor, MALITT, MaChao2004, M.Meteorite, Lydia Lyle, LUPPLEstore, Look at the place, LKNCOS, LiYu-us-Metalsign, liyihaoshop and liuliliposter added to case caption. (Text entry; no document attached.)

NEW PARTIES: LION, linposhu, linmo123, linli123456, Limit counts, lihekejiyouxiangongsi, LIHAOSTORE, LeMusi, LCYSHOP-USA, langyan1212, LAMILA Art, lagoet, Krorgeman, Kefa Trading Company, KANGSHUN Jewelry, jxxhpbh, JODZSWYXGS, JINGNIUSIBO, jinanlingfeishangmaoyouxiangongsi, jiale123, Jericho&Jess, It's a special castle, IMAKARA, HZXKL, HUIZHENHUIYI, Hucuic, HQG NeonSign, hottiemoo, HonRmon, HongjieYa, HNXGJJ, Henan Yishuang Trading Co., Ltd., Henan Wangdu Trading Co., Ltd, hefeikengcouxinxikejiyouxiangongsi, HATOKYO STORE, Hargrove Hare, Happy DJ S, GZCOS, GuangZhouHuaLiuShangMaoYouXianGongSi, Gocomcom, gangxiashangmaoyouxiangongsi, FUNTOPTOPKIDS, FUFIOR, fragrance shop, Four out of V, Forever Gems & Jewels, FFSMJYBXZ, fenglinghuabaihuohang, fen shop, February, FCXZI, fangwuduoshangmao, Enai, Elitabert, Elisa's Boutique Shop, East jingyy, DXSXX, DQ-Tech, donglinxing, Doller, DIY LIFE, Deng Zhihaohao, DECAL PROMAX, DANG HAI NGUYEN SHOP, DALLA DALLA, Dalichukj, Daihongguang, COSPLAY-USA, cool charms us, Compared to, Colored Flag, City, CHUNXIANGLOU, chenyubinhsyegbf, chenhaibo123, Camplos, C.X Trendy (Sorrica), BushCraft, Brdwn, bmarlf, BlaceAngcrlsy, binzhougaoxinquqiangzigaobaihuodian, binzhougaoxinqugangdunbaihuodian, binghe store, BHTCD, BDAYPRT, Banquetan, AYiNuEr TuoHeTi, AXVJKRTU, Authoritative World, Asa Jia, Anna_Kerenza, Anime Domain, anhua Jiaying, Alhaitha, AIYAYI Direct, Ainur Collection, A little Sellers, Yinxian Fengshou department store retail store, TH TrueSold, lvjun111 and gengyao added to case caption. (Text entry; no document attached.)

NOTICE by Taizhou Yusu Trading Co., Ltd., mincl, shanghailange yanjingyouxia ngongsi, taoshangjing, wulinsheng re response in opposition to motion, 48, withdrawal of opposition

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Defendants' motion for leave to file excess pages 56 and accepts and enters Defendants' responses to the preliminary injunction motion 48, 49, as well as the supporting declarations, as filed. The Court reminds Defendants, however, that the Court's Standing Order, requires that "[b]efore filing a motion, the movant's counsel must ask opposing counsel whether there is an objection to the motion. The motion should clearly indicate whether it is opposed or unopposed." Given the limited nature of the relief requested, the Court excuses Defendants' failure to indicate whether the motion is opposed in this instance, but going forward, the Court expects all parties to comply with the Court's Standing Order. Mailed notice.

REPLY by Plaintiff TV Tokyo Corporation Plaintiff's Reply in Support of its Motion for Entry of a Preliminary Injunction

Exhibit A

Exhibit B

Exhibit C

(Exhibit D)

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is certain Defendants Taizhou Yusu Trading Co., Ltd., mincl, shanghailange yanjingyouxia ngongsi, taoshangjing, wulinsheng's notice of withdrawal of opposition 58. Certain Defendants withdraw their Response in opposition to Plaintiff's motion for entry of preliminary injunction 48. Mailed notice.

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

RESPONSE by Plaintiff TV Tokyo Corporation Plaintiff's Response to the Motion to Modify the Asset Restraint of Defendant No. 151 "NEWFANCY" [Dkt. No. 54]

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Harbin Shang, Herlloy, Jagogh Yson, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, kaisher, shangde hongtao, tina guo, yuanyixindianzi to compel notice to Amazon, emergency

Exhibit 1

(Exhibit 2)

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 48

MOTION by Plaintiff TV Tokyo Corporation to strike Plaintiff's Motion to Strike the Motion to Compel [Dkt. No. 68]

REPLY by Newfancy to Response 64 In Support of Motion to Modify Asset Restraint

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Defendants' emergency motion to compel notice 68. In the motion, certain Defendants indicate that although there is no temporary restraining order or preliminary injunction order in effect to restrain their Amazon accounts, their Amazon accounts remain restrained. By 09/27/2024, Plaintiff may file a response limited to three pages indicating its position on the Amazon restraints as to certain Defendants, and whether Plaintiff opposes a Court order lifting those restraints, and the status of any communication efforts by Plaintiff with Amazon to lift the restraints as to certain Defendants. Mailed notice

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion to strike the motion to compel 70. In the motion, Plaintiff argues that certain Defendants' motion to compel should be stricken for certain Defendants' failure to comply with the federal and local rules, specifically failure to file a notification of affiliates pursuant to Federal Rule of Civil Procedure and Local Rule 3.2. The Court directs certain Defendants to file their notification of affiliates on or before 10/03/2024. Mailed notice

RESPONSE by Plaintiff TV Tokyo Corporation Plaintiff's Response to Defendants' Emergency Motion to Compel Notice [Dkt. No. 68]

(Exhibit A)

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Motion to Extend the Temporary Restraining Order Against Defendants Nunc Pro Tunc

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 110

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ahern Li, Coddle HSY, Feast of Yan, Grand Di, Murdoffi, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Tsun Ki-sung, Wenchentel, Yaeerang, tina guo

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Costmoon, DORTELLA, Dnna Huang, Feperig, HENRY A. KAUFMANN CONSTRUCTION LLC, Harbin Shang, Herlloy, LILI Poyd, PEMERLE, Qinfelicor, ZaiPingQin, gardner ruirui, kaisher, shangde hongtao, yuanyixindianzi

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ahanblaim, BESTOYARD, Jagogh Yson, Limicounts

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

REPLY by Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Harbin Shang, Herlloy, Jagogh Yson, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, kaisher, shangde hongtao, tina guo, yuanyixindianzi to Response 74

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion to strike certain Defendants' motion to compel 70. In Plaintiff's motion, Plaintiff argues that certain Defendants' motion to compel should be stricken for certain Defendants' failure to comply with the federal and local rules, specifically failure to file a notification of affiliates pursuant to Federal Rule of Civil Procedure and Local Rule 3.2. The Court directed certain Defendants to file their notification of affiliates on or before 10/03/2024, which they complied with. 79 80 81. On that basis, the Court denies Plaintiff's motion to strike the motion to compel 70 as moot. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Defendants' emergency motion to compel notice 68. In the motion, certain Defendants argue that the Court should order Plaintiff to notify Amazon that no asset restraints apply to certain Defendants' Amazon accounts. Certain Defendants have sought to have the asset restraints lifted from their accounts by contacting Amazon directly, however they have been unsuccessful to date. It is certain Defendants' position that Amazon will not lift restraints imposed by a TRO where the TRO expires without correspondence from Plaintiff's counsel or an order of the Court. Certain Defendants argue that it is prejudicial to continue restraining Defendants' access where no order for the restraint is in place. In response, Plaintiff argues the merits of its motion for preliminary injunction against certain Defendants. However, Plaintiff has not provided the Court with any authority to continue the restraints on the accounts of certain Defendants where no temporary restraining order or preliminary injunction order applies. By way of background, the TRO was entered on 07/25/2024 25 for a period of fourteen days and extended for an additional fourteen days on 08/08/2024 28. The TRO expired on 08/26/2024. 28 Since that time, Plaintiff has filed a motion for preliminary injunction 35, which certain Defendants oppose 43 49. Thus, there is currently no asset restraint or injunction entered against certain Defendants. On that basis, the Court grants certain Defendants' motion to compel notice 68. On or before 10/14/2024, Plaintiff must notify Amazon that the TRO has expired and any restraints on certain Defendants' accounts and their accused Amazon Standard Identification numbers (ASINs) may be lifted. The Court directs Plaintiff to file a notice of compliance with the Court by 10/15/2024. The opposed motion for preliminary injunction remains under advisement. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court denies Plaintiff's motion to extend the temporary restraining order against Defendants nunc pro tunc (TRO) 75. The TRO 25 has already been extended by a period of 14 days 28. Plaintiff has not argued that Defendants have consented to this extension. The Court declines to extend the TRO beyond the 28-day period, and denies the motion with prejudice. H-D Michigan, LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 844 (7th Cir. 2012) ("In our view, the language of Rule 65(b)(2) and the great weight of authority support the view that 28 days is the outer limit for a TRO without the consent of the enjoined party, regardless of whether the TRO was issued with or without notice.") Mailed notice.

Notice of Compliance by TV Tokyo Corporation

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of TV Tokyo Corporation

MOTION by Plaintiff TV Tokyo Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

(Exhibit A)

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment 89

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 89

(Exhibit Hierl Exhibit 1)

MOTION by Defendant Newfancy for extension of time to file answer regarding complaint 1 (UNKNOWN IF OPPOSED)

MOTION by Defendants Coddle HSY, Costmoon, Dnna Huang, DORTELLA, Feast of Yan, Feperig, gardner ruirui, Grand Di, Harbin Shang, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, kaisher, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, shangde hongtao, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, tina guo, Tsun Ki-sung, Wenchentel, Yaeerang, yuanyixindianzi, ZaiPingQin, Ahanblaim, Ahern Li, BESTOYARD for extension of time

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 64

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendant NEWFANCY's motion for extension of time to answer or otherwise respond to the complaint [92]. Defendant NEWFANCY's responsive pleading is now due 11/14/2024. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Pursuant to the notice of dismissal [66] of Defendant No. 36 Cold Blade and Defendant No. 169 Said, Defendants are dismissed from this action with prejudice, with all parties to bear their own attorneys' fees and costs. Defendants' motion to dismiss [45] is terminated as moot. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is certain Defendants' motion for extension of time [93]. For the reasons stated in the motion, the Court grants the motion. Certain Defendants' deadline to respond to the Complaint is extended to 11/25/2024. Mailed notice.

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 69

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion for default judgment [89]. By 11/10/2024, the Court directs Plaintiff to submit an amended proposed order which omits any appearing Defendants from the proposed default judgment order. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's motion for leave to file excess pages [88] and Plaintiff's motion for entry of default and default judgment [89]. Statutory damages are awarded in the amount of $150,000 per each distinct Defaulting Defendant as indicated in the order. Enter Default Judgment Order as amended. By 12/07/2024, Plaintiff is directed to file a status report as to the status of the case against the remaining defendants. To obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. Mailed notice.

DEFAULT JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 11/7/2024. Mailed notice.

MOTION by Defendant Newfancy to withdraw motion for miscellaneous relief, [54] (AGREED)

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 151 "NewFancy"

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendant Newfancy's agreed motion to modify the asset restraint [102]. The Court directs the Clerk to terminate Defendant Newfancy's motion to modify the asset restraint [54] as a motion. Pursuant to the notice of dismissal [103] of Defendant No. 151 NewFancy, Defendant is dismissed from this action without prejudice, with all parties to bear their own attorneys' fees and costs. Mailed notice.

MOTION by Defendants Coddle HSY, Costmoon, Dnna Huang, DORTELLA, Feast of Yan, Feperig, gardner ruirui, Grand Di, Harbin Shang, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, kaisher, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, shangde hongtao, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, tina guo, Tsun Ki-sung, Wenchentel, Yaeerang, yuanyixindianzi, ZaiPingQin, Ahanblaim, Ahern Li, BESTOYARD for extension of time

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated therein, the Court grants Defendants' motion for extension of time [105]. Certain Defendants' deadline to respond to the Complaint is extended to 12/27/2024. Mailed notice.

STATUS Report by TV Tokyo Corporation

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed Plaintiff's status report [107], which identifies the remaining defendants in this matter. On or before 01/10/2025, the parties shall file a joint initial status report. A template for the Joint Initial Status Report, setting forth the information required, may be found at http://www.ilnd.uscourts.gov/Judges.aspx by clicking on Judge Valderrama's name and then again on the link entitled Joint Initial Status Report. The parties are further ordered to review all of Judge Valderrama's standing orders and the information available on his webpage. Any nongovernmental corporate party that qualifies under the Rules is reminded of the requirement to file a disclosure statement under Federal Rule of Civil Procedure 7.1/N.D. Ill. Local Rule 3.2. Mailed notice.

SATISFACTION of Judgment

MOTION by Defendants Coddle HSY, Costmoon, Dnna Huang, DORTELLA, Feast of Yan, Feperig, gardner ruirui, Grand Di, Harbin Shang, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, kaisher, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, shangde hongtao, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, tina guo, Tsun Ki-sung, Wenchentel, Yaeerang, yuanyixindianzi, ZaiPingQin, Ahanblaim, Ahern Li, BESTOYARD for extension of time

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 Franklin U. Valderrama: For the reasons stated therein, Defendants' motion for extension of time [110] is granted in part over Plaintiff's objection. Defendants shall respond to Plaintiff's complaint by 01/13/2025. No further extensions will be granted. The 01/10/2025 deadline for the initial joint status report is stricken and reset to 01/27/2025. Mailed notice.

SATISFACTION of Judgment

ANSWER to Complaint by Coddle HSY, Costmoon, Dnna Huang, DORTELLA, Feast of Yan, Feperig, gardner ruirui, Grand Di, Harbin Shang, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, kaisher, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, shangde hongtao, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, tina guo, Tsun Ki-sung, Wenchentel, Yaeerang, yuanyixindianzi, ZaiPingQin, mincl, taoshangjing, Taizhou Yusu Trading Co., Ltd., shanghailange yanjingyouxia ngongsi, wulinsheng, Ahanblaim, Ahern Li, BESTOYARD

STATUS Report Joint Status Report by TV Tokyo Corporation

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed the parties' joint initial status report [115]. The deadline for amendments to the pleadings is 3/28/2025. The Court refers discovery supervision (including setting all deadlines, resolution of any discovery motion, and resolution of any motion to stay discovery), resolution of Plaintiff's motion for preliminary injunction [35] as to all appearing Defendants, and settlement matters to Magistrate Judge Jantz. Mailed notice.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Beth W. Jantz for the purpose of holding proceedings related to: Discovery Supervision (including setting all deadlines, resolution of any discovery motion, and resolution of any motion to stay discovery), resolution of Plaintiff's motion for preliminary injunction [35] as to all appearing Defendants, and settlement matters. (jcm). Mailed notice.

MINUTE entry before the Honorable Beth W. Jantz: This case has been referred to Magistrate Judge Beth W. Jantz for discovery supervision, Plaintiff's motion for preliminary injunction [35], and settlement. A status hearing is set for 2/7/25 at 11:30 a.m. to discuss a proposed discovery schedule and any interest in settlement. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. 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 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. Mailed notice.

MINUTE entry before the Honorable Beth W. Jantz: The telephonic status hearing on 2/7/25 is reset to 2/7/2025 at 10:15 a.m. Time change only. Call in information to remain. Mailed notice.

MINUTE entry before the Honorable Beth W. Jantz: Status hearing held on 2/7/25 and continued to 5/22/25 at 1:45 p.m. The parties update the Court on settlement discussions, Plaintiff tendered an initial settlement offer, and the Defense is to respond in advance of the next status. Initial disclosures and written discovery requests are due to issue by 2/28/25, with a fact discovery deadline of 7/25/25. At the next status, the parties will report on the status of discovery and settlement interest. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. 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 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. Mailed notice.

MINUTE entry before the Honorable Beth W. Jantz: The status hearing currently scheduled for 5/22/25 is advanced to 4/16/25 at noon Central, for an in person status hearing in Courtroom 1812, in order to discuss the progress of written discovery, settlement progress, and the pending motion for a preliminary injunction. Mailed notice.

MOTION by Attorney Adam E. Urbanczyk and Brian Swift to withdraw as attorney for Harbin Shang, kaisher. New address information: See attached Party Contact Forms Presented before District Judge

Declaration of Yanmei Tang

Declaration of Ke Xiang

Errata Party Contact Form, Harbin Shang

Errata Party Contact Form, kaisher

MOTION by Defendants Ahanblaim, Ahern Li, BESTOYARD, Coddle HSY, Costmoon, DORTELLA, Dnna Huang, Feast of Yan, Feperig, Grand Di, HENRY A. KAUFMANN CONSTRUCTION LLC, Herlloy, Jagogh Yson, LILI Poyd, Limicounts, Murdoffi, PEMERLE, Qinfelicor, Qiysangi, Saieli, Shannon Wenha, Spring TU, Star Aier, Summer Seconds, Tsun Ki-sung, Wenchentel, Yaeerang, ZaiPingQin, gardner ruirui, shangde hongtao, tina guo, yuanyixindianzi for extension of time to respond to certain discovery requests Presented before Magistrate Judge

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, Attorney's Adam E. Urbanczyk and Brian Swift's motion to withdraw 122 is granted. By 05/02/2025, Defendants Harbin Shang and kaisher shall retain new counsel. The Court notes that corporations are not permitted to represent themselves in federal court. See 1756 W. Lake St. LLC v. Am. Chartered Bank, 787 F.3d 383, 385 (7th Cir. 2015) (noting the "requirement that a limited liability company be represented in litigation by a lawyer"); Philos Techs., Inc. v. Philos & D, Inc., 645 F.3d 851, 858 (7th Cir. 2011) ("[C]orporations must appear by counsel or not at all.") Failure to obtain substitute counsel by the date set forth above may subject the corporate Defendants to the entry of an order of default and ultimately to the entry of a default judgment. The Clerk of the Court is directed to update (1) Defendant Harbin Shang's contact information to No. 43, Heshan Street, Daoli District, Harbin, Heilongjiang Province, China, 150000 as stated in [122-3] and (2) Defendant kaisher's contact information to No. 001652, Room 206, Building 6, No. 1, Dongke Road, Dongcheng Street, Dongguan, Guangdong Province, China, 523000 as stated in [122-4]. By 04/07/2025, withdrawing Attorneys Urbanczyk and Swift must: (1) serve a copy of this order on Defendants Harbin Shang and kaisher's representative; and (2) file a certificate of compliance on the Court's docket stating that counsel has done so. Mailed notice.

CERTIFICATE of Compliance [Dkt. 124]

MINUTE entry before the Honorable Beth W. Jantz: The Court is in receipt of Certain Defendants' Motion for Extension of Time to Respond to Certain Discovery Requests 123. The Motion will be addressed at the April 16, 2025 in person status hearing. Mailed notice.

MINUTE entry before the Honorable Beth W. Jantz: The parties appeared for an in-person status hearing on April 16, 2025. The parties reported on the ongoing status of discovery, including exchanging responses to discovery requests. Certain Defendants' Motion for Extension of Time to Respond to Certain Discovery Requests 123 is granted. Defendants' deadline to respond to Plaintiff's discovery requests is extended to April 21, 2025. The parties also reported that they have been participating in productive settlement talks. The parties (through counsel) shall appear for an in-person status hearing on May 21, 2025 at 10:15 AM, in Courtroom 1812 for a status hearing to discuss settlement and the progress of discovery. The parties should be prepared to report their clients' current settlement positions to the Court. Mailed notice.

SATISFACTION of Judgment

MINUTE entry before the Honorable Beth W. Jantz: In Court hearing held on 5/21/25. The parties report that a settlement has been reached as to all Defendants that were referred before the Magistrate Judge [116-17]. The portions of the motion at 123 that are still pending are DENIED as moot. A telephonic status hearing is set on 7/24/25 at 11:45 a.m. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. The status hearing will be cancelled, and no one need call in, if a stipulation to dismiss is filed with the District Judge prior to the hearing. Mailed notice.

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of TV Tokyo Corporation

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A Presented before District Judge

(Exhibit A)

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment, 131

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 131

(Exhibit Hierl Exhibit 1)

DEFAULT JUDGMENT ORDER: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment 131. Statutory damages are awarded in the amount of $ 150,000 per each distinct Defaulting Defendant as indicated in the Order. Enter Default Judgment Order. The remaining parties have indicated that they have reached a settlement agreement. Accordingly, the parties shall file a joint status report by 06/09/2025 indicating when a stipulation to dismiss will be filed. The bond posted in this case will be returned upon the filing of the stipulation to dismiss. Enter Default Judgment Order. Signed by the Honorable Franklin U. Valderrama on 6/2/2025. Mailed notice.

STIPULATION of Dismissal Stipulation of Voluntary Dismissal

STATUS Report Joint Status Report by TV Tokyo Corporation Presented before District Judge

MINUTE entry before the Honorable Beth W. Jantz: In light of the Stipulation of Dismissal 135, all matters related to the referral of this action to Judge Jantz are resolved. The case is returned to the assigned district judge. The July 24, 2025 status hearing before Judge Jantz is stricken. Referral terminated. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed the parties' joint stipulation of voluntary dismissal 135 and joint status report 136, which indicate that a settlement has been reached as to all remaining Defendants. The ten thousand dollar ($10,000.00) surety bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd., 70 West Madison St. Suite 4000, Chicago, Illinois 60602 via certified mail. Civil case terminated. Mailed notice.

MAILED ten thousand dollar ($10,000.00) surety bond posted by Plaintiff to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd., 70 West Madison St. Suite 4000, Chicago, Illinois 60602 via certified mail #7001 2510 0005 7681 7297. (Text entry; no document attached.)

MAILED final trademark report with a copy of minute entry 138 to Patent Trademark Office, Alexandria VA

MAILED ten thousand dollar ($10,000.00) surety bond posted by Plaintiff to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd., 70 West Madison St. Suite 4000, Chicago, Illinois 60602 via certified mail #7001 2510 0005 7681 7297. (Text entry; no document attached.)