2024-cv-06194

COMPLAINT filed by Anagram International, LLC; Filing fee $ 405, receipt number AILNDC-22272925.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SCHEDULE A to Complaint by Plaintiff Anagram International, LLC Schedule A to Complaint 1 Modified on 8/28/2024.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Christopher Romero

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Anagram International, LLC

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 3). (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 Anagram International, LLC for leave to file under seal

MOTION by Plaintiff Anagram International, LLC for leave to file excess pages

MEMORANDUM in Support of 14 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Christopher Wiles

(Exhibit 1, of Christopher Wiles' Declaration)

EXHIBIT 2 by Plaintiff Anagram International, LLC to the Declaration of Christopher Wiles in support of memorandum in support of 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 e-mail and/or electronic publication 15 Modified on 8/28/2024.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

Exhibit 2-8

Exhibit 2-9

Exhibit 2-10

Exhibit 2-11

Exhibit 2-12

Exhibit 2-13

(Exhibit 2-14)

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 12 and motion to file excess pages 13 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order (etc.) 14 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 8/7/2024 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 980-394-33. Any motion for preliminary injunction or motion to extend the TRO must be filed by 8/2/2024. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. Plaintiff is directed to promptly serve summonses and not to wait until too close to the preliminary injunction hearing so that the defendants may have a fair opportunity to appear and oppose the anticipated motion for preliminary injunction. Mailed notice.

EX PARTE Temporary Restraining Order: Signed by the Honorable Matthew F. Kennelly on 7/24/2024. Modified on 8/28/2024.

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 Anagram International, LLC. (Document not scanned). (jn,)

MOTION by Plaintiff Anagram International, LLC for preliminary injunction

MEMORANDUM by Anagram International, LLC in support of motion for preliminary injunction 20

Declaration of Keith A. Vogt

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

SUMMONS Returned Executed by Anagram International, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/31/2024, answer due 8/21/2024.

Declaration of Service, Keith A. Vogt

(Exhibit 1, Declaration of of Service, Keith A. Vogt)

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic preliminary injunction hearing held on 8/7/2024. On its own motion, the Court extends the temporary restraining order to 8/21/2024. The telephonic preliminary injunction hearing is reset to 8/21/2024 at 9:00 a.m. The following call-in number will be used: 650-479-3207, access code 980-394-33. 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.

ATTORNEY Appearance for Defendant Mapanwen by He Cheng

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

ATTORNEY Appearance for Defendants INFLORAL, Changlei Grocery store by Pete Scott Wolfgram

MOTION by Defendants Changlei Grocery store, INFLORAL for extension of time to Answer Complaint (Unopposed)

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MOTION by Defendant Mpanwen for extension of time to file answer regarding complaint 1

ATTORNEY Appearance for Defendant Cheerland by Huicheng Zhou

MOTION by Defendant Cheerland for extension of time

ATTORNEY Appearance for Defendants jadelian, Kozeelife by Christopher Paul Keleher

MOTION by Defendants Kozeelife, jadelian for extension of time to file answer regarding complaint 1 (UNOPPOSED)

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MOTION by Defendant Cheerland for extension of time to file response/reply as to motion for preliminary injunction 20

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic preliminary injunction hearing held on 8/21/2024. The motions for extension of time 27 29 31 33 are granted. All deadline dates are extended to 9/19/2024. The motion for preliminary injunction 20 is granted. Preliminary injunction order to follow. The case is set for a telephonic status hearing on 10/18/2024 at 8:55 a.m. The following call-in number will be used for the hearing: 650-479-3207, access code 980-394-33. The parties are directed to file a joint status report by 10/11/2024. The Clerk is directed to unseal any documents that were previously filed under seal. Law Firm JiangIP LLC and Keith Vogt, Ltd. are 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. 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.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 8/21/2024. Mailed notice.

ATTORNEY Appearance for Defendant softened by Michael Thomas Stanley Defendant No. 24 softened

MOTION by Defendant softened for extension of time to file answer regarding complaint 1

ATTORNEY Appearance for Defendants HengTongDa, zhongshanshiruida, COCOA (KOOKOOG), KYGNE, WEALLIN STORE, LeiYiDianZiShangWu, Lingqiang-US by Christopher Paul Keleher

MOTION by Defendants COCOA (KOOKOOG), HengTongDa, KYGNE, LeiYiDianZiShangWu, Lingqiang-US, WEALLIN STORE, zhongshanshiruida for extension of time to file answer regarding complaint 1 (UNOPPOSED)

ATTORNEY Appearance for Defendants AKIO CRAFT, Alay US, Aweson Party, enjoy market, freelee, FUEAWIM, GolrayDirect, Hokilands, Keleno US, Winrayk, With a fine by Adam Edward Urbanczyk

MOTION by Defendants AKIO CRAFT, Alay US, Aweson Party, FUEAWIM, GolrayDirect, Hokilands, Keleno US, Winrayk, With a fine, enjoy market, freelee for extension of time

(Vogt, Keith) (Entered: 08/22/2024) (Text entry; no document attached.)

MINUTE entry before the Honorable Matthew F. Kennelly: Motions for extension of time 39 41 43 are granted; responses to complaint are to be filed by 9/19/2024.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 21 NOVIPEROW

NEW PARTIES: AIQINHU, Balloon Cabin, Blingparty, EnShiShiMiaoHuoBaiHuoYouXianGongSi, FECEDY, FECLOUD Direct, GLS-Party Store, Halloluck, Huhudde, IEMIEBSHA, Jadelian, Jiahao shop US, JuFaDianZi, JUMINE, Kozeelife, Ladovin, magiczoo, Mairubo, MeeROR SHOP, NOVIPEROW, Ruyi, singyico, weiwodianzi, WSAFO2013, xingshanyaobaihuo, XINYIDAO, Youngy, Yullmu Direct, Fancypartyshop, GREATWILD, Also, maxfor, xingogo, 3buy564, Adomius, Amandir Store, Anqing Jiayi Building Material Co., Ltd., Arioered Direct, CLMY, COCOA, CUTEUP, CY ggde and Diballoond ability added to case caption. (Text entry; no document attached.)

NEW PARTIES: FSLF PartyDecor, Goneby, GOODBUY., HCQCJ, HoHoParty, Heusnlaj-US, Hokoad US, Jiang Yang, JinXL, Kawailay-US, LianAnMaoYiYouXianGongSi, LIN-HA, LiYi trade, Neo LOONS, OMTU large, Refasy, Shenzhenshimingjunmaoyi, siumir-us, Tyydz, WLBHD-US, XJ trade, YOTHORN, ZERODECO, junsen Partyline and Beauty Pro. added to case caption. (Text entry; no document attached.)

NEW PARTIES: Kunyu Home, PYROSOME, Cuddly Home, Enjoy Party Store, HAIPA, BlueseaWYH, CBLUO, Chen Wenjiang, HAI YUAN, henanpucuimaoyiyouxiangongsi, KIHOARL, Mall of Ghaon, NYDREAM, TACYKIBD, Tchliarn, ZHUOLINBALLOON, ANHUIRUIJINGSHANGMAO, Eaych US Direct and GoodYH added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Anagram International, LLC for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Anagram International, LLC in support of motion for default judgment 48

NEW PARTIES: HaoTe Mall, Hottong, Nuoyifan, StarryParty, partytime, Aunifun, Fxozru-US, Hefei Shuangzaizai Trade Co., Ltd, Lemon Breeze, OKA Direct, PLEASE CLOSE, WEALLIN STORE, WRuizhe, ATSMOICY, Beliueyes, HQun Seller, Kistreao Direct, LZGQXF, SFSL, sunnylifyau, TuRin, Wish you goodluck, xinganxianwanyuanmaoyiyouxiangongsi, Geofun, JOPHMO US and Street added to case caption. (Text entry; no document attached.)

NEW PARTIES: Changlei Grocery store added to case caption. (Text entry; no document attached.)

NEW PARTIES: DuoDuozw and Flohuaer Shop added to case caption. (Text entry; no document attached.)

NEW PARTIES: freelee, Bidbigdeals, crazysweet, ebuymall360, elaesh, mr.8, owlmall, phcmall, tworabbit, violet0, wonderfine, DOITIANS, INparty, MASTORE, Star Holdings-US, WITH-G-BO, Yartifun, YiYou., disrespectful, Greatbobo, HOURIUS, LIN DANDAN, party maker, TSLin, Weenkeey-US, WHYMEO US, huozhoushilanqimaoyidian, Chuanyin, DOOVE and DXary added to case caption. (Text entry; no document attached.)

NEW PARTIES: Fezava, Food-usa, HAIOPS, JEWELERY WINDOW, OHLIGEI, SBYURE, SHENLI, Staringirl, Value Bar, YL Decor, ZCMG, ZOYO-CMC, bison, LeiYiDianZiShangWu, LQANG, PAIT, Scorpio Balloon, Wing, FANGSHENGKEJI, AnnoDeel, BoningNEW, JeVenis, JOYMEMO, Weloves, Bigjia Direct, JYIN Trade, partylinks, santonila, RoaringGoodTime, SSS-Swag, AP ENTERPRISES STORE, Dolleme Direct, FashionTrendGarden, HongYanQingUS, QingMeng US, Weitenggogo, Bonropin, Dripykia, Hilight Store US, Miaoce, Niceter, Sunjustly, HasAura, An Peri MEE, BinaryABC, Know me, VIVIKING, LaVenty, Morndew, Virtue morals, wanglingli1230, GoerDirect, PIBIPAID, Tedercle, Yeqot, ieventsin party store, Ouddy-Life, DecorWoo, VHUWE Party Supplies, qutuqi-us, Qukpa Direct, Wetco, Party Flag, Defendant 66, Defendant 69 and Defendant 117 added to case caption. (Text entry; no document attached.)

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

ATTORNEY Appearance for Defendants Balloon Cabin, JOYMEMO, junsen Partyline, partytime by Yong Chen

ATTORNEY Appearance for Defendants CY ggde, Hokoad US by Christopher Paul Keleher

MOTION by Defendants CY ggde, Hokoad US for extension of time to file answer regarding complaint 1

ATTORNEY Appearance for Defendants JeVenis, LaVenty, RoaringGoodTime by Christopher Paul Keleher

MOTION by Defendants JeVenis, LaVenty, RoaringGoodTime for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Matthew F. Kennelly: Motions by defendants CY ggde, Hokoad US, JeVenis, LaVenty, RoaringGoodTime for extension of time 52 54 are granted; deadline for those defendants to respond to the complaint is extended to 9/13/2024. Plaintiff's counsel should submit a revised draft order on its recently filed motion for default judgment deleting these defendants from the draft order.

MOTION by Defendants Balloon Cabin, JOYMEMO, junsen Partyline, partytime for extension of time to file answer regarding complaint 1

ATTORNEY Appearance for Defendants Hefei Shuangzaizai Trade Co., Ltd, Ouddy-Life, PYROSOME by Timothy Tiewei Wang

MOTION by Defendants Hefei Shuangzaizai Trade Co., Ltd, Ouddy-Life, PYROSOME for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Matthew F. Kennelly: Motions by defendants Balloon Cabin, JOYMEMO, junsen Partyline, and partytime 56, and by defendants Hefei Shuangzaizai Trade Co., Ltd, Ouddy-Life, and PYROSOME 58 for extension of time are granted; responses to complaint are to be filed by 9/16/2024. Plaintiff is directed to submit a revised draft order on its motion for default judgment removing these defendants the list of those as to which default judgment is requested.

MOTION by Plaintiff Anagram International, LLC to withdraw motion for default judgment 48

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for default judgment 48 is withdrawn.

ATTORNEY Appearance for Defendant Chuanyin by Adam Edward Urbanczyk

MOTION by Defendant Chuanyin for extension of time

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendant Chuanyin for extension of time 63 is granted; response to complaint is to be filed by 9/20/2024. This does not affect any other date or deadline set by the Court.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable Matthew F. Kennelly: Order: It has come to the Court's attention that the access code for its telephonic conference line was changed without notice. For any telephonic hearing set in this case the following call-in number will be used: 650-479-3207; access code 2305-915-8729. That is the number that should be used for any telephonic hearing in this case after today's date. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

ATTORNEY Appearance for Defendants Fancypartyshop, santonila by Yong Chen

MOTION by Defendants Fancypartyshop, santonila for extension of time to file answer regarding complaint 1

ANSWER to Complaint by Mpanwen

MOTION by Defendant Mpanwen for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Matthew F. Kennelly: Motions by defendants Fancypartyshop, santonila and Mpanwen for extension of time 74 76 are granted; responses to complaint are to be filed by 9/30/2024. This does not affect any other date or deadline set by the Court.

MOTION by Defendant Cheerland to amend/correct SEALED Order 18

MINUTE entry before the Honorable Matthew F. Kennelly: Motion to unfreeze assets or to modify TRO is set for a telephonic hearing on 10/2/2024 at 8:50 AM, using call-in number 650-479-3207, access code 2305-915-8729. Plaintiff is directed to file a response to the motion by 9/27/2024.

MOTION by Plaintiff Anagram International, LLC for extension of time JOINT AGREED

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 3 Blingparty

MOTION by Plaintiff Anagram International, LLC for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Anagram International, LLC in support of motion for default judgment 83

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 198 santonila

MINUTE entry before the Honorable Matthew F. Kennelly: Agreed motion for extension of time 80 is granted. Due date for plaintiff's response to defendant Cheerland's motion to unfreeze (etc.) is extended to 10/11/2024. The telephonic motion hearing set for 10/2/2024 is vacated and reset to 10/16/2024 at 8:55 AM, using call-in number 650-479-3207, access code 2305-915-8729.

DEFAULT JUDGMENT ORDER AS TO CERTAIN DEFENDANTS signed by the Honorable Matthew F. Kennelly on 9/27/2024: Motion for entry of default judgment as to certain defendants 83 is granted.

MOTION by Plaintiff Anagram International, LLC for extension of time JOINT

ATTORNEY Appearance for Defendant FUEAWIM by Baruch Simcha Gottesman

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 164 AKIO CRAFT

STATUS Report Pursuant to Minute Entry 36 by Anagram International, LLC

MINUTE entry before the Honorable Matthew F. Kennelly: Motion for extension of time 88 is granted; deadline for response to defendant Cheerland's motion to amend is extended to 11/1/2024. The telephonic hearing set for 10/18/2024 is vacated and reset to 11/12/2024 at 9:10 AM, using call-in number 650-479-3207, access code 2305-915-8729. A joint status report regarding all remaining defendants is to be filed on 11/5/2024 unless the remaining defendants have been dismissed before that date.

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic hearing set for 10/18/2024 is vacated.

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant no. 132 Cheerland

MINUTE entry before the Honorable Matthew F. Kennelly: All claims against defendant 132, Cheerland, are dismissed without prejudice pursuant to stipulation. Defendant's motion to amend 78 is denied as moot. It is not clear to the Court whether any defendants remain in the case at this point. The telephonic status hearing set for 9:10 AM on 11/12/2024 is advanced to 8:55 AM on that same date, using call-in number 650-479-3207, access code 2305-915-8729.

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant no. 87 Mpanwen

SATISFACTION of Judgment as to [Certain] defendants

STATUS Report by Anagram International, LLC

MINUTE entry before the Honorable Matthew F. Kennelly: Pursuant to the stipulation of dismissal 96, this case is dismissed. The 11/12/2024 telephonic hearing is vacated. Civil case terminated. Mailed notice.

SATISFACTION of Judgment as to defendant no. 187 FANGSHENGKEJI