2024-cv-06246

COMPLAINT filed by Blujay Studios, Inc.; Filing fee $ 405, receipt number AILNDC-22278533.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Blujay Studios, Inc. Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Christopher Romero

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Blujay Studios, Inc. by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Blujay Studios, Inc.

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Maria Valdez. 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 Blujay Studios, Inc. for leave to file under seal

MOTION by Plaintiff Blujay Studios, Inc. 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 Deborah Stout

Exhibit 1, of Deborah Stout's Declaration

SEALED EXHIBIT by Plaintiff Blujay Studios, Inc. Sealed Exhibit 2, Declaration of Deborah Stout regarding memorandum in support of motion, [15]

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff is required to supplement its TRO motion 14 with a listing of all prior on-line trademark/copyright infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff and a certification that it has not used any of the screenshot evidence 16 supplied in support of its motion for TRO 14 in any prior proceeding. Mailed notice

Certificate by Blujay Studios, Inc. Pursuant to Minute Entry Order [19]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 14 is granted. Plaintiff's motions for leave to file under seal 12 and to exceed page limitation 13 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 8/5/2024. Mailed notice

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

INJUNCTION BOND in the amount of $ 183,000.00 posted by Blujay Studios, Inc. (Document not scanned)

MOTION by Plaintiff Blujay Studios, Inc. for preliminary injunction

MEMORANDUM by Blujay Studios, Inc. in support of motion for preliminary injunction[24]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's Declaration

SUMMONS Returned Executed by Blujay Studios, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/13/2024, answer due 9/3/2024.

Declaration of Service

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [24] is taken under advisement. Any objection or response is due before 8/20/24. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement, by 8/15/2024, the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before August 20, 2024. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Having reviewed the summons executed as to the Schedule A defendants, the Court extends the deadline for defendants to object or respond to the preliminary injunction motion 24 to 9/3/2024. Mailed notice

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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 130 Lucky First

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notices of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [29][30], defendant nos. 150, 183, 111, 103, 35, 46, 94, 97, 102, 116, 143, 160, 171, 172, 98, 39, 27, and 130 are dismissed from this case. Mailed notice

ATTORNEY Appearance for Defendants huiyuandianzi Co. Ltd., KAIJIA Co. Ltd by He Cheng

MOTION by Defendant huiyuandianzi Co. Ltd. for extension of time to file answer regarding complaint[1]

MOTION by Defendant KAIJIA Co. Ltd to dismiss for lack of jurisdiction

Exhibit Declaration of Jingying Xing

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 104 AOYINGMRWJ and defendant no. 152 xiongxianyuhengrujiaozhipinxiaoshouyouxiangongsi

MINUTE entry before the Honorable John J. Tharp, Jr: The deadline to object or respond to plaintiff's motion for preliminary injunction [24] having passed, the Court directs plaintiff by 9/9/2024 to submit a list of all remaining Schedule A defendants. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant huiyuandianzi Co. Ltd.'s unopposed motion for an extension of time to file an answer [33] is granted, and the deadline for defendant huiyuandianzi Co. Ltd. is extended to 10/4/2024. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant KAIJIA Co. Ltd.'s motion to dismiss [34] is take under advisement. Plaintiff's response is due 9/24/2024; the defendant's reply is due 10/8/2024. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [35], defendant nos. 104 and 152 are dismissed from this case. Mailed notice

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

(Exhibit 1)

MEMORANDUM by Blujay Studios, Inc. in support of motion for default judgment 40

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MOTION by Plaintiff Blujay Studios, Inc. to stay regarding MOTION by Defendant KAIJIA Co. Ltd to dismiss for lack of jurisdiction [34] and Incorporated Memorandum in Support, and For Leave to Conduct Jurisdictional Discovery

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [24] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 9/11/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [40] is taken under advisement. Any objections or responses are due by 9/16/2024. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 9/10/2024. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

NEW PARTIES: 0.79994, apvx5077, babylovetoystore, breuh10bc, bsahg23a, buluke, canzhk-0, csac242u, daigu-63, dasfd22a, dav1_35, deanss, dhueze20yw, digitionalljp, dingjing08, dqwv6820, duolier, dwgywvf, edcvb48n, edfsa50u, ejyrher, enshishirongdiansh-0, epnf_24, esabus34, feishu109 and fgffd20wj added to case caption. (Text entry; no document attached.)

NEW PARTIES: free-hongkong, ge46966, georgesshop-66, gsd47fs, gssfs19wj, haizhuo07, hdgy34c, helenaa, hkzdgdz38, hongyangwm, huihui-666, huoquan, jayonly14, jkghf18wj, lasthope201111 and lemonkl added to case caption. (Text entry; no document attached.)

NEW PARTIES: liling_9611, lizhang-1362, luizhr_82, lunshu51, luobinjiang, luoen3-21, luyang01, madge4-26, media-cdk, meqidlufei, mkkweb-1, nia_4842, okmijnyy, peiluona, pengchenk, pinganjixiang999, poker3it, qergvb15u, qergx22u, qernv23u, qiao-7908, qingzhi2-6, qkghm14u, qwdg24u, qwertuio15u, qxcvb21u, rdazyy, rjiao523, rockshi-69, ronghua34, roshanrpilap_0, selena4-26, serddtr, shedy07ew, shengping22, shenzhen5, shenzhen7-7 and shenzy-0 added to case caption. (Text entry; no document attached.)

NEW PARTIES: sufengyun3, swdbhj, tian442, toy-xi, tqywef17ka, us.bizhe, vfvff69, vsjed38me, weihaub, wertyi, wgdhwbvhg, wsdjra11ky, yangxinyi01, yingdawen_0, yjfsme-31, youmilai, yq3studi-0, yuansheng2020, zhuyaqinke, zpjia7-70, zvxcb237nn, Aimiy, ANGUJC, AOYINGMRWJ, beijingchangyueshundashangmaoyouxiangongsi, BlancheGiftShop, BOOK, Bovonia, Camille Xu, Chili pie, Dry him, EASYDAYY, Fly Taurus, foshanbopeibangmaoyiyouxiangongsi, foshanyuannakaimaoyiyouxiangongsi, fuyongdexiaodian, hefeisulangdianzishangwuyouxiangongsi, huangjinrongdegongyipindian, huozhoushilipingmaoyidian, jiangguihongjkhsd32, JLKJ Store, KANQIYUAN, LaiYueShangMaoYouXianGongSi, LI-MING BIN and linchengpengyishuhaibao added to case caption. (Text entry; no document attached.)

NEW PARTIES: linfengshangmaodianpu, liuzhijie, Lucky First, LULUWAIMAO, Mammykiss-US, MaoYunlong, MingMeiJunZhuoWan, OYZX, penglongdexiaodian, second long, shicheng1212, sktt, taianjiezhidianzishangwuyouxiangongsi, taiyuanshijunjieshangmaoyouxiangongsi, Teacups, The Bread Basketei, Tiffeory, WangYongJiangUS, wenzhouyishishangmaoyouxiangongsi, wuxishijuyouqianzixunyouxiangongsi, WUYANYIDUIDE, WWJJWWJJ, XIAOG Art Poster, XingTaiWanYinShangMaoYouXianGongSi, xiongxianyuhengrujiaozhipinxiaoshouyouxiangongsi, XUSHANGHI, YANGyu, yichangshidangyangshiwenyangyanwujinjidianxiaoshoudiangerenduz, yixinzonghe, yuhudianzishangwuyouxiangongsi, yunchengshiyanhuqushengxiashangmaoyouxiangongsi, YYDSJJH and Zanbai Co., Ltd added to case caption. (Text entry; no document attached.)

NEW PARTIES: ZHANGKAIWAIMAO, zhangmingyubaihuo, Zhenpei-Store, ZHENQUTANG, zhongmndc, Hefeicuolengdianzishangwuyouxiangongsi, Honest, huiyuandianziCo. Ltd, Manyunmeichen Trading, QSNightwilQ, SSS Pro, AO YING LONGER, APHMAO, Apushmeu, Good Sticker, KaiMao, Mammykiss, Mickey Bear, Mockerii, Moler, Splushmow Shop, ZXIRNA, Defendant 105 and Defendant 106 added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable John J. Tharp, Jr:A telephone status hearing will be held on 9/18/2024 at 10:00 AM Central to address plaintiff's motion for jurisdictional discovery 42. If defendant wishes to respond to the motion, it must do so no later than 9/16/2024. For instructions regarding participation in, or access to, the telephone hearing, see the standing order on telephone hearings on Judge Tharp's web page (https://www.ilnd.uscourts.gov/judge-info.aspx?79eF+7uiX7ewBj/ITKrjoA==). Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 113, 142, 99, 135, 107, 112, 137, 109, 131, 148, 133, 168, 144, and 170 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [40] is granted. Enter default judgment order.

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/17/2024.Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Status hearing held. Upon Defendant #169's oral motion to withdraw their motion to dismiss, Plaintiff's motion for jurisdictional discovery [42] is denied as moot. Mailed notice

MOTION by Plaintiff Blujay Studios, Inc. for default judgment as to [Unopposed] Motion For Entry Of Default And Default Judgment Against Defendant No. 169 KAIJIA Co.Ltd

MEMORANDUM by Blujay Studios, Inc. in support of motion for default judgment[51]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's unopposed motion for default judgment against defendant no. 169 [51] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/19/2024. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA

SATISFACTION of Judgment as to defendant no. 140 taianjiezhidianzishangwuyouxiangongsi

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 56, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 140. Mailed notice

SATISFACTION of Judgment as to defendant no. 139 sktt and defendant no. 105 Aplushuman

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 58, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant nos. 139 and 105. Mailed notice

SATISFACTION of Judgment as to defendant no. 122 jiangguihongjkhsd32 and defendant no. 163 Zhenpei-Store

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 60, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant nos. 122 and 163. Mailed notice

SATISFACTION of Judgment as to defendant no. 124 KANQIYUAN

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 62, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 124. Mailed notice

SATISFACTION of Judgment as to defendant no. 180 Mockerii

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [64], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 180. Mailed notice