2024-cv-06925

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-22335467.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

CIVIL Cover Sheet

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

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.)

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Adam Sapper regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 2 - Parts 1-10 regarding declaration[15]

MOTION by Plaintiff Mattel, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte telephone conference held on 8/12/2024. Transcript is to remain sealed. Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [12] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [17] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 8/12/2024. Mailed notice.

Registry Deposit Information Form by Mattel, Inc.

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

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time[25]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[26]

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [25] is granted. The Temporary Restraining Order entered on 8/12/2024 is extended by a period of fourteen (14) days until 9/9/2024. Mailed notice.

ATTORNEY Appearance for Defendant Jingtu Home by Bole Yuan

SURETY BOND in the amount of $ 129,000 posted by Mattel, Inc. (Document not scanned).

MOTION to Dismiss Unreasonable Temporary Restraining Order and the lawsuit against NoTagCat in the Case of 24-cv-06925 Defendant NoTagCat ("NoTagCat", "Defendant" "I" or "me")moves the Court to dismiss this case, in support of this Motion, defendant's states as follows. Pursuant to Rule 65(b)(4) of the Federal Rules of Civil Procedure, NoTagCat may challenge the TEMPORARY RESTRAINING ORDER (TRO) injunction at any time after its entry by asking the court to vacate the temporary injunction by Defendants Notagcat, Xiao Tianxiang. (Exhibits) (Received via pro se email on 8/23/24.)

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff's response to Defendant NoTagCat's motion to dismiss 31 is due by 8/30/2024. Defendant's reply is due by 9/6/2024. Mailed notice.

MOTION by Plaintiff Mattel, Inc. to strike MOTION by Defendants Notagcat, Xiao Tianxiang to dismiss MOTION by Defendants Notagcat, Xiao Tianxiang to vacate [31]

MOTION by Defendant Notagcat to strike Plaintiff's motion to strike[1]1 (Received via pro se email on 8/28/24.)

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin Tyler Joseph

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

ATTORNEY Appearance for Defendant Meifigno by Bole Yuan

NOTICE of Voluntary Dismissal by Mattel, Inc. as to a certain Defendant

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction 39

Declaration of Rachel S. Miller

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 39 is set for 9/9/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/3/2024, answer due 9/24/2024.

Declaration of Justin T. Joseph

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 9/9/2024. No one was present on behalf of defendants other than Notagcat. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 39 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Adam Sapper 16, and the TRO 23. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The TRO as to Defendant Notagcat is continued. Defendant is to respond to discovery requests within 14 days of issuance. A telephone status hearing is set for 10/16/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

NEW PARTIES: Home-Seasons, HomeTrend Essentials, Hoululu, Huaheng hi tech, HUANGHUIZHONG, HUYMHTER, HYTDYM, iirukaa-us, IKOJING, INNERDIVA, Ivar Tong, JacyanUS, Jericho&Jess, JeVenis, Jeweyeah, JIANIAO, jiedianm, JINGTU HOME, jinmeishiping, Jipaidz7, JIUQUXI, jun yu guo ji, juzran, JZABAO, Kolding Luo, Korotho, Kstweyl, KuLuo, Lagusida, Leiouna, LEQIQIZHI, LiaobinYunzun, Lidan-us, LiGuoQiang00, lijinfeng121, Lipmok-us, lirunqidianpu, liu888cos, liufuliang+tangpinshangmao, liulinanposter, LIYAN-GOOD, LIyiJ, LJCL, longliangwu, Lover 77, LuckyshopYing, lucoacos, lvyifeng, mamba, Mankoshin, MC TTL, Meifigno, MelissaPettit, MingMer, minibright, MMJIE, Moalioi, MorvallyDirect, MSSmile, Muagorn, MUPUR, NaturGuard Gears, Nishuna, Norah hu, NoTagCat, oecoel, Olwyn Gift Direct, OMGGMO, ONEST Studio, ONGHYUGAO, Orlight-US, OSPOOO, PENGcen, pingyaoxianyangzidianzishangwuyouxiangongsi, PLAN D, PsPet, PuJiangXianKeDiDianZiSheBeiShangHang, PUnlimited, Qian's Party, QIEJNX, QJYQ, Qonmpcvu, QT-T, RAAIBB, REYOUST, RIHIOOP, RONGYUH, keychain_suppliers, hkedgechent, Holy Stone And DEERC Online Store, Home-Fashion-Store, honey-peach, hotpier, hydt1379, jesseskyplay, jiajiazz, JR Toys House, kanavi_5, kkti84, knight-baby, limitedusa, lovfen_direct, lunts-86, lvpue_54, Made-With-Love-3, mingmingshop, Mingyang Shen, nguye_758143, phammi-81, pyosikB-ba'b'y, Qiang0036, Rabbit sells cup, Rabbits eat carrots666, Raoto168, sceggiolk, scktoo_Baby, sddghwb-82, shoppingtarget, SHOWDIO, Sparkwalkers, starbucks, Starbucks China, starsparadise, ejoyshop, FUNWEE, ONE HOMER and Today Co.Ltd added to case caption. (Text entry; no document attached.)

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 9/9/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant JacyanUS by Christopher Paul Keleher

MOTION by Defendant JacyanUS for extension of time to file answer regarding complaint[1] (AGREED)

MINUTE entry before the Honorable Thomas M. Durkin: Agreed motion for extension of time to answer 47 is granted. Defendant JacyanUS is to respond to Plaintiff's Complaint by 10/8/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant Lipmok-us by Haipeng Xiao

ANSWER to Complaint with Jury Demand by Lipmok-us

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant JeVenis by Christopher Paul Keleher

TRANSCRIPT OF PROCEEDINGS held on 09/09/2024 before the Honorable Thomas M. Durkin. Motion for Preliminary Injunction. Order Number: 49758. Court Reporter Contact Information: Elia E. Carrion, EECarrionOfficialTranscript@gmail.com, 312.408.7782. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 10/17/2024. Redacted Transcript Deadline set for 10/28/2024. Release of Transcript Restriction set for 12/25/2024.

MOTION by Defendant JeVenis for extension of time to file answer regarding complaint[1] (AGREED)

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time to answer 55 is granted. Defendant JeVenis is to respond to Plaintiff's complaint by 10/17/2024. Mailed notice.

RESPONSE to Plaintiff's Interrogatories by Defendant Xiao Tianxiang (Received via pro se email on 10/01/24)

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 10/16/2024 is reset for 10/15/2024 at 9:00 a.m. The dial-in information will remain the same. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. to strike Response 57

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 10/15/2024. Plaintiff reported on status of settlement with defendants. Defendant Notagcat's response to Plaintiff's motion to strike Defendant's responses to Plaintiff's interrogatories [61] is due by 10/29/2024. Plaintiff's reply is due by 11/5/2024. A telephone status hearing is set for 11/12/2024 at 8:45 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

TRANSCRIPT OF PROCEEDINGS held on 10/15/2024 before the Honorable Thomas M. Durkin. Status Hearing. Order Number: 50062. Court Reporter Contact Information: Elia E. Carrion, EECarrionOfficialTranscript@gmail.com, 312.408.7782. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 11/15/2024. Redacted Transcript Deadline set for 11/25/2024. Release of Transcript Restriction set for 1/23/2025.

RESPONSE in Opposition to Plaintiff's Motion to compel by defendant by Xiao Tianxiang operating as NoTagCat to obtain U.S. Counsel and Motion to dismiss for failure to join an indispensable and necessary party. (Received by Box.Com on 10/29/24).

Notice of withdrawal by Xiao Tianxiang (NoTagCat). (Received by Box.Com on 10/29/24).

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 11/12/2024 at 8:45 a.m. is reset for 9:00 a.m. Time change only. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

REPLY by Mattel, Inc. to response in opposition to motion, [66] and in support of [61]

ORDER: For the reasons stated in the attached order, NoTagCat's motions [31] and [34] are denied as moot, Mattel's motion [33] is denied, and Mattel's motion to strike [61] is denied in part and granted in part. Signed by the Honorable Thomas M. Durkin on 11/6/2024. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: NoTagCat must retain an attorney and answer or otherwise please within 21 days or risk a default judgment being entered against it. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 11/12/2024. A telephone status hearing is set for 1/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

MOTION by Defendant Xiao Tianxiang to clarify order [71]. (Received via pro se email on 11/20/24.)

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants with the exception of certain Defendants

(Exhibit A)

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment 76

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 77

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for entry of default and for default judgment 76 is set for 12/19/2024 at 8:45 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin: Plaintiff is to respond to the motion to clarify [75] by 12/12/2024. Mailed notice.

MOTION by Defendant Xiao Tianxiang to strike Scheduling Order [80]. (Received via pro se email on 12/03/2024)

MINUTE entry before the Honorable Thomas M. Durkin: Defendant Xiao Tianxiang's (NoTagCat) motion to strike Scheduling Order [81] is denied. Mailed notice.

MOTION by Defendant Notagcat to enter a briefing schedule. (Received via Box.com on 12/05/2024)

MINUTE entry before the Honorable Thomas M. Durkin: Defendant's motion to enter a briefing schedule [83] is granted. Xiao Tianxiang (NoTagCat) may file a reply in support of their motion to clarify [75] by 1/7/2025. Mailed notice.

RESPONSE by Xiao Tianxiangin Opposition to Defdault Judgment [76] (Received via pro se email on 12/06/24.)

NOTICE by Xiao Tianxiangin of Supplemental Authority in Opposition to Plaintiff's Motion for Default Judgment. (Exhibits) (Received via pro se email on 12/06/24.)

RESPONSE by Mattel, Inc.in Opposition to MOTION by Defendant Xiao Tianxiang to clarify [75]

Exhibit 1

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

RESPONSE by Plaintiff Mattel, Inc. to Defendant Notagcat's Opposition to Default Judgment [85]

Exhibit A

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 1/7/2025 is reset for 1/9/2025 at 9:00 a.m. The dial-in information will remain the same. The telephonic motion hearing set for 12/19/2025 stands. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 12/19/2024. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and for default judgment as to certain defendants 76 is granted. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 12/19/2024. Mailed notice.

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 Thomas M. Durkin: The telephone status hearing set for 1/9/2025 is reset for 1/7/2025 at 9:15 a.m. The dial-in information will remain the same. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 1/7/2025. No one appeared on behalf of Defendants. Telephone status hearing is set for 1/28/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. (jn,)

MOTION by Defendant NoTagCat for a written opinion regarding defendant's motion to clarify [75]. (Exhibits) (Received at the Intake Counter on 01/23/2025)

MAILED original one hundred twenty-nine thousand- and 00/100-dollar ($129,000) surety bond posted by Mattel, Inc. to Amy Crout Ziegler Greer, Burns & Crain Ltd. 200 W Madison St, Ste 2100, Chicago, IL 60606 via certified mail article number 9589 0710 5270 0579 7828 92 (Text entry; no document attached.)

ORDER: For the reasons stated in the attached order, Xiao Tianxiang's motion to clarify [75] is denied, and Xiao Tianxiang's motion for a written opinion [96] is denied as moot. Xiao Tianxiang is barred from making filings in this case on behalf of NoTagCat; Shenzhen Jiuniyu Technology, Co., Ltd.; or Shenzhen Jiumuyu Technology Co., Ltd. Signed by the Honorable Thomas M. Durkin on 1/27/2025. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 1/28/2025 is reset for 2/3/2025 at 9:00 a.m. The dial-in information will remain the same. Mailed notice.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 2/3/2025. A telephone hearing as to the anticipated motion to dismiss the last remaining defendant is set for 3/5/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7828 92 (Received by mail in the Clerk's Office on 2/6/2025.)

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment 102

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 103

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 3/5/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and for default judgment 102 is granted. Enter order. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 3/5/2025. Mailed notice.