2024-cv-07759

COMPLAINT filed by Anagram International, LLC; Filing fee $ 405, receipt number AILNDC-22410249.

Exhibit Ex. 1 - Registrations

Exhibit Ex. 2 - DHS Report

Exhibit Ex. 3 - IP Rights

(Exhibit Ex. 4 - Seizure Stats)

CIVIL Cover Sheet

SEALED DOCUMENT by Plaintiff Anagram International, LLC

MOTION by Plaintiff Anagram International, LLC to seal document sealed document 3

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

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Matthew A. Werber

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

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 3).

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.

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Peter Krusiewicz

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion for leave to file exhibit under seal 4. For the reasons stated in the motion, the motion is granted and Plaintiff has leave to seal Schedule A to the complaint. Mailed notice.

MOTION by Plaintiff Anagram International, LLC for temporary restraining order

MEMORANDUM by Anagram International, LLC in support of motion for temporary restraining order 10

Declaration Declaration of Christopher Wiles

(Declaration Declaration of Matthew A. Werber)

SEALED EXHIBIT by Plaintiff Anagram International, LLC regarding memorandum in support of motion 11

Wiles Ex. 1 part 1 of 11

Wiles Ex. 1 part 2 of 11

Wiles Ex. 1 part 3 of 11

Wiles Ex. 1 part 4 of 11

Wiles Ex. 1 part 5 of 11

Wiles Ex. 1 part 6 of 11

Wiles Ex. 1 part 7 of 11

Wiles Ex. 1 part 8 of 11

Wiles Ex. 1 part 9 of 11

Wiles Ex. 1 part 10 of 11

(Wiles Ex. 1 part 11 of 11)

MOTION by Plaintiff Anagram International, LLCELECTRONIC SERVICE

(Declaration Declaration of Matthew A. Werber)

MEMORANDUM by Anagram International, LLC IN SUPPORT OF JOINDER

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-22418373.

MINUTE entry before the Honorable Franklin U. Valderrama: Attorney April Hua's motion to appear pro hac vice 15 is granted. 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 a temporary restraining order 10 and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 13. Provided that Plaintiff provides the security described in paragraph 10 of the temporary restraining order, the temporary restraining order shall become effective on 09/06/2024 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.

SURETY BOND in the amount of $ 10,000.00 posted by Anagram International, LLC

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

ATTORNEY Appearance for Defendants HomBae, RinaParty by Erin Kathryn Russell

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

ATTORNEY Appearance for Defendant SHXSTORE by Pete Scott Wolfgram

MOTION by Plaintiff Anagram International, LLC for extension of time of TRO until Oct. 4, 2024

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order 22. The Temporary Restraining Order 18 shall now expire on 10/04/2024 at 6:00 p.m. Mailed notice.

NOTICE of Voluntary Dismissal by Anagram International, LLC as to certain defendants

SUMMONS Returned Executed by Anagram International, LLC as to All Defendants.

MOTION by Plaintiff Anagram International, LLC for preliminary injunction

MEMORANDUM by Anagram International, LLC in support of motion for preliminary injunction[26]

Declaration Matthew A. Werber

ATTORNEY Appearance for Defendant shelling home by Steven G Kalberg

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 26 is granted as to all defendants but HomeBae, RinaParty, SHXSTORE, and shelling home, who have appeared via counsel. Enter Preliminary Injunction Order as amended. The following documents are to be unsealed: (1) Schedule A to the Complaint 3 ; (2) Exhibit 2 to the Declaration of Christopher Wiles 12 ; and (3) the TRO 18. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. The Court sets the following briefing schedule on the motion for a preliminary injunction as to HomeBae, RinaParty, SHXSTORE, and shelling home: HomeBae, RinaParty, SHXSTORE, and shelling home's responses due 10/26/2024; Plaintiff's reply due 11/09/2024. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Franklin U. Valderrama on 9/26/2024. Mailed notice

NEW PARTIES: Ahern Li, AILIBA, Anhity, Aooxpok Store, ArRuissi Aviation Model, Beaumode, Belicious Helper, bestsupport, Better Life for You, BoJunB, Bonanze Store, Bounce-US, Bulubulu Store, Buyer Favors, CaseFan, CboDeco, ceutmelye, Chagar, Changchunshixinshengbinshangmaoyouxiangongsi, CHENYIXINYI, CHLOOD, CHOWDOLANG, COMOPHOTO Backdrop, Compared to, CostumeParty support, DEMOCRATIC, Domgoge-US, DSQ Party, Dumilla, Elevimond, eRoot, FaFa Party, Feirrothen, FNOJANWODWANOD, Frianchly, Friendsship Forever, fucaigu, fujianheyouranxinxikejiyouxiangongsi, FUKUGAWACO, Funmemoir, Fuzhou Qianjun Electronic Commerce Co., Ltd., Gaobai, GoGoGoodie, guangzhouchunlukejiyouxiangongsi, Happy Balloon, HealthSTEC, Hengfengmy-US, Hiboom US, Honest Anan, HUFAND US, Huihe Creative Home Living Museum, Heshan District, Yiyang City, HuLePeng HuaCheng, iftnotea, Isndare, Jericho&Jess, Jerps, Jingcai001, Joinwin, Judge, Julianxin office, juntushangmao, Kesote, KINBOM stores, KOMODOMO, Langtel Products, lanxiufeng, LFVIK, Linbloom, LINDOO, Literarysmall, LM2020 large, LOL Party&Crafts, LOTUSPIE DIRECT, Lyingcats, Max running, Mocsicka Backdrop, Ms Beauty, number1shopdirect, ParlikeenMic, PARLONTY, Party Moment, Party Time USA, Party-Queen, Partyplaza, Pateeha Party Direct, Phogary US, QZMCEAGS, Red Psalm, Rony mar, Rukie, SERONLINE, shangde hongtao, ShenZhenShiHongYuDaShangMaoYouXianGongSi, shijiazhuang niuzhuimaoyishanghang, Shindel, Shinyhome, Simple polymer, sit down, Siticoto, Stcomart, Taotenish, Tellpet Store, Tiblue, To the radar, Vsdski Party Favor, VYNYJOAN, wesley Hu, What is it?, WINMIND, XANGNIER, YaterYing, YYTCST, Zenada, ZHEXUNDIAN, 7YH7DL, AaSFJEG, AESKEALLY, AiYqZypa, Beijiate Boutique, BONTRM, BrowQuartz, Bzldin, Chunhongkeji, Ciaoed life Co. ltd, CJUAN, COMIOR Co.Ltd, Cool BUY, CRCMJUHGSA, CUGBO, Delike, Dengmore, Description politics co., ltd, Fangleland Party Decor, Fast Sell, FENGZZ, Fj Rich Co.Ltd, foshanshichanchengquwenrenshengshangmaoyouxiangongsi, FSLF PartyDecor, Funmemoir Party Decor, goilinor, gongxifacai, Gongxipen, guangzhourenmaishangmaoyouxiangongsi, HALJEN, Hen, HEWANN HOME, HGEGPO, Hjuang, Huangjiacheng, Huaping Trading Co., Ltd., Huayishang, HWDS, IFKSFXKF, iTi Direct, JELEUON, JiaChangwang Co., LTD, jiayuxuandianzi, Jibingyi, jikesheng, Jingzi Co., LTD, JISHENX, JIZHIXIAN, JOKI, Jollyboom Party Decor, JOYMEMO Party Decor, JUMRHFAN, Kaixunba Co., Ltd., Kiddopark, Kkewar, Kwlinmg, LaMaz, LivNxt, LMEEOR, LongYTong, LOVERLYZ, LRZWY, Ltrototea Co.ltd, LWZWM Clearance Sold, LYGFSRDX, LYTiang, LZKang, Magic life, Menolana, MetMetalrt, MFJA Store, Minggoods Supply, Miracle Trading Company, MQjiaju, MUGU_Store, MYTAKEND, noxiang si tech Co. Ltd, OXM MALL, Pngyino, QingLongXuanJiaJu, QJUHUNG Co. Ltd, Quauec, Quqiuxian, REEREEN Co. Ltd, Ruihangxiemaoltd, Sarkoyar Co.Ltd, Shangfeng, shansuidianzishangwu, Shiusinaa, SHLT Mall, SNOWKITTEN, STONCEL Home Department Store, Sunbeauty Store, SYCMKUH, TaiYuanShiQianShuKeJiYouXianGongSi, Tartikaily, TETOU Store, TIANGAO, TUWEN, UEBXS, VOLTENICK, Wmhsylg, Worgeous, WRDMNBV, XLZMUHYTGS, XunHong, YanMaoYi, YCCMML, Yiyibai, youyag, Yu Boutique Store, yuehuaidai, Yueyihe, YUHUO, yushangoua, Ywlanda, YXVWKN, ZB-HRGBZ, Zengyong, ZhongXiangShi, Zipning, Zjurshop, ZMhangE, Zweiton and ZXIPN added to case caption. Terminating Anagram International, LLC

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 Defendant Shindel by Hua Chen

ATTORNEY Appearance for Defendant Rukie by Mark Berkowitz

MOTION by Defendant Rukie to vacate preliminary injunction 30 - (Opposed) Request to Modify the Preliminary Injunction Order

CIVIL Cover Sheet

NOTICE of Voluntary Dismissal by All Plaintiffs as to Certain Defendants

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Defendant Rukie's request to modify the preliminary injunction order 35. The Court construes the motion as a motion to vacate the preliminary injunction order entered against Defendant Rukie and sets the following briefing schedule: (1) Plaintiff's response to motion due 10/24/2024; (2) Defendant Rukie's reply due 10/31/2024. 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

MOTION by Plaintiff Anagram International, LLC for default judgment as to Certain Defaulting Defendants

(Exhibit A - Defaulting Defendants)

MEMORANDUM by Anagram International, LLC in support of motion for default judgment 42

(Werber Decl.)

ATTORNEY Appearance for Defendant HUFAND US by Christopher Paul Keleher

MOTION by Defendant HUFAND US for extension of time to file answer regarding complaint, 1 (UNOPPOSED)

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Defendant HUFAND US's unopposed first motion for extension of time to answer or plead 45. For the reasons stated in the unopposed motion, the Court grants the motion. Defendant's responsive pleading deadline is extended to 11/15/2024. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff voluntarily dismissed Defendant Rukie. R. 40. On that basis, the Court terminates Defendant Rukie's pending motion to dissolve the preliminary injunction as moot 35. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment 42. Statutory damages are awarded in the amount of $100,000 per each distinct Defaulting Defendant as indicated in the order. Enter Default Judgment Order as amended. By 11/21/2024, Plaintiff is directed to file a status report as to the status of the case against the remaining defendants, including with respect to Defendant SHXSTORE who was mistakenly included as a Defaulting Defendant, but who has appeared through counsel in this case. 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 11/15/2024. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants, including 100SHXSTORE

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

NOTICE by All Plaintiffs re order on motion for default judgment, set deadlines, 51 STATUS REPORT BY PLAINTIFF ANAGRAM

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed Plaintiff's status report [55], which indicates that no remaining defendants are subject to the Court's preliminary injunction order. Accordingly, Plaintiff shall file a motion for return of the bond or a status report indicating when plaintiff anticipates filing such a motion by 11/27/2024. Mailed notice.

MOTION by Plaintiff Anagram International, LLC for release of bond obligation PLAINTIFF'S MOTION FOR RELEASE OF SURETY BOND

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated therein, the Court grants Plaintiff's motion to return of the bond 57. The ten-thousand-dollar ($10,000.00) surety bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Matthew Werber of Nixon Peabody LLP. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Matthew Werber of Nixon Peabody LLP., 70 W. Madison, Suite 5200, Chicago, IL 60602, via certified mail. Civil case terminated. Mailed notice.

ORDER: Signed by the Honorable Franklin U. Valderrama on 12/2/2024. Mailed notice.

MAILED copyright report to Registrar, Washington DC

SATISFACTION of Judgment as to certain defendant(s)