2024-cv-08964

COMPLAINT filed by TV Tokyo Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-22524251.

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 11/6/2024.

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

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. 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.)

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 3 Part 1 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 2 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 3 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 4 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 5 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 6 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 7 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 8 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 9 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 10 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 11 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 12 of Saiki Declaration

EXHIBIT 3 Part 13 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 14 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 15 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

EXHIBIT 3 Part 16 of Saiki Declaration by Plaintiff TV Tokyo Corporation Modified on 11/6/2024.

Notice of Claims Involving Trademarks by TV Tokyo Corporation

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. If the template is not completed by October 10, 2024, the Court may dismiss this matter for failure to prosecute. Mailed notice.

Schedule A Supplement by TV Tokyo Corporation

SEALED ORDER Signed by the Honorable Lindsay C. Jenkins on 10/3/2024. Mailed notice.

TEMPORARY Restraining Order. Signed by the Honorable Lindsay C. Jenkins on 10/3/2024. Mailed notice. Modified on 11/6/2024.

SURETY BOND in the amount of $ 10,000.00 posted by TV Tokyo Corporation. (Document not scanned.)

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 Lindsay C. Jenkins: Plaintiffs motion to extend the TRO 35 is granted. The TRO is extended to October 31, 2024. Mailed notice.

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

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

MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction 37

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 37

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 37 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by October 31, 2024." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by John Wilson on behalf of TV Tokyo Corporation

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 10/28/2024, answer due 11/18/2024.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 37 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 41 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Hughes Socol Piers Resnick & Dym, Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Lindsay C. Jenkins on 11/1/2024. Mailed notice.

NEW PARTIES: Zhuhai Baize Technology Co., Ltd., Zhongshan Yutian Apparel Co., Ltd., Zhongshan Seemale Underwear Co., Ltd., Zhongshan Hongtu Garments Co., Ltd., Zhengzhou Play Card Animation Co., Ltd., Zhengzhou Damulin Industry and Trade Co., Ltd., Zhengzhou Awesome Carpet Co., Ltd., Zhejiang IKALI Cosplay Co.,Ltd Shanghai First Branch, Zhaoqing Redily Trading Co., Ltd., Zhangzhou Henko Trading Co., Limited, Zebra Gift Jewelry & Daily Commodity Development (Dongguan) Co., Ltd., Yuanho International Enterprise Co., Ltd., Yiwu Zhuoyi E-Commerce Ltd., Yiwu Zhijia Jewelry Co., Ltd., Yiwu Yuma Trade Co., Ltd., Yiwu Youxian E-Commerce Co., Ltd., Yiwu Yirun Clothing Co., Ltd., Yiwu Yihua Trade Co., Ltd, Yiwu Yibei E-Commerce Co., Ltd., Yiwu Yayan Trading Co., Ltd., Yiwu Xuxin Jewelry Co., Ltd., Yiwu Xinmu Network Technology Co., Ltd., Yiwu Wuben Trade Co., Ltd., Yiwu Wowei Crafts Co., Ltd., Yiwu Wenzan Apparel Co., Ltd., Yiwu Wanqian Clothing Firm, Yiwu Vanzon Import And Export Co., Ltd., Yiwu Suki Glasses Co., Ltd., Yiwu Showme Apparel Co., Ltd., Yiwu Shirun Import And Export Co., Ltd., Yiwu Shanmei Arts And Gifts Co., Ltd., Yiwu SanLan Jewelry Co., Ltd., Yiwu Saichi Trade Co., Ltd., Yiwu Richer Accessories Co., Ltd., Yiwu Oceans Jewelry Co., Ltd., Yiwu Ningchang Trading Co., Ltd., Yiwu Miaoyi Jewelry Factory, Yiwu Maro E-Commerce Firm, Yiwu Market Union Co., Ltd., Yiwu Manjia Trading Co., Ltd., Yiwu LvQiang Packing Factory, Yiwu Lucky Star Crafts Co., Ltd., Yiwu Lilang Crafts Co., Ltd., Yiwu Kaomikesi Jewelry Co., Ltd., Yiwu Junze Trading Co., Ltd., Yiwu Junhai Crafts Co., Ltd., Yiwu Jiyun Apparel Co., Ltd., Yiwu Jinyuan Jewelry Factory and Yiwu Jingyi Import & Export Co., Ltd. added to case caption. (Text entry; no document attached.)

NEW PARTIES: Yiwu Jingwan Jewelry Co., Ltd., Yiwu Huailang Trading Co., Ltd., Yiwu Hintcan Trade Co., Ltd., Yiwu Hengma Jewelry Co., Ltd., Yiwu Gulu E-Commerce Firm, Yiwu Fangtuo Jewelry Factory, Yiwu Fanda E-Commerce Firm, Yiwu Dongye E-Business Limited, Yiwu Diyan E-Commerce Co., Ltd., Yiwu Cna Jewelry Co., Ltd., Yiwu City Kefeng Jewelry Co., Ltd., Yiwu Changhong Electronic Commerce Co., Ltd., Yiwu Canying E-Commerce Co., Ltd., Yiwu Baihong Toys Co., Ltd., Yiwu Baige International Trade Co., Ltd., Yiwu Animestar Import and Export Co.,Ltd, Yichun Daotian Technology Co., Ltd., Yichun City Dongsheng Jewelry Co., Ltd., Xinxiang Dixini E-Commerce Co., Ltd., Xingtai Xuxing Trading Co., Ltd., Xiamen Xipuwan Shunlai Trade Co., Ltd., Xiamen Xinhengjun International Trade Co., Ltd., Xiamen Xiashengyuan Industry And Trade Co., Ltd., Xiamen Meiju Garment Co., Ltd., Xiamen Manqi Technology Co., Ltd., Xiamen Luxishi Clothing Co., Ltd., Xiamen Jinlai Sufengshan Trade Co., Ltd., Xiamen Jimei Luzhaoyao Daily Store, Xiamen Jimei District Tianxinmei Department Store, Xiamen Huanqiu Aerospace Technology Co., Ltd., Xiamen Glorystar Import And Export Co., Ltd., Xiamen Fengdongshi Shannan Trade Co., Ltd., Wuhan Baijia Shirui Trading Co., Ltd., Victory Group Co., Ltd., Tianjin Able Clothing Co., Ltd., Thaihe apparel (Dongguan) Co., Ltd, Suzhou Maokang Industrial Technology Co., Ltd., Suzhou Getogether Sujiao Co., Ltd., Suzhou Blossom Group, Sichuan Chendang Technology Co., Ltd., Shishi City Suixin Hardware Firm, Shijiazhuang Aishangxin Imp&Exp Co., Ltd., Shenzhen Yuanzheng Energy Technology Co., Ltd., Shenzhen Yihongcheng Technology Company Limited, Shenzhen Yi Shang Electronic Technology Co., Ltd., Shenzhen Yazhitang Trading Co., Ltd., Shenzhen Xinmeiyi Electronic Technology Co., Ltd., Shenzhen Unico Technology Co., Ltd., Shenzhen Tianzhixiang Cross Border Trade Co., Ltd. and Shenzhen Rukap Sportwear Co., Ltd. added to case caption. (Text entry; no document attached.)

NEW PARTIES: Shenzhen Rich Technology Co., Ltd., Shenzhen Phoneyue Electronics Co., Ltd., Shenzhen Momeishi Clothing Co., Ltd., Shenzhen Mingliu Trade Co., Ltd., Shenzhen Lylong Industrial Limited, Shenzhen Litu Culture Media Co., Ltd., Shenzhen Kawasaki-Bulls Sports Gear Co., Ltd., Shenzhen Kai Wei Garment Co., Ltd., Shenzhen Jin Bofeng Technology Co., Ltd., Shenzhen Jianuohui Trading Co., Ltd., Shenzhen Ideal Electronics Co., Ltd., Shenzhen Hi-Go Electronic Technology Co., Ltd., Shenzhen Haiyuan Technology Co., Ltd., Shenzhen Gudeke Electronic Commerce Co., Ltd., Shenzhen Ginsten Technology Co., Ltd., Shenzhen Gangcheng Yuanda Technology Co., Ltd., Shenzhen Fendi Jewelry Co., Ltd., Shenzhen F-Show Technology Co., Ltd., Shenzhen Cuichang Garment Co., Ltd., Shenzhen Cool Anime Technology Co., Ltd., Shenzhen Antiman Technology Co., Ltd., Shengzhou Esincerely Trading Co., Ltd., Shengzhou Deyao E Commerce Co., Ltd., Shantou Love Summer Technology Co., Ltd., Shantou Fujia Toys Co., Ltd., Shangrao Oufeishan Technology Co., Ltd., Shangrao Caidu Clothing Co., Ltd., Shanghai Yihengze Technology Co., Ltd., Shandong Paramount Import&Export Co., Ltd., Shandong Hht International Trading Co., Ltd., Shaanxi Junyuyi Trading Co., Ltd., Sege Import And Export Trade (Ningbo) Co., Ltd., Sakya Sports (Shenzhen) Co., Ltd., Rising Sun International CO., LTD., Quanzhou Yixun Crafts Co., Ltd., Quanzhou Walson Supply Chain Management Co., Ltd., Quanzhou Jiansheng Printing Co., Ltd., Quanzhou Jiage Luggage Co., Ltd., Quanzhou Huiyue Shoe Material Co., Ltd., Quanzhou Haixin Garment Technology Co., Ltd., Qingdao Youdian Xiaoguo Supply Chain Management Co., Ltd., Qingdao Highknight Industry & Trade Co., Ltd., Nancoly (Xiamen) Trading Co., Ltd., Nanchang Zhaoyun Garment Co., Ltd., Nanchang Xinyueda Clothing Co., Ltd., Nanchang Daili Clothing Co., Ltd., Nanchang Chengwei Stationery Gift Co., Ltd., Marsun (Guangzhou) Technology Co., Ltd., Lu'an Futu Electronic Commerce Co., Ltd. and Longgang city Xinxi Bags factory added to case caption. (Text entry; no document attached.)

NEW PARTIES: Lens Technology (Shenzhen) Co., Ltd., Jiujiang Dujiang Trading Co., Ltd., Jinjiang Guoyi E-Commerce Co., Ltd., Jinhua City Coexistence Import And Export Co., Ltd., Jianou Jinbella Arts & Crafts Co., Ltd., Jiangxi Smile Clothing Co., Ltd., Jiangxi Qianhui Garment Co., Ltd., Jiangxi Karong E-Commerce Co., Ltd., Jiangsu Pegasus Technology Co., Ltd., JIANGSU CRAFTFORGE ARTS AND CRAFTS CO., LTD, Huizhou Top Smart Technology Co., Ltd., Huizhou Ever Rock Hardware Co., Limited, Huangshi Binguo Party Trading Co., Ltd., Hefei Qiyi E-Commerce Co., Ltd., Hefei Luyang District Serlir Home Textile Store, Hangzhou Yongyuan Technology Co., Ltd., Hangzhou Nanhuan International Trade Co., Ltd., Hanchuan Ouwanni Clothing Co., Ltd., Guangzhou Zhiqian Technology Co., Ltd., Guangzhou Yudi Clothing Co., Ltd., Guangzhou Yize Trading Co., Ltd., Guangzhou Yitang Electronic Technology Co., Ltd., Guangzhou Tjkd Watch Co., Ltd., Guangzhou Three D Printing Co., Ltd., Guangzhou Suqi Clothing Co., Ltd., Guangzhou Shuosheng Clothing Co., Ltd., Guangzhou Puzhi Electronic Technology Co., Ltd., Guangzhou Pinjing Electronics Co., Ltd., Guangzhou Nadanbao Clothing Co., Ltd., Guangzhou Minghui Technology Co., Ltd., Guangzhou Meihui Color Packaging And Printing Co., Ltd., Guangzhou Longcheng Ceramics Co., Limited, Guangzhou Lewell Industry & Trade Co., Ltd., Guangzhou Langming Clothing Co., Ltd., Guangzhou Kemoli International Trading Co., Limited, Guangzhou Joye Accessories Co., Ltd., Guangzhou Jiuyi Electronics Co., Ltd, Guangzhou Healong Sportswear Co., Ltd., Guangzhou Guliwu Island Business Technology Co., Ltd., Guangzhou Gamewear Sporting Goods Co., Ltd., Guangzhou Focus Advertising Company Limited, Guangzhou Fengrui Clothing Co., Ltd., Guangzhou Elite Craft Co., Ltd., Guangzhou Dihui Clothing Co., Ltd., Guangzhou Chengyi International Trading Co., Limited, Guangzhou Baoqian Intelligent Technology Co., Ltd., Guangdong Yuefan E-Commerce Trading Co., Ltd., Fuzhou SFS Trading Co., Ltd. and Fuzhou Reliable E-Commerce Co., Ltd. added to case caption. (Text entry; no document attached.)

NEW PARTIES: Fuzhou Qianhu Trading Co., Ltd., Fuzhou Ju Cheng Ren De Trade Co., Ltd., Fuzhou Joined Import & Export Co., Ltd., Fuzhou Jin 'an Shining Jewelry Firm, Fuzhou Daxinsheng Trading Co., Ltd., Foshan Yiss Fera Import & Export Co., Ltd., Foshan Mujin Clothing Co.,ltd., Foshan Daiyue Watch Co., Ltd., Dongguan Zhuoli Toys Co., Ltd., Dongguan Zhongai Jewelry Co., Ltd., Dongguan Yuewen Electronic Technology Co., Ltd., Dongguan Yisuntex E-Commerce Co., Ltd., Dongguan Yaokai Electronic Technology Co., Ltd., Dongguan Xiwei Textile Co., Ltd., Dongguan Sborn Supply Chain Co., Ltd., Dongguan Padmat Rubber Co., Ltd., Dongguan Nanteng Knitting Co., Ltd., Dongguan Max Garment Co., Ltd., Dongguan Lanwo Clothing Co., Ltd., Dongguan Kuangmin Clothing Co., Ltd., Dongguan Kaqi Garment Co., Ltd., Dongguan Kafany Apparel Co., Ltd., Dongguan Happy Beauty Jewelry Co., Ltd., Dongguan Great Sportswear Co., Ltd., Dongguan Geersi Garments Co., Ltd., Dongguan Fulida Rubber Co., Ltd., Dongguan City Taiyao Hardware Products Co., Ltd., Dongguan City Charlo Garments Co., Ltd., Dongguan Build Plastic & Hardware Factory, Chongqing Senjianan E-Commerce Co., Ltd., Chengweida Group (Chengdu) Technology Co., Ltd., Chaozhou Anbixun Trading Co., Ltd., Changsha Zhouhang Technology Co., Ltd., Changsha Dahuan Electronic Technology Co., Ltd., Changsha Botu Trade Co., Ltd., CC NEON HOUSEHOLD BUSINESS, Cangzhou Escher Import And Export Trading Co., Ltd., Beijing Boningsai Trading Co., Ltd., Archer Clothing International Trade Co., Ltd., Anqing Chendong Jewewlry Co., Ltd., Anhui Ruifeng Crafts Co., Ltd., Yiwu Yushu Clothing Co., Ltd., Yiwu Ni Kehua Clothing Co.,Ltd., Yiwu Manyi Electronic Commerce Co., Ltd., Jinhua Wucheng Iyan Trading Firm, Fuzhou Shengfuyong Cultural Industry Co., Ltd., Fuzhou Mawei District Jiuxian Aquatic Products Business Department, Fujian Paxdun Import And Export Co., Ltd. and Datian Chuxi Trading Co., Ltd. added to case caption. (Text entry; no document attached.)

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

MINUTE entry before the Honorable Lindsay C. Jenkins: By November 18, 2024, Plaintiff shall file a status report regarding next steps in this case. If Plaintiff intends to file a motion for default judgment, it should be filed by that date, and if Plaintiff moves for default judgment as to all Defendants, no status report need be filed. Mailed notice.

ATTORNEY Appearance for Defendant Quanzhou Haixin Garment Technology Co., Ltd. by Adam Edward Urbanczyk

MOTION by Defendant Quanzhou Haixin Garment Technology Co., Ltd. for extension of time

MINUTE entry before the Honorable Lindsay C. Jenkins: Over the objection, Defendant Quanzhou Haixin Garment Technology Co., Ltd's motion for an extension of time [48] is granted. This Defendant's responsive pleading is now due by December 9, 2024. Mailed notice.

STATUS Report by TV Tokyo Corporation

MOTION for an extension of time to answer or otherwise plead filed by Defendant, No. 224, Suave Lobodzinski (pro se). (Received via pro se email on 11/18/2024)

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

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant No. 224 Yiwu Wenzan CO., Ltd.'s motion for an extension of time [51] is granted. This Defendant's deadline to answer the complaint is extended to December 9, 2024. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: A further status report as to the remaining Defendants (other than Defendant Quanzhou Haixin Garment Technology Co., Ltd. who is represented by counsel) is due by December 11, 2024, unless a motion for default judgment is filed sooner. Mailed notice.

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 54

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

OPPOSED MOTION to Dismiss or, alternatively, to sever filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se email on 12/3/2024)

DECLARATION OF JING ZHU. (Exhibits) (Received via pro se email on 12/3/2024)

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 42

DECLARATION OF JING ZHU. (Exhibits) (Received via pro se email on 12/6/2024)

OPPOSED MOTION to Dismiss or, alternatively, to sever filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se email on 12/6/2024)

MINUTE entry before the Honorable Lindsay C. Jenkins: A person named "S. Suave Lobodzinski" acting on behalf of Defendant Yiwu Wenzan Apparel Co., Ltd has filed amotion to dismiss or to sever [58] but the motion is denied without prejudice to refiling. The Court does not know whether Lobodzinski is a licensed attorney, but a pro se litigant may only represent himself in federal court, not another person or entity. A search of the Illinois Attorney Registration and Disciplinary Commission website shows that Lobodzinski is not a licensed attorney in Illinois, nor does he appear to be a member of the Court's bar, and he did not file an attorney appearance in this case. The Court directs Plaintiff's counsel to confer with Lobodzinski to see if the matter can be resolved, and to file a status report by December 20, 2024. If no agreement can be reached, the Court will permit Defendant Yiwu Wenzan Apparel Co., Ltd time to retain US counsel and refile the motion. Mailed notice.

DECLARATION of S. Suave Lobodzinski. (Exhibits) (Received via pro se email on 12/6/224)

DECLARATION of Xin Lan. (Exhibit) (Received via pro se email on 12/6/2024)

CERTIFICATE of Service. (Received via pro se email on 12/6/2024)

MOTION by Defendant Quanzhou Haixin Garment Technology Co., Ltd. to dismiss for lack of jurisdiction

Declaration of Ni Liang

MOTION by Defendant Quanzhou Haixin Garment Technology Co., Ltd. for leave to file excess pages UNOPPOSED

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's response to the motion to dismiss [66] is due by December 30, 2024 and Defendant's reply is due by January 9, 2025. The motion for excess pages [67] is granted. Mailed notice.

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[69]

Exhibit 1

Exhibit 2

DECLARATION of Michael A. Hierl regarding motion for default judgment[69]

Exhibit Hierl Exhibit 1

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion [69] for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before December 18, 2024. If no objections are filed by that date, the court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by December 16, 2024. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by William Benjamin Kalbac on behalf of TV Tokyo Corporation

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

PRO SE Appearance by Defendant JING ZHU,an Individual doing business as Yiwu Wenzan Apparel CO., Ltd. (Received via pro se email on 12/13/2024)

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

OPPOSITION to Plaintiff's Motion for Summary Judgment by Yiwu Wenzan Apparel Co., LTD's No. 224. (Received via pro se email on 12/18/2024)

CERTIFICATE of Service filed by Yiwu Wenzan Apparel Co., LTD's No. 224, Jing Zhu. (Received via pro se email on 12/18/2024)

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendant Quanzhou Haixin Garment Technology Co., Ltd. No Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [69] is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants (Plaintiff has failed to seek an accounting of profits), the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $75,000 is an appropriate award of statutory damages. Enter Final Partial Judgment Order. Mailed notice.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Lindsay C. Jenkins on 12/19/2024. Mailed notice.

STATUS Report by TV Tokyo Corporation

MINUTE entry before the Honorable Lindsay C. Jenkins: The Order of default is vacated as to Defendant Yiwu Wenzan Apparel Co., LTD only. This Defendant should not have been included in the default judgment materials Plaintiff submitted because the Court directed the parties to meet and confer and provide an update by way of a status report. It is unclear whether the conferral occurred as the Court directed. Lobodzinsk reports that the parties did not confer [79] and Plaintiff's status report states only that the parties were not able to reach an agreement [81]. In light of Defendant Yiwu Wenzan Apparel Co., LTD.'s efforts to appear and respond and the Court's preference to resolve cases on the merits, the Court provides Defendant Yiwu Wenzan Apparel Co., LTD until January 17, 2025 to retain US counsel and file an answer to the complaint, or otherwise resolve the matter with Plaintiff. As previously explained, Lobodzinski is not a licensed attorney, and a pro se litigant may only represent himself in federal court, not another person or entity. If no answer or responsive pleading is filed by Yiwu Wenzan Apparel Co., LTD by that date, Plaintiff may file the appropriate motion. Mailed notice.

STATUS Report filed by Jing Zhu, an individual doing business as Yiwu Wenzan Apparel Co., Ltd. (Received via pro se email on 12/23/2024)

SATISFACTION of Judgment

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.

RESPONSE by Plaintiff TV Tokyo Corporation Plaintiff's Response to Defendant's Motion to Dismiss [Dkt. No. 66]

Exhibit A

Exhibit B

SATISFACTION of Judgment

ATTORNEY Appearance for Defendant Quanzhou Haixin Garment Technology Co., Ltd. by Brian Swift

REPLY by Quanzhou Haixin Garment Technology Co., Ltd. to Response[85]

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to dismiss [66] for lack of jurisdiction is denied. Personal jurisdiction may be either general or specific. See Daimler AG v. Bauman, 571 U.S. 117, 12628 (2014), and Plaintiff has established a prima facie case of specific personal jurisdiction over Defendant Quanzhou Haixin Garment Technology Co., Ltd. Defendant's argument against specific personal jurisdiction is that it did not conduct business in Illinois and did not direct or target their allegedly infringing activities to the Illinois market [Dkts. 66, 89] But the materials included in Plaintiff's response, including a purchase order dated March 2024 using an order number ending in 6462 involved an order for a counterfeit product from Defendant, that listed a Bensenville, Illinois address for shipping that had been placed but was awaiting confirmation. [Dkt. 85-1 at 6.] Even assuming the order was cancelled and never shipped, the Court agrees with other decisions in this district that it cannot allow a defendant to avoid this Court's jurisdiction by apparently cancelling the order after it was placed. RABUS GmbH v. Individuals Identified on Schedule A, 2022 WL 7501046 (N.D. Ill. 2022); Pit Viper, LLC v. The P'Ships, et al., Case No. 23-cv-14761. Here, the order was placed and Defendant assigned it an order number, which is sufficient to make a prima facia showing of purposeful availment at this stage. Defendants were ready, willing, and able to ship products to an Illinois address. NBA Properties, Inc. v. HANWJH, 46 F.4th 614, 624 (7th Cir. 2022) (purposeful direction aimed at Illinois where the defendant established an online storefront, indicated a willingness to sell to Illinois, and fulfilled an order by "intentionally shipping an infringing product to the customer's designated Illinois address.") The remaining requirements for personal jurisdiction are also satisfied because the contact at issue relates to this suit and Defendant has taken steps to make its products, including those at issue in this case, available to Illinois customers. As such, it does not offend traditional notions of fair play and substantial justice for Defendant to defend against the claims in this forum. Defendant's answer is due by January 17, 2025. By January 24, 2025, the parties are to jointly propose a fact discovery schedule and if either party wishes to conduct jurisdictional discovery, it should be included in the proposed schedule to occur alongside fact discovery. Mailed notice.

SATISFACTION of Judgment

ANSWER to Complaint by Quanzhou Haixin Garment Technology Co., Ltd.

ANSWERS to Plaintiff's Complaint by Yiwu Wenzan Apparel Co., Ltd. (Exhibits) (Received via pro se email on 1/17/2025)

DECLARATION of Jing Zhu. (Exhibits) (Received via pro se email on 1/17/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: As to Yiwu Wenzan Apparel Co., Ltd., the Court provided this Defendant until January 17, 2025 to retain US counsel and file an answer to the complaint, or otherwise resolve the matter with Plaintiff. The filings at docket entries 93 and 94 were made by Jing Zhu, who is not a licensed lawyer and therefore he cannot make filings on behalf of Yiwu Wenzan Apparel Co., Ltd. The declaration states that Jing Zhu is operator and business owner, but not that he is licensed to represent another entity in this case. The Court provided Defendant Yiwu Wenzan Apparel Co., Ltd with more than 3 weeks to either retain counsel who can appear and answer the matter, but that has not occurred, so the filing at 93 is stricken. Plaintiff should file the appropriate motion as to this Defendant by or before February 5, 2025. Mailed notice.

MOTION by Defendant Yiwu Wenzan Apparel Co., Ltd. to reconsider.

Declaration of Jing Zhu

MOTION by Defendant Quanzhou Haixin Garment Technology Co., Ltd. to Modify Asset Restraint [Dkt. 44]

by TV Tokyo Corporation Proposed Joint Discovery Schedule

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Yiwu Wenzan Apparel Co., Ltd's motion to reconsider [96] is granted. Jing Zhu represents that he is the sole proprietor doing business as Defendant Yiwu Wenzan Apparel Co., Ltd. Mr. Zhu argues that as a sole proprietor, he may appear on Yiwu Wenzan Apparel Co.'s behalf. The Seventh Circuit agrees that a sole proprietorship may litigate pro se. United States v. Hagerman, 545 F.3d 579, 581 (7th Cir. 2008) ("A sole proprietorship may litigate pro se. because it has no legal identity separate from the proprietor himself." (citations omitted)); Jeroski v. Fed. Mine Safety & Health Rev. Comm'n, 697 F.3d 651, 652 (7th Cir. 2012) ("A proprietorship is not a legal entity, but merely a name under which the owner, who is the real party in interest, does business."). Thus, Yiwu Wenzan's filing at [93], which the Court treats as a motion to dismiss, shall stand. Plaintiff's response is due by February 10, 2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: As to the motion to modify the asset restraint on Defendant Quanzhou Haixin Garment Technology Co., Ltd. [97], Plaintiff's response to the motion is due by February 24, 2025 and Defendant Quanzhou Haixin's reply is due by March 3, 2025. The Court imposes the following fact discovery schedule as proposed by Plaintiff and Defendant Quanzhou Haixin Garment: Rule 26(a)(1) disclosures are due by February 28, 2025; written discovery may issue beginning on March 28, 2025; third-party platform discovery may issue by March 28, 2025; all fact discovery including third-party platform discovery must be noticed in time for completion by June 27, 2025. The parties are to file a joint status report by June 6, 2025 that confirms fact discovery will conclude on time and that proposes an expert discovery schedule. Mailed notice.

RESPONSE by Plaintiff TV Tokyo Corporation Plaintiff's Response to Defendant's Motion to Dismiss [Dkt. No. 93]

Exhibit A

Exhibit B

Exhibit C

Exhibit D

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Yiwu Wenzan Apparel Co., Ltd's motion to dismiss [93] is denied, though the filing at docket entry [93] may stand as this Defendant's answer. See attached Order for further details. The Court imposes the same fact discovery schedule on Defendant Yiwu Wenzan Apparel Co., Ltd as is in place for the other appearing Defendant in this case. That is, Rule 26(a)(1) disclosures are due by February 28, 2025; written discovery may issue beginning on March 28, 2025; third-party platform discovery may issue by March 28, 2025; all fact discovery including third-party platform discovery must be noticed in time for completion by June 27, 2025. All the parties are to file a joint status report by June 6, 2025 that confirms fact discovery will conclude on time and that proposes an expert discovery schedule. Mailed notice.

ORDER Signed by the Honorable Lindsay C. Jenkins on 2/12/2025. Mailed notice.

RESPONSE by Plaintiff TV Tokyo Corporation Plaintiff's Response to the Motion to Modify the Asset Restraint of Defendant No. 110 "QUANZHOU HAIXIN GARMENT TECHNOLOGY CO., LTD." [Dkt. No. 97]

Exhibit A

SATISFACTION of Judgment

REPLY by Quanzhou Haixin Garment Technology Co., Ltd. to Response, [104]

Declaration of Ni Lang

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Quanzhou Haixin Garment Technology Co's motion to modify the asset restraint [97] is granted. Defendant argues that $165,720.52 is restrained in its Alibaba seller account "as compared to a total revenue and maximum equitable award of $0 from sales of the allegedly infringing products, which strains equity." Plaintiff responds only by arguing that it would be premature for the Court to reduce the asset restraint before the parties complete discovery. Still, the Court agrees with Defendant that there is at least some indication that the current restraint includes funds that Defendant obtained from the sales of other products unrelated to the alleged infringing sales in this case, and Plaintiff has no interest or claim in those funds. [Dkt. 66-1 at 2.] A reduction of the restraint is appropriate, though the Court declines to eliminate the restrain altogether as Defendant advocates. After all, Plaintiff has responded with an affidavit of its own stating that information regarding the sales of Defendant's infringing products located on Alibaba's platform had not been supplied, so Defendant's assertion that revenue from sales of the allegedly infringing product is $0.00 remains untested, and there has been no accounting. The current restrain is modified to reflect that any funds in excess of $2,500 must be released immediately by Alibaba. Mailed notice

STIPULATION of Dismissal Stipulation of Voluntary Dismissal

MOTION to Modify Asset Restraint filed by defendant Jing Zhu, Yiwu Wenzan Apparel Co., Ltd. (Received via pro se email on 5/12/2025)

DECLARATION of Jing Zhu. (Exhibits) (Received via pro se email on 5/12/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court declines to provide the length of time requested by the parties to resolve the straightforward question of an asset restraint. Plaintiff's response to the motion to modify the asset restraint is due by May 23, 2025. Any reply is due by May 30, 2025. Mailed notice.

RESPONSE by Plaintiff TV Tokyo Corporation Plaintiff's Response to the Motion to Modify the Asset Restraint of Defendant No. 224 "YIWU WENZAN APPAREL CO., LTD." [Dkt. No. 112]

Exhibit A

Exhibit B

DECLARATION of Jing Zhu of Yiwu Wenzan Apparel Co., Ltd. (Exhibits) (Received via pro se online portal on 5/24/2025)

REPLY to Plaintiff's Response in Opposition to Defendant's Motion to Modify Asset Restraint filed by Defendant Jing Zhu for Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 5/24/2025)

EXHIBITS filed by Jing Zhu of Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 5/27/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Jing Zhu, Yiwu Wenzan Apparel Co., Ltd's motion to modify the asset restraint [112] is granted. Defendant argues that the nearly $460,000 currently restrained in its Alibaba account should be limited to that which Plaintiff is reasonably likely to recover pursuant to an equitable accounting of profits in this case. 17 U.S.C. § 504(a). According to this Defendant, there has been $0 in revenue from sales of the allegedly infringing products. Plaintiff responds that Defendant's actual sales remain disputed since no discovery has taken place, and even if Defendant's sales were known, Plaintiff's actual damages are irrelevant to a determination of statutory damages. It also argues that its request for an asset restraint prevents asset dissipation until a final accounting can be performed. [115] The Court agrees with Defendant, however, that the current asset restraint covers a substantial amount, including money that Defendant obtained from the sales of other products that is completely unrelated to this case. [117 at 3] A reduction is therefore appropriate. Plaintiff proposes that a significant (albeit lower) restraint be imposed given the list price of Defendant's hats and the considerable inventory Defendant has on hand. [115 at 6.] The current restrain is modified to reflect that any funds in excess of $150,000 must be released immediately by Alibaba. Mailed notice.

DECLARATION of Jing Zhu (Exhibits) (Received via pro se online portal on 5/29/2025)

REPLY by Defendant Yiwu Wenzan Apparel Co., Ltd. to Plaintiff's Response in Opposition to Defendant's motion to modify asset restraint. (Received via pro se online portal on 5/29/2025)

STATUS Report by TV Tokyo Corporation

REPLY in Support Defendants' Motion to Reduce Asset Restraint filed by Defendant, Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 6/6/2025)

EXHIBITS filed by Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 6/6/2025)

REVISED REPLY in Support Defendants' Motion to Reduce Asset Restraint filed by Defendant. Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 6/7/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Yiwu Wenzan Apparel Co., Ltd has filed additional documents concerning its request to modify the asset restraint [121, 123, 124]. The court already granted the motion to modify the restraint and reduced it from $460,000 to $150,000. In so doing, the court considered the argument that there has been $0 in revenue from sales of the allegedly infringing products, but the court declined to reduce the restraint to $0. Given the list price of Defendant's hats and the considerable inventory Defendant has on hand (See Dkt. 115 at 6 "An asset restraint is appropriate given the fact that Defendant has disclosed an inventory of at least 1,000,000 hats priced from $0.95 to $1.68 per hat), some restraint remains necessary. The court has authority to freeze assets "to preserve an equitable accounting of profits, a remedy provided to counterfeiting victims by 15 U.S.C. § 1117(a)." Klipsch Grp., Inc. v. Big Box Store, Ltd., 2012 WL 5265727, at *4 (S.D.N.Y. Oct. 24, 2012.) "The appropriate scope of prejudgment restraint must be limited only to what is reasonably necessary to secure the (future) equitable relief." Deckers Outdoor Corp. v. P'ships & Unincorporated Ass'ns Identified on Schedule A, 2013 WL 12314399, at *2 (N.D. Ill. Oct. 31, 2013). "To exempt assets from an asset freeze, the burden is on the party seeking relief to present documentary proof that particular assets are not the proceeds of counterfeiting activities." Monster Energy Co. v. Wensheng, 136 F. Supp. 3d 897, 910 (N.D. Ill. 2015). Yiwu Wenzan Apparel Co. has not presented an accounting of the restrained funds, so the Court declines to disturb the prior ruling. Roadget Bus. Pte. Ltd. v. Schedule A Hereto, No. 24 C 607, Doc. 77 (N.D. Ill. Apr. 16, 2024) (granting motion to modify asset restraint when defendants provided data obtained from online sales platform with accompanying affidavit from employee at online sales platform explaining how the platform collected the data). The restraint remains at $150,000. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: As between Plaintiff and Defendant No. 224 "Yiwu Wenzan Apparel Co., Ltd," the status report states that the parties have exchanged written discovery. Based on the report, fact discovery will close by the June 27, 2025 deadline. The court modifies the proposed expert discovery schedule as follows: Plaintiff must disclose any expert witness by July 25, 2025 and any expert witness disclosed by Plaintiff must be deposed by August 29, 2025. By August 25, 2025, the parties must jointly file a status report that (a) confirms Plaintiff's expert witness discovery has concluded; and (b) confirms that Defendant intends to designate and disclose an expert witness. If Defendant intends to disclose an expert witness, then that that aspect of expert discovery must conclude by September 26, 2025. The court will then set a dispositive motion briefing schedule to commence in October 2025. Mailed notice.

EXHIBITS filed by Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 6/9/2025)

SATISFACTION of Judgment

DECLARATION of JING ZHU, the sole proprietor of Yiwu Wenzan Apparel Co., Ltd. (Exhibits) (Received via pro se online portal on 6/12/2025)

MOTION for Reconsider of Asset Restraint Reduction filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 6/13/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for reconsideration [131] related to the asset freeze is denied. Defendant Yiwu Wenzan Apparel Co., Ltd. has stated multiple times in multiple ways that the Asset Restraint should be reduced to $0 because revenue from sales of the allegedly infringing product is $0.00. The materials it submitted most recently hardly constitute an accounting: it has filed a one-page screenshot of an Alibaba "amount details page" that is nearly indecipherable to the court, and has not been subject to adversarial testing through fact discovery. The court already reduced the restraint but declines to eliminate it altogether for the reasons already explained. The schedule at docket entry [126] stands. Mailed notice.

AFFIDAVIT of Custodial Certification filed by Liyi Lei. (Received via pro se online portal on 6/23/2025)

SATISFACTION of Judgment

MOTION for reconsider of asset restraint reduction filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 6/25/2025)

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Opposed Motion to Extend the Discovery Deadline

MINUTE entry before the Honorable Lindsay C. Jenkins:Yiwu Wenzan Apparel Co has submitted its third filing asking the court to modify the asset restraint. The most recent motion relies on the same information submitted with the second motion for reconsideration, that is the screenshot attached to docket entry [130] at page 3. It also cites to other district court cases where courts modified the restraint so as not to "exceed the profits generated from the sales." The court already took these matters into account when it concluded that a $460,000 asset restraint was unwarranted because it potentially included money that Defendant obtained from the sales of other products unrelated to this case. But the court declines, for the final time, to reduce the restraint to $0 or $3.80, which is the amount Yiwu Wenzan Apparel Co says constitutes its revenue from sales of the allegedly infringing product. Fact discovery will reveal the extent of sales of infringing and unrelated products. The motion [135] is denied. The motion to extend fact discovery [136] is granted, though it is not clear whether Defendant opposes the request. Fact discovery is extended to July 28, 2025. The expert discovery schedule set by docket entry [126] stands, and the status report regarding expert discovery is due by August 25, 2025. Mailed notice.

MOTION by Plaintiff TV Tokyo Corporation to compel Plaintiff's Motion to Compel Responses to Discovery Requests of Defendant No. 224 "YIWU WENZAN APPAREL CO., LTD." and for Attorneys' Fees

Exhibit A

Exhibit B

Exhibit C

Exhibit D

RESPONSE by Plaintiff TV Tokyo Corporation to Defendant's first set of production requests. (Received via pro se online portal on 7/19/25)

RESPONSE by Defendant Yiwu Wenzan Apparel Co., Ltd. to plaintiff's motion for compel response to discovery requests (Dkt. No. [138]) (Received via pro se online portal on 7/19/25)

RESPONSE by Plaintiff TV Tokyo Corporation to Defendant's No. 224 "Yiwu Wenzan Apparel Co., Ltd."S Interrogatories. (Received via pro se online portal on 7/19/25)

SUPPLEMENT by Yiwu Wenzan Apparel CO., Ltd. to Defendant No. 224 Yiwu wenzan Apparel Co., Ltd. Supplement for First set of discovery. (Received via pro se online portal on 7/19/25)

DEFICIENCIES by Yiwu Wenzan Apparel Co., Ltd. in Plaintiff's Responses to Defendant's first Set of Discovery Requests to Defendant No.224 Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 7/19/25)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to compel and for attorney's fees as to Defendant No. 224 Yiwu Wenzan Apparel Co., Ltd is set for a telephonic status hearing on July 30, 2025, at 10:00 am CT. It is not clear the extent to which the parties met and conferred as required by LR 37.2. The motion references time Plaintiff expended meeting and conferring, but the details of those efforts are not spelled out. Defendant may file a brief in response to the motion to compel by July 28, 2025, and before the July 30 status hearing, the parties are directed to make a genuine effort to comply with LR 37.2 about their disagreements and be prepared to explain those efforts at the hearing. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: 855-244-8681, Access Code: 2302 225 8245. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, 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 Yiwu Wenzan Apparel Co., Ltd. for extend the deposition (Received via pro se online portal on 7/21/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The court construes the motion to extend [145] as a request that the court allow Defendant Yiwu Wenzan Apparel Co., Ltd's upcoming deposition to taken place by zoom given its residence in China. It also requests the court change the date of the deposition from July 24, 2025 to July 28, 2025. It appears reasonable to allow the deposition to proceed virtually under the circumstances, and the court requests that Plaintiff's counsel accommodate that aspect of the motion (if counsel had not already communicated its willingness to do so). The court encourages the parties to work out an agreeable date and time for the deposition, but declines to order a specific date for the deposition, other than that the deposition must occur before the close of fact discovery on July 28, 2025. Defendant Yiwu Wenzan Apparel Co., Ltd is reminded that its response to the motion to compel and for attorney's fees is due by July 28, 2025 and the matter remains set for a telephonic hearing and ruling on July 30, 2025 at 10:00 am CT. Mailed notice.

MOTION to Dismiss Plaintiff's Claims filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 7/23/2025)

RESPONSE to Plaintiff's Motion for Compel Responses to Discovery Request, Docket No. [138] filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 7/25/2025)

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Motion to Extend Discovery Deadline, Compel the Deposition of Defendant No. 224 "YIWU WENZAN APPAREL CO., LTD." and Award Costs, Attorneys' Fees and Sanctions

Exhibit A

Exhibit B

RESPONSE to Plaintiff's Motion for Motion to extend discovery deadline Dkt. No. [148] filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 7/28/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to dismiss [147] is denied. The court already denied Defendant Yiwu Wenzan Apparel Co., Ltd's motion to dismiss in a written order dated February 12, 2025. [See docket entry [103]]. This Defendant has also filed an answer, see docket entry [93], so the motion is procedurally improper and substantively frivolous, especially considering that fact discovery is nearing its end. The July 30, 2025 telephonic status hearing stands, where the court will address both Plaintiff's motion to compel and the motion to extend the fact discovery deadline. Defendant should be prepared to say (a) when he will provide answers to written discovery; and (b) when he will sit for his deposition. The court advises Defendant that it has the power to enter default judgment against a party to a case who violates discovery rules or other court orders, as one of several available sanctions. Fed. R. Civ. Pro. 37(b)(2)(A)(vi). Greyer v. Ill. Dep't of Corr., 933 F.3d 871, 877 (7th Cir. 2019). Mailed notice.

MOTION to compel responses to discovery requests of Plaintiff filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 7/29/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: Telephone conference held. For the reasons stated on the record, Plaintiff's motion to compel responses to discovery request of Defendant No. 224 Yiwu Wenzan Apparel Co, Ltd. and for attorneys' fees [138] withdrawn. Plaintiff's motion to extend the discovery deadline and to compel the deposition of Defendant No. 224 Yiwu Wenzan Apparel Co, Ltd. [148] is granted in part. Fact discovery is extended to August 29, 2025. The parties shall arrange for the Defendant's deposition by August 1, 2025 and for the remaining depositions during the week of August 4, 2025. Plaintiff shall submit a proposed protective order to the Judge's P.O. Box by or before August 6, 2025. Defendant shall respond to the written discovery deficiencies by August 6, 2025. By August 13, 2025, the parties shall jointly file a status report as to the progress of fact discovery. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: After the telephone conference in this matter concluded on July 30, 2025, the clerk's office docketed Defendant's response to Plaintiff's motion to compel discovery responses [Dkt 151]. The document objects to Plaintiff's written discovery requests by stating things like "Plaintiff has not registered the red Cloud graphic copyright individually"; "Plaintiff has no right to make claim without holding copyright of red cloud graphic"; "in no case does copyright protection for an original work of authorship extend to any idea"; and that "Copyright cannot cover the Red Cloud image." These statements are not responsive to the interrogatories, requests for production or requests to admit so the court overrules Defendant's objections. The motion to compel has been granted and Defendant must provide written responses to Plaintiff's discovery requests as previously ordered. To repeat, the court now orders Defendant to respond to written discovery by August 6, 2025 and the depositions discussed at the conference shall take place on the timeframe described. [see docket entry 150]. The court reiterates that it has the power to enter default judgment against a party to a case who violates discovery rules or other court orders, as one of several available sanctions. Fed. R. Civ. Pro. 37(b)(2)(A)(vi). Greyer v. Ill. Dep't of Corr., 933 F.3d 871, 877 (7th Cir. 2019). Mailed notice

MOTION to Obtain Counsel and extend the deposition and discovery deadline filed by Defendant Yiwu Wenzan Apparel Co., Ltd. (Received via pro se online portal on 7/31/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: Enter Confidentiality Order. Mailed notice

CONFIDENTIALITY Order Signed by the Honorable Lindsay C. Jenkins on 8/1/2025. Mailed notice

MINUTE entry before the Honorable Lindsay C. Jenkins:The motion to compel 153 is denied. Defendant issued a deficiency letter regarding Plaintiff's responses to interrogatories, requests to admit and requests to produce. Plaintiff's responses to that discovery have been docketed at entries 140, 142, 143 and 144. The court disagrees that Plaintiff's responses are deficient. Many of the answers direct Defendant to Plaintiff's Copyright Registration No. PA 2-276-002, which it provided with its responses. Defendant has requested "the high quality of the original cloud copyrighted artwork image," but the motion does not explain the need for this information in light of the registration information produced. Given that this case alleges that Defendant infringed Plaintiff's copyright, Plaintiff need not provide Defendant with "a high-quality image, digital file with meta data," when the image has been provided in the registration documents. None of Defendant's other arguments or objections are well taken, so the responses Plaintiff provided stand.Mailed notice

MINUTE entry before the Honorable Lindsay C. Jenkins: The court encourages Defendant Yiwu Wenzan Apparel Co., Ltd. to obtain US counsel, but it declines the extend the fact discovery deadline beyond August 29, 2025. If Defendant obtains counsel and that person files an appearance in the case, the court will take up any issues regarding discovery at that time. But the previous deadlines and instructions and deadlines stand, see docket entries 150 and 152. Mailed notice.

MOTION by Plaintiff TV Tokyo Corporation to compel Plaintiff's Motion to Compel Responses to Discovery Requests, Produce Defendants for Deposition, Extend Discovery Deadline and Award Attorneys Fees, Costs and Sanctions Against Defendant No. 224 "YIWU WENZAN APPAREL CO., LTD."

Exhibit A

Exhibit B

STATUS Report Joint Status Report by TV Tokyo Corporation

ATTORNEY Appearance for Defendant Yiwu Wenzan Apparel Co., Ltd. by Adam M. Berger

ORDER: The court issues the attached order on Plaintiff's motion to compel; the motion is entered and continued. As detailed in the order: 1. Jing Zhu must sit for a second deposition from Plaintiff by or before September 22, 2025, See Fed. R. Civ. P. 30(a)(2)(A)(ii); and 2. Defendant must make S. Suave Lobodzinski and Xin Lan available for depositions by or before September 22, 2025; and 3. Defendant has one final opportunity to provide adequate responses to Plaintiff's outstanding written discovery, which must be submitted to Plaintiff by no later than August 21, 2025. Fact discovery is extended to September 29, 2025, and a joint status report is due by September 25, 2025. Once these things are accomplished, the court will provide Defendant an opportunity to respond in writing to the request for fees and costs associated with the motion and with the re-deposition the court has ordered. The court has now made crystal clear what Defendant and Jing Zhu must do to comply; any continued failure to comply with this order will result in entry of default judgment against Defendant Yiwu Wenzan Apparel Co., Ltd. The court reiterates, for the final time, that following these instructions is the only way for Defendant and Jing Zhu to comply. No motion that it has filed or may file in the future will excuse Defendant or Jing Zhu from sitting for the deposition, making the witnesses listed above available for their depositions; and from answering written discovery. If Jing Zhu or Defendant chooses not to do what the court has ordered, they know what the consequence will be. "Parties ignore court orders at their peril." NLRB v. Haven Salon + Spa, Inc., 60 F.4th 1058, 1059 (7th Cir. 2023). Signed by the Honorable Lindsay C. Jenkins on 8/14/2025. Mailed notice.

ATTORNEY Appearance for Defendant Yiwu Wenzan Apparel Co., Ltd. by Jianwei Du

STATUS Report Joint Status Report by TV Tokyo Corporation

MINUTE entry before the Honorable Lindsay C. Jenkins: The parties report that they have reached a settlement but need time to finalize their written settlement agreement. A stipulation of dismissal is due by October 6, 2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: In light of the parties' pending resolution of the case, the motion to compel [160] is terminated as moot. Mailed notice.

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Motion for a First Extension of Time to File its Stipulation of Dismissal as to Defendant No. 224 "YIWU WENZAN APPAREL CO., LTD." [Dkt. No. 166]

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for an extension of time 168 is granted. A stipulation of dismissal is now due by October 20, 2025. Mailed notice.