2024-cv-11493

COMPLAINT filed by Anagram International, LLC; Filing fee $ 405, receipt number AILNDC-22701731.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff Anagram International, LLC Schedule A to Complaint 1 Modified on 1/20/2025.

CIVIL Cover Sheet

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

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Yi Bu

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Adam Grodman

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

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

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Christopher Romero

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

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

MOTION by Plaintiff Anagram International, LLC for leave to file under seal

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

MEMORANDUM in support of 14 Exparte motion

Declaration of Keith A. Vogt

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

Declaration of Christopher Wiles

(Exhibit 1, of Christopher Wiles' declaration)

DECLARATION by Plaintiff Anagram International, LLC Sealed Exhibit 2, Declaration of Christopher Wiles regarding memorandum in support of motion, 15 Modified on 1/20/2025.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

(Exhibit 2-7)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 12, motion to exceed page limitation 13, and 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 14 are set for a telephonic motion hearing on 12/4/2024 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 Andrea R. Wood: Telephonic status hearing held on 12/4/2024. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 12, motion to exceed page limitation 13, and 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 14 are entered and continued. By 12/6/2024, Plaintiff shall make a supplemental filing that establishes Plaintiff's right to assert the intellectual property rights at issue. Telephonic status hearing set for 12/20/2024 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

SUPPLEMENT to order on motion for leave to file, order on motion for leave to file excess pages, order on motion for exparte, set/reset hearings, motion hearing, 18, memorandum in support of motion, 15 Supplemental Declaration of Christopher Wiles

Exhibit 1, filed under seal

(Exhibit 2)

MOTION by Plaintiff Anagram International, LLC for leave to file under seal

SEALED Exhibit 1 to Supplemental Declaration of Christopher Wiles by Anagram International, LLC [19-1] Docket Text Modified by Clerk's Office.

(Exhibit 1 of Supplemental Declaration of Christopher Wiles)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 12/20/2024. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 12, 20, motion to exceed page limitation 13, and 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 14 are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to complaint 2, (2) Sealed Exhibit 2, Declaration of Christopher Wiles 16, and (3) Supplemental Declaration 21. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:15 a.m. on 12/20/2024 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 1/3/2025 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

TEMPORARY Restraining Order: Signed by the Honorable Andrea R. Wood on 12/20/2024. Mailed notice Modified on 1/20/2025.

TEMPORARY Restraining Order (Corrected): Signed by the Honorable Andrea R. Wood on 12/20/2024. Mailed notice Modified on 1/20/2025.

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 12/20/2024: Mailed notice.

MOTION by Plaintiff Anagram International, LLC for extension of time to Post Bond

SURETY BOND in the amount of $ 10,000 posted by Anagram International, LLC (document not scanned)

MOTION by Plaintiff Anagram International, LLC for preliminary injunction

MEMORANDUM by Anagram International, LLC in support of motion for preliminary injunction 27

Declaration Of Keith A. Vogt

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

SUMMONS Returned Executed by Anagram International, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/31/2024, answer due 1/21/2025.

(Declaration of Service)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 1/3/2025. For the reasons stated on the record, Plaintiff's motion for entry of preliminary injunction 27 is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal docket entries 2, 16, 23, 24. Plaintiff's counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 2/4/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Andrea R. Wood on 1/3/2025. Mailed notice.

ATTORNEY Appearance for Defendant MelsanDirect by Baruch Simcha Gottesman

MOTION by Defendant MelsanDirect for extension of time to file answer regarding complaint[1], summons returned executed[29] (Unopposed Motion to Extend Time to Answer until February 3, 2025)

ATTORNEY Appearance for Defendant Concico by Haipeng Xiao

MOTION by Defendant Concico for extension of time (Unopposed)

ATTORNEY Appearance for Defendant Bextsrack Directly by Michael Thomas Stanley

MOTION by Defendant Bextsrack Directly for extension of time to file answer regarding complaint[1]

ATTORNEY Appearance for Defendant JoySpot by Yong Chen

MOTION by Defendant JoySpot for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable Andrea R. Wood: Defendant MelsanDirect's motion on consent for an extension of time to answer or otherwise move with respect to the complaint [34] is granted. Defendant MelsanDirect shall answer or otherwise respond to the complaint by 2/3/2025. Defendant Concico's unopposed motion for extension of time [36] is granted. Defendant Concico shall answer or otherwise respond to the complaint by 2/20/2025. Defendant Bextsrack Directly's motion for extension of time to respond to the complaint [38] is granted. Defendant Bextsrack Directly shall answer or otherwise respond to the complaint by 2/11/2025. Defendant JoySpot's motion for extension of time [40] is granted. Defendant JoySpot shall answer or otherwise respond to the complaint by 2/11/2025. Plaintiff's motion for extension of time to post bond [25] is terminated as moot. Mailed notice

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 leave to file under seal

SEALED DOCUMENT by Plaintiff Anagram International, LLC Statement

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

MEMORANDUM by Anagram International, LLC in support of motion for default judgment[46]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

ATTORNEY Appearance for Defendants Delicioc, hengzirui, Ingridstore, JertbinR, Ndyrrri, Senikei, Shisuyan, Weisidun, Delandmont, Tinnitus, ChuZhouZhanHen, Bicheness, KEWENN, LWEEIN by Adam Edward Urbanczyk

MOTION by Defendants Delicioc, hengzirui, Ingridstore, JertbinR, Ndyrrri, Senikei, Shisuyan, Weisidun, Delandmont, Tinnitus, ChuZhouZhanHen, Bicheness, KEWENN, LWEEIN for extension of time

MINUTE entry before the Honorable Andrea R. Wood: Defendants Delicioc, hengzirui, Ingridstore, JertbinR, Ndyrrri, Senikei, Shisuyan, Weisidun, Delandmont, Tinnitus, ChuZhouZhanHen, Bicheness, KEWENN, and LWEEIN's motion for extension of time [49] is granted. Those Defendants shall answer or otherwise respond to Plaintiff's complaint by 2/20/2025. Plaintiff's motion for entry of default and default judgment against the Defendants identified in First Amended Schedule A [46] will be heard at the telephonic hearing set for 2/4/2025 at 9:00 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no 129 Foclover

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 2/4/2025. Telephonic status hearing set for 2/25/2025 at 9:00 AM, for Plaintiff and Defendants Delicioc, hengzirui, Ingridstore, JertbinR, Ndyrrri, Senikei, Shisuyan, Weisidun, Delandmont, Tinnitus, ChuZhouZhanHen, Bicheness, KEWENN, and LWEEIN to report on settlement. Plaintiff's motion for entry of default and default judgment against defendants identified the first amended Schedule A [46] is taken under advisement. Telephonic status hearing set for 2/25/2025 at 9:00 AM, as to remaining non-dismissed defendants. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 All Plaintiffs as to [Certain] defendants

MOTION by Plaintiff Anagram International, LLC to approve consent judgment, MOTION by Plaintiff Anagram International, LLC for permanent injunction as to Defendant No. 113 JoySpot

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's agreed motion for consent judgment and permanent injunction as to Defendant no. 113 [55] will be heard at the telephonic hearing set for 2/25/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 Concico for extension of time Unopposed

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

MINUTE entry before the Honorable Andrea R. Wood: Defendant Concico's motion for extension of time [57] is granted. Defendant Concico shall answer or otherwise respond to Plaintiff's complaint by 3/22/2025. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 139 Jiangbu and defendant no. 54 Bonhomstyle

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 2/25/2025. For the reasons stated on the record, Plaintiff's agreed motion for consent judgment and permanent injunction as to Defendant no. 113 [55] is granted. Enter Order. Plaintiff's motion for entry of default and default judgment against the Defendants identified in First Amended Schedule A [46] is entered and continued. Plaintiff's motion for leave to file under seal [44] is granted. Telephonic status hearing set for 3/26/2025 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

CONSENT JUDGMENT AND PERMANENT INJUNCTION. Signed by the Honorable Andrea R. Wood on 2/25/2025. Mailed notice

ATTORNEY Appearance for Defendant HighPremium by Timothy Tiewei Wang

MOTION by Defendant HighPremium for extension of time to file answer regarding complaint[1] Unopposed

MINUTE entry before the Honorable Andrea R. Wood: Defendant HighPremium's first unopposed motion to extend deadline to answer or otherwise respond [64] is granted. Defendant HighPremium shall answer or otherwise respond to the complaint by 4/14/2025. Mailed notice

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

STIPULATION of Dismissal as to Defendant No. 7 HighPremium

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/26/2025. For the reasons stated on the record, Defendant Concico's deadline to answer or otherwise respond to Plaintiff's complaint is extended to 4/14/2025. Telephonic status hearing set for 4/18/2025 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 All Plaintiffs as to defendant no. 7 HighPremium

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/18/2025 and continued to 5/1/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

STIPULATION of Dismissal as to Defendant No. 6 Concico

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 96 Cihdmfb

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/1/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against defendants identified the first amended Schedule A [46] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 5/2/2025. Mailed notice

MAILED copyright report with order dated 5/2/2025 to Registrar, Washington DC