2024-cv-11984

COMPLAINT filed by Ubisoft Entertainment, S.A. and Ubisoft, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-22755443.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. by John Wilson

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ubisoft Entertainment, S.A. and Ubisoft, Inc.

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2).

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 Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Ubisoft Entertainment, S.A. and Ubisoft, Inc. to Hughes Socol PIers Resnick & Dym Ltd Three First National Plaza 70 West Madison Street Suite 4000 Chicago, IL 60602 via certified mail # 9589 0710 5270 0579 7785 67.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Ubisoft Entertainment, S.A. and Ubisoft, Inc. to Hughes Socol PIers Resnick & Dym Ltd Three First National Plaza 70 West Madison Street Suite 4000 Chicago, IL 60602 via certified mail # 9589 0710 5270 0579 7785 67.

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. 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 Ubisoft Entertainment, S.A. and Ubisoft, Inc. in support of motion for temporary restraining order, 11

Declaration Muraccini Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Exhibit 2 Part 1 of Muraccini Declaration

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Exhibit 2 Part 2 of Muraccini Declaration

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Exhibit 2 Part 3 of Muraccini Declaration

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Exhibit 2 Part 4 of Muraccini Declaration

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Exhibit 2 Part 5 of Muraccini Declaration

Notice of Claims Involving Trademarks by Ubisoft Entertainment, S.A. and Ubisoft, Inc.

NOTICE of Motion by Michael A. Hierl for presentment of motion to seal document 7, motion for leave to file excess pages 10, motion for temporary restraining order, 11 before Honorable Elaine E. Bucklo on 11/27/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 7 ; Plaintiff's motion to exceed limitation 10 ; and Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 11 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 12/11/2024 any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 12/4/2025. Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf The case is set for a status hearing on 1/13/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 1/6/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 11/27/2024. Mailed notice.

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 22 before Honorable Elaine E. Bucklo on 12/11/2024 at 09:45 AM.

Surety BOND in the amount of $ 10,000 posted by Ubisoft Entertainment, S.A. and Ubisoft, Inc. (Document not Imaged) (Received at the Intake Counter on 12/5/2024)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex-Parte motion to extend the temporary restraining order 22 is granted to 12/25/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. and Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 38

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order Nunc Pro Tunc from December 25, 2024

(Exhibit 2)

SEALED DOCUMENT by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. Exhibit 1

NOTICE of Motion by Michael A. Hierl for presentment of extension of time, 27 before Honorable Elaine E. Bucklo on 12/27/2024 at 09:45 AM.

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Nunc Pro Tunc to December 25, 2024 Against Defendant Nos. 1-10, 18-37, 39-41 and 73-87

MEMORANDUM by Ubisoft Entertainment, S.A. and Ubisoft, Inc. in support of motion for preliminary injunction, 30

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction, 30

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction, 30 before Honorable Elaine E. Bucklo on 12/27/2024 at 09:45 AM.

SUMMONS Returned Executed by Ubisoft Entertainment, S.A. and Ubisoft, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 12/18/2024, answer due 1/8/2025.

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.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's ex parte motion to extend the temporary restraining order Nunc Pro Tunc from December 25, 2024 27 and motion for entry of a preliminary injunction Nunc Pro Tunc from December 25, 2024 against Defendant Nos. 1-10, 18-37, 39-41 and 73-87 30 are granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Plaintiffs' Schedule A to the Complaint Dkt. No. 8, Exhibit 2 to the Declaration of Marc Muraccini Dkt. Nos. [13-17] and the TRO Dkt. No. 21. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Elaine E. Bucklo on 12/27/2024. Mailed notice.

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Defendant Nos. 11-17 and 42-72

MEMORANDUM by Ubisoft Entertainment, S.A. and Ubisoft, Inc. in support of motion for preliminary injunction 38

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 38

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 38 before Honorable Elaine E. Bucklo on 1/8/2025 at 09:45 AM.

STATUS Report by Ubisoft Entertainment, S.A. and Ubisoft, Inc.

SUMMONS Returned Executed by Ubisoft Entertainment, S.A. and Ubisoft, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 1/3/2025, answer due 1/24/2025.

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiff's status report. Plaintiff's motion for entry of a Preliminary Injunction Against Defendant Nos. 11-17 and 42-72 38 is granted. Status hearing is reset for 2/27/2025 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 2/20/2025. The court will enter an order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. and Ubisoft, Inc. Plaintiffs' Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. and Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. and Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

CERTIFICATE of Service by John Wilson on behalf of Ubisoft Entertainment, S.A. and Ubisoft, Inc.

MOTION by Plaintiff Ubisoft Entertainment, S.A. and Ubisoft, Inc. 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 Ubisoft Entertainment, S.A. and Ubisoft, Inc. in support of motion for default judgment, 49

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 49

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment, 49 before Honorable Elaine E. Bucklo on 2/6/2025 at 09:45 AM.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. and Ubisoft, Inc. Plaintiffs' Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. and Ubisoft, Inc. Plaintiffs' Notice of Voluntary Dismissal as to Defendant No. 26

STATUS Report by Ubisoft Entertainment, S.A. and Ubisoft, Inc.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment against the defendants identified on amended Schedule A 49 is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) via certified mail to counsel of record for Plaintiff to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 3/11/2025. Mailed notice.

MAILED trademark report with order dated 3/11/2025 to Patent Trademark Office, Alexandria VA

RETURN of Service of Certified Mail PS Form 3811 Domestic Return Receipt returned Executed as to Hughes Socol Plers Resnick & Dym Ltd Three First National Plaza 70 West Madison Street Suite 4000 Chicago, IL 60602 via certified mail # 9589 0710 5270 0579 7785 67.

SATISFACTION of Judgment