2024-cv-12596

COMPLAINT filed by Zagtoon Sarl, Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC; Filing fee $ 405, receipt number AILNDC-22812269.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl Schedule A regarding complaint, [1]

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl

Notice of Claims Involving Trademarks by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl by Alexander Whang

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl by Sydney Paige Fenton

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Heather K. McShain. 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 Partnerships And Unincorporated Associations Identified On Schedule A

NEW PARTIES: Cangnan Shuanglian Packaging Co., Ltd., Guangzhou Man Wei Animation Clothing Co., Ltd., Guangzhou Qimei Packaging Printing Co., Ltd., Hangzhou Dan Hong Import And Export Co., Ltd., Hefei Qiyi E-Commerce Co., Ltd., Shaoxing Skyline Import & Export Co., Ltd., Shenzhen Hengtaihao Technology Co., Ltd., Shenzhen Pengrui Technology Co., Ltd., Shenzhen Rain Yip Plastics Co., Ltd., Taizhou Luqiao Yuqing Print And Craft, Taizhou Xinyue Gift Co., Ltd, Xian Decai Honorise New Material Co., Ltd., Yiwu Baige Crafts Co., Ltd., Yiwu Feinuo Clothing Factory, Yiwu Ruoque Trading Co.,ltd, All Night Party Store, Authentic clothes Store, BBTHBDNBY New 326 3C Store, Black Man K Store, Brilliant Party Life Store, Cozy Life Factory Diamond Store, HasbroAnime Figures Toy Store, Hero Party Backdrop Store, Love DIY Clothing Store, M2 Jewelry Store, Maiya Home Decor 321 Store, Modern Canvas Painting Store, Pailou Art Factory Store, Peace Love Clothing Store, SG-Songchang Jewelry Store, Shop1102888430 Store, Shop1102895247 Store, Shop1103009520 Store, Shop1103267057 Store, Shop1103555189 Store, Shop1103575194 Store, Shop1103607387 Store, Shop1103672094 Store, Stitch Baby Home Textiles Store, Superheros Cosplay Store, Uiui Store, ADQHLFEGACO1Q, BOBOE, CASOLVX, CENTRAL_HC_SHOP, FORYOUBEST, HengLong(GuangZhou)ShangMaoYouXianGongSi, hubeimengdasendianzishangwuyouxiangongsi, JENNIY, Liu Congc, liuyizeshop, longying11, PengChengSM, Pgnew, pingdingrongrongshangmaoyouxiangongsi, shErrYLu, UrSIM, xuel Yao, YUXIAO0808, aiyueele08, amazing9999, cngarden, hkshenyusheng02, hkshenyusheng06, jyzg, ko9u, plwd, roq0, rrjg, tjqv, tlqr, zmrj, zqnw, ardhie-492, samuraiz.go, umeerasan53, creativegiftstore, ArtanaFR, Crazyfantasyworld, Labaleinequiembosse, MAMELICOOKIESTAMP, KHALILAHSTORE, 2020 Trending Tees Fashion Store, 2020huaweitee, All Star Shirt, Aunna, azurebuy, beddingdecor.us, Buddpots, casebig, casefine, casesummer, Clotee, Coscrew, Cosplaymade, Costume.Azurebuy, cryptizen, DREAM ART EUROPA, dresskiss, Easteeshirt, favocase, FunnyShirts.net, GhostTshirt, graphicteestore, Kidzishop, Lightbox Goodman, Madeprinted, Melonashirt, moveekbuddy, mugteeco, NihaoStyles, NVDteeshirt, omycos, outlettrends, pajamasbuy, Party On X, Perspirature, posedionclothing, PrimeSporty, PROCOSPLAY, Samyla, simsluvcreations, SWANSDOWNE, teehandy, TEEPOP, Teeuni, TeleTeeShirt, Tshirtpulse, Ultron Digital, VibramTee, Wowshirtstore, XPERFACE, Zentaifan, HongMingJewelry, JiuZunJewelry, JiuZunJewelry local, lingyuuzhidianshiping, QiaoCartoon, TADSRR, YangYuanShiPin, Yiwu Xiyuexi Home Textile, YTCOS, Beauty Snow Store, chuanxunshangmao, Dongyuxing, Funny Kitty Shirts, GTYYNNMTTG, GZLY Co.,Ltd, HONGQI, JiangPengWireless, KEVCHE Co.,Ltd, qinduosi, QiYulight menswear, Qiyunmaoyi, WeiFangChunJianWang, WJXYang, YanTaiYuanLu, YUNZONG, ZhengJieWireless and zhishangbufan(chengdu)jiaju added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarlfor Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for miscellaneous relief[12]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl Exhibit 3, Parts 1-9 regarding declaration[14]

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for miscellaneous relief[16]

Declaration of Martin F. Trainor

Exhibit to MFT Dec. re E-Service

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for leave to file certain documents under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [12], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16] are set for a telephonic motion hearing on 1/24/2025 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 1/24/2025. For the reasons stated on the record, Plaintiffs' motion for leave to file certain documents under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [12], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16] 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 regarding complaint [2], and (2) Exhibit 3, Parts 1-9 regarding declaration [15]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 1/24/2025 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 2/7/2025 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 1/24/2025. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. (Corrected). Signed by the Honorable Andrea R. Wood on 1/29/2025. Mailed notice

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl to Redate the Temporary Restraining Order

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for miscellaneous relief[22]

Declaration of Alexander Whang

MINUTE entry before the Honorable Andrea R. Wood: The minute order dated 1/24/2025 [20] and the Sealed Temporary Restraining Order [21] are corrected to reflect that the Sealed Temporary Restraining Order is entered effective 1/29/2025 at 2:00 PM. Telephonic status hearing set for 2/7/2025 is stricken and reset for 2/12/2025 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

SURETY BOND in the amount of $ 10,000 posted by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl. Document not imaged. daj,)

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl to Extend the Temporary Restraining Order

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for miscellaneous relief[27]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' ex parte motion to extend temporary restraining order [27] is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 2/26/2025. Plaintiffs' ex parte motion to re-date temporary restraining order [22] is terminated as moot. Telephonic status hearing set for 2/12/2025 is stricken and reset for 2/26/2025 at 10:00 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 (888) 557-8511 and the access code is 3547847. 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 (aw,)

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to a certain defendant

SUMMONS Returned Executed by Zagtoon Sarl, Miraculous Z.Part Bidco Inc., ZAG America, LLC as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 2/21/2025, answer due 3/14/2025.

Declaration of Alexander Whang

Exhibit A

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for preliminary injunction

Exhibit A

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for preliminary injunction[32]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for entry of a preliminary injunction as to certain defendants [32] will be heard at the telephonic hearing set for 2/26/2025 at 10:00 AM. Any person wishing to be heard on the motion shall file an appearance and 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

SUMMONS Returned Executed by Zagtoon Sarl, Miraculous Z.Part Bidco Inc., ZAG America, LLC as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 2/25/2025, answer due 3/18/2025.

Declaration of Alexander Whang

Exhibit A

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for preliminary injunction as to Certain Defendants or, Alternatively, to Extend the Temporary Restraining Order

Exhibit A

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for preliminary injunction, [36]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 2/26/2025. As discussed on the record, Plaintiffs' motion for entry of a preliminary injunction as to certain defendants [32] and motion for entry of a preliminary injunction as to certain defendants or, alternatively, to extend the temporary restraining order [36] are entered and continued. The Temporary Restraining Order is extended until 3/4/2025 to allow adequate time for Defendants to receive adequate notice and be heard regarding the motion for a preliminary injunction. Any party aggrieved by the continued Temporary Restraining Order may file a motion for relief and be heard on an emergency basis. Telephonic status hearing set for 3/4/2025 at 9:45 AM. (NOTE DATE CHANGE). 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 Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to a certain defendant

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/4/2025. For the reasons stated on the record, Plaintiffs' motion for entry of a preliminary injunction as to certain defendants [32], [36] are granted. Enter Preliminary Injunction Order. Plaintiff's anticipated motion for default and default judgment shall include a spreadsheet that identifies up-to-date information on the amounts that are being restrained for each of the remaining defendants. Plaintiff is granted leave to file the spreadsheet under seal. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint [2], (2) Exhibit 3, Parts 1-9 regarding declaration [15], and (3) the sealed temporary restraining order [21], [25]. 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 4/3/2025 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 3/4/2025. Mailed notice

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to a certain defendant

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to certain Defendants

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to certain Defendants

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to certain Defendants

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/3/2025 and continued to 5/20/2025 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 5/20/2025 and continued to 6/17/2025 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

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to a certain defendant

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/17/2025 and continued to 7/16/2025 at 9:00 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to certain Defendants

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for entry of default, MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for default judgment as to all Defendants with the exception of Defendant QiYulight menswear

Exhibit A

MEMORANDUM by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl in support of motion for entry of default, motion for default judgment, [51]

Exhibit 1

Exhibit 2

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[52]

Exhibit 1

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl to approve consent judgment (AGREED)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/16/2025. As stated on the record, Plaintiff shall file a supplement in support of the motion for entry of a consent judgment [54] that evidences that Defendant's consent to the proposed relief by 7/21/2025. Plaintiffs' motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of a certain defendant [51] is entered and continued. Telephonic status and motion hearing set for 7/24/2025 at 10:45 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. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

Regarding Proposed Consent Judgment (Joint) STATEMENT by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/24/2025. For the reasons stated on the record, Plaintiffs' motion for entry of a consent judgment [54] and motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of a certain defendant [51] are granted. Enter Consent Judgement and Default Judgment Orders. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 7/28/2025. Mailed notice

MAILED Trademark report with certified copy of minute order dated 7/24/2025 to Patent Trademark Office, Alexandria VA

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to a certain defendant

NOTICE of Voluntary Dismissal by Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl as to a certain defendant

FULL SATISFACTION of Judgment as to a certain defendant