2024-cv-12643

COMPLAINT filed by Spin Master Ltd., Spin Master Toys UK Limited; Filing fee $ 405, receipt number AILNDC-22816506.

Exhibit 1

SEALED EXHIBIT by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited Schedule A regarding complaint[1]

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Spin Master Ltd., Spin Master Toys UK Limited

Notice of Claims Involving Trademarks by Spin Master Ltd., Spin Master Toys UK Limited

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Yu Hin Jeffrey Tsai (Tsai, Yu Hin)

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2).

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

NEW PARTIES: angelina_baby, babyhouse2020, bear_baby, fine333, gamescard, hy0110, kenhj3359, shirffg0893, yy_dhhome, antique58568, blackfriday79, changchunshichaozhis_0, Chinesearts, Clothing oversold, coconut78978, feichu777, fuqingt09, handanbirangwenhuachuanboyouxiangongsi, hotsale_158159, jinanyixiuzhuangshig_83, Keerfairyshop, lsxsfer1, Millions of winners, New popular children_apo_s clothing, nucleus798, orange8996, PavilionMobao3, psf-01, rstuvwxyz, sunflower-03, taoling090, Toy Mall Factory Store, ucvx6454, UYT-8943, weijie0062, xiangyun-9, ying9487, ypka8241, zhe-8941, zhouhehe66, zhuitaodi798, Adana, Alex Jewelry Store, chuangjiu888, denggudianzi, Emily Store, ERUWIQUIEEQIOWRU, fengdaxinxijishu, Foohvr, Fourall, guang zhou yi yu mao yi you xian gong si, guangzhoubaoruicanyinyouxiangongsi, guangzhouhaishangmaoyi, guangzhoujinhekejiyouxiangongsi, guangzhoupingyishangmaoyouxiangongsi, Guichaokj, Happy Great Sale, helianjudianzikeji, HongDongXianShuoHuaShangMao, hongfukeji, HOURUXING, huanrushangmao, huizhoushihua, JadeBamboo, JIAHONG Co.Ltd, JIAXUXI, jinanjingyidianzixinxikeji, jiuhe188, junovoo, kjhgfdfghjkl, KKAmanda, Kong Xiang, KunMingXiYuanTong, laifuzhubao, longlong88, Maritcute, MASALA, meizizijj, Ming Lee, mingtuyu, Nehlobo, shengboshe, shenzhenhuanmengkeji, shenzhenshiguleyanwangluokeji, shenzhenshipuyukeji, Sunshine Girl, Syudst, tabaikekeji, Trilenars, WIN WITH SCIENCE, WQEIOTUPORT, xiamenshiminhuihonggongmao, XIJIA, XUYEEYUAN, yfikf3450, YGCYYFZ, yoyoyo and yuhua trading co., ltd added to case caption.

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Spin Master Ltd., Spin Master Toys UK Limited in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Susanne Teixeira regarding memorandum in support of motion[12]

Exhibit 1

SEALED EXHIBIT by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited Exhibit 2 - Parts 1-2 regarding declaration[14]

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Spin Master Ltd., Spin Master Toys UK Limited in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[11], motion for miscellaneous relief[16], motion for leave to file[3] before Honorable Jorge L. Alonso on 12/17/2024 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA. (jn,)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials. (jn,)

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Kahlia Roe Halpern

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [11] [16] are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $100,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 12/17/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 12/16/2024. Notice mailed by Judge's staff

Registry Deposit Information Form by Spin Master Ltd., Spin Master Toys UK Limited

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for extension of time of Temporary Restraining Order

MEMORANDUM by Spin Master Ltd., Spin Master Toys UK Limited in support of extension of time 26

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 27

MINUTE entry before the Honorable Jeffrey I Cummings: This matter is before Judge Cummings as the Emergency Judge. Plaintiffs' motion for extension of the TRO 26 is granted. The TRO entered on 12/16/24 24 is extended until 1/13/25. Mailed notice

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.

SURETY BOND in the amount of $ 100,000.00 posted by Spin Master Ltd., Spin Master Toys UK Limited

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for preliminary injunction

(Exhibit A)

MEMORANDUM by Spin Master Ltd., Spin Master Toys UK Limited in support of motion for preliminary injunction 32

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 33

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 32 before Honorable Jorge L. Alonso on 1/8/2025 at 09:30 AM.

(Exhibit A)

SUMMONS Returned Executed by Spin Master Ltd., Spin Master Toys UK Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/3/2025, answer due 1/24/2025.

Declaration of Y. Jeffrey Tsai

(Exhibit A)(Tsai, Yu Hin)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 1/8/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiffs' Motion for entry of a preliminary injunction [32] is granted. Enter Preliminary injunction order. Plaintiff 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 at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 1/8/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Spin Master Ltd. as to certain defendants

NOTICE of Voluntary Dismissal by Spin Master Ltd. as to certain defendants

ATTORNEY Appearance for Defendant JIAHONG Co.Ltd by He Cheng

ANSWER to Complaint, COUNTERCLAIM filed by JIAHONG Co.Ltd against Spin Master Ltd., Spin Master Toys UK Limited. by JIAHONG Co.Ltd

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for extension of time to Respond to Counterclaims [43] (Agreed)

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time[44] before Honorable Jorge L. Alonso on 2/11/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Spin Master Ltd., Spin Master Toys UK Limited as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 2/11/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Rachel S Miller

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Agreed Motion for extension of time for Plaintiffs to respond to counterclaims [43][44] is granted to 3/7/25. Telephonic status hearing set for 3/13/25 at 9:30 a.m. The parties are directed to file a joint status report by 3/10/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Spin Master Ltd., Spin Master Toys UK Limited as to certain defendants

NOTICE of Voluntary Dismissal by Spin Master Ltd., Spin Master Toys UK Limited as to certain defendants

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited to approve consent judgment as to Certain Defendants

Exhibit A

MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for entry of default, MOTION by Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited for default judgment as to certain Defendants

Exhibit A

MEMORANDUM by Spin Master Ltd., Spin Master Toys UK Limited in support of motion for entry of default, motion for default judgment, [53]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[54]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, [53], motion to approve consent judgment[52] before Honorable Jorge L. Alonso on 3/4/2025 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited, Counter Defendants Spin Master Ltd., Spin Master Toys UK Limited by Madeline Halgren

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 3/4/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master Toys UK Limited by Jennifer Van Nacht

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiffs' Agreed Motion for entry of a consent judgment as to certain Defendants [52] is granted. Enter Consent Judgment As To Certain Defendants. Plaintiffs' Motion for entry default and default judgment as to certain Defendants [53] is granted. Enter Default Judgment Order. Notice mailed by Judge's staff

CONSENT Judgment As To Certain Defendants. Signed by the Honorable Jorge L. Alonso on 3/4/2025. Notice mailed by Judge's staff

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 3/4/2025. Notice mailed by Judge's staff

ANSWER to counterclaim and Affirmative Defenses by Spin Master Ltd., Spin Master Toys UK Limited

STATUS Report Pursuant to [49] (Joint) by Spin Master Ltd., Spin Master Toys UK Limited

MINUTE entry before the Honorable Jorge L. Alonso: The Court has reviewed the parties' joint status report [64] and sets the following schedule. Rule 26(a)(1) initial disclosures shall be served by 4/11/25. All fact discovery shall be completed by 9/8/25. The parties shall file a joint status report regarding their proposed next steps within 14 days after the close of fact discovery. This case is referred to magistrate judge for discovery supervision with the authority to set and extend deadlines and a settlement conference. The status hearing previously set for 3/13/25 is stricken. Notice mailed by Judge's staff

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Beth W. Jantz for the purpose of holding proceedings related to: discovery supervision; settlement conference. Notice mailed by Judge's staff.

FULL SATISFACTION of Judgment regarding order[62] in the amount of $150,000 as to certain defendants

MINUTE entry before the Honorable Beth W. Jantz: This case has been referred to Magistrate Judge Jantz for discovery supervision with the authority to set and extend deadlines and a settlement conference [65], [66]. The Court adopts the schedule set by the district judge [65], specifically: (1) Rule 26(a)(1) initial disclosures shall be served by April 11, 2025; (2) all fact discovery shall be completed by September 8, 2025; and (3) the parties shall file a joint status report regarding their proposed next steps within fourteen (14) days after the close of fact discovery. A telephonic status hearing is scheduled for 6/11/25 at 10:30 a.m. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. Mailed notice.

STIPULATION of Dismissal as to a Certain Defendant (Joint)

MINUTE entry before the Honorable Jorge L. Alonso: A stipulation to dismiss has been filed. This cased is dismissed with prejudice. Civil case terminated. Notice mailed by Judge's staff

MAILED trademark report with certified copy of minute order dated 3/20/25 to Patent Trademark Office, Alexandria VA

MINUTE entry before the Honorable Beth W. Jantz: In light of the dismissal of the case with prejudice 70, all matters related to the referral of this action are resolved. The June 11, 2025 status hearing before Judge Jantz is stricken. Referral terminated. Mailed notice.