2025-cv-00146

COMPLAINT filed by TV Tokyo Corporation; Filing fee $ 405, receipt number AILNDC-22918994.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

EXHIBIT by Plaintiff TV Tokyo Corporation Schedule A to Complaint 1. Modified on 2/14/2025.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Keith A. Vogt

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Adam Grodman

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Christopher Romero

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Monica Rita Martin

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Yanling Jiang

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Yi Bu

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

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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: Bai Xuyang0229, DIGTIA, Drying, Feng Bobo, First day, GAOLONGCAI, Guangzhousichennanshangmaoshanghanggerenduzi, Guangzhouwangyuliangshangmaoshanghanggerenduzi, hongxiaus, House Of Fandom, huangzhendian, huimei888, InnovTools, lanzhoubangdedashangmaoyouxianzerengongsi, lixiaojuanfeisiyaxieye, Rattan Neon, Ravi Export2, The Fashion Jackets, VA StoreDN3, Wanil Store, xipengxindianzishangwuyouxiangongsi, zhangjiayinmaiwazi, zhengzhoushiganfeishangmaoyouxiangongsi and zhizhongmaoyi added to case caption.

NEW PARTIES: Alex Group, Beijiate Boutique, beijingqingyueshangmaoyouxiangongsi, beiyaxuanzhubao, Bekayaa, BINRONG HOME STORE and Cao Hua market added to case caption.

NEW PARTIES: Chanchengyunweishe, chang sha ying kai ke ji you xian gong si, chaobinshangmao, Chen Leisure clothing, CHENKEJI-182, Co Co Happy Store and Crazy Forever Toy added to case caption.

NEW PARTIES: Cuwyeasf, damaifangzhi, dongguanshiqiaoshengfushi, dongguanshixiaolinw, DUTA GLOBAL- Eastern-Print, ERUWIQUIEEQIOWRU, fengdaxinxijishu, Fly higher, foruided, foshanshiyuhengyankeji, fuhandao, fuxuanmaoyi, GHYBBAA, grtyuriuytt, guaiyingbian, guangzhoubaoruicanyinyouxiangongsi, guangzhouchenfashangmaoyouxiangongsi, guangzhouchenpomaoyi, GuangZhouHuiJiaShangMao05, guangzhoujinhekejiyouxiangongsi, guangzhoumaidashangmaoyouxiangongsi, guangzhoushiwankejiyouxiangongsi, guangzhoutangruanmaoyiyouxiangongsi, guangzhouzhenchengdianzishangwuyouxiangongsi, guchengxianquyanshangmaoyouxiangongsi, GUYONGWENHUA, Haikou XS Trading, HaiKouLiuJiQiShangMao, Haiyuebin, HANCHIFS, Hengjin Technology, Hesheng2023, hexindasu, House Of Fandom, huanrushangmao, HuiHongJia, huileishangmaoyouxiangongsi, huiyunengyuanguanli, HZDQ, IEnjoy Home, jiejiehongyunshangmao, jinanzhanweixinxikeji, jincheng8888, JINZHAOYOUJIU, jiujiangzhiguoguishangmaoyouxiangongsi, Koocovel, lalaxiaohumaoyi, Lanboya and lexiangdongguanshifushiyouxiangongsi added to case caption.

NEW PARTIES: LiBin, LiBinbm, liboshangmaa, LiheShen, liulishangmaoyouxiangongsi, LiuQiuTingShangMao, liweimaoyiyou, LKUK, Lucky trade, luhuarao21, LUILANC US, Megabizz, meidun, MingYuanDian, mingyuejiguang, Moonlight Store, ngwenganxia, NingZhiHaoShop, NovaGlobal, nuanshixinxikeji, Opspring, PAWPAW, pinqinfang, PQ EMBROIDERY COMPANY LIMITED, Puniama, Ranxin Bathing Supplies Store, ribinda, ruikangteyundongyongpin, Sanyuanguoji, SEATTY, shanghaizhongshushiye, shen zhen chao fan jie mao yi you xian gong si, shen zhen shi shen yun shu an ke ji you xian gong si, shenzhen zhenfengshangmao you xian gong si, shenzhenshihaojiyoujiankangkeji, ShopGlobal, TianJiaLeWireless, Tongda-US, Treenotthree, Vitdipy, vkjany, wang gang, wangwansendedian, weidalignxiu, WIQEOUIO, wuxifeisiyashangmaoyouxiangongsi, xianboliyangwangluokejiyouxiangongsi and XingFashion added to case caption.

NEW PARTIES: xingguangcai, XTCSDZSW, XTCYYX, Xu bee Toy store, yanchengjialvjiajuyongpinyouxiangongsi, Yaoqihuang trading co., ltd, YHZDZ, Yicheng XSKL NS, Yingfanfushi, yonglinyushangmao, Yuding trading co., ltd, Yuhaibing123, YunyangKJ, ZDSJ, Zhangdawn frock, Zhimeixing, zhipeng, zhongshengdinghang, Zunyishitengyiwenhuachuanmeiyouxiangongsi, Zxuyon, Defendant 4, Defendant 15 and Defendant 23 added to case caption.

MOTION by Plaintiff TV Tokyo Corporation for leave to file under seal

MOTION by Plaintiff TV Tokyo Corporation for leave to file excess pages

MEMORANDUM in Support of 14 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Hiroaki Saiki

Exhibit 1, of Hiroaki Saiki's Declaration

(Exhibit 2, of Hiroaki Saiki's Declaration)

DECLARATION of Hiroaki Saiki by Plaintiff TV Tokyo Corporation Sealed Exhibit 3, regarding memorandum in support of motion, 15. Modified on 2/14/2025.

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

Presentment for Exparte Motion 14 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 13, motion for leave to file 12 before Honorable Jorge L. Alonso on 1/14/2025 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 1/14/25 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: Plaintiff's ex parte motions 12 13 14 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 $158,000--$1,000 per defendantis sufficient to secure the injunctive relief. Telephonic Motion hearing set for 1/14/25 is stricken. Notice mailed by Judge's staff

TEMPORARY Restraining Order: Signed by the Honorable Jorge L. Alonso on 1/14/2025. Notice mailed by Judge's staff Modified on 2/14/2025.

Surety BOND in the amount of $ 158,000 posted by TV Tokyo Corporation. (Document not Imaged)

MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction

MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction 24

Declaration of Keith A. Vogt

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

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 24 before Honorable Jorge L. Alonso on 1/28/2025 at 09:30 AM.

SUMMONS Returned Executed by TV Tokyo Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/22/2025, answer due 2/12/2025.

(Declaration of Service)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 1/28/25 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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Motion hearing held. Plaintiff's Motion for preliminary injunction 24 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. Telephonic status hearing set for 2/27/25 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

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 1/28/2025. Notice mailed by Judge's staff

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

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment 32

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 32 before Honorable Jorge L. Alonso on 2/27/2025 at 09:30 AM.

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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 73 Hesheng2023

ATTORNEY Appearance for Defendants JINZHAOYOUJIU, ribinda, zhongshengdinghang by Adam Edward Urbanczyk

MOTION by Defendants JINZHAOYOUJIU, ribinda, zhongshengdinghang for extension of time UNOPPOSED

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time 38 before Honorable Jorge L. Alonso on 2/27/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 127 TianJiaLeWireless

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 3/26/25 at 9:30 a.m. The parties are directed to file a joint status report by 3/21/25. Defendants JINZHAOYOUJIU, ribinda, zhongshengdinghang's Unopposed Motion for extension of time 32 is granted to 3/18/25. Plaintiff's Motion for entry of default and default judgment against the Defendants identified in the first amended schedule A 32 is granted. Enter Default judgment order. 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

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 2/27/2025. Notice mailed by Judge's staff

SATISFACTION of Judgment as to defendant no. 101 LUILANC US and defendant no. 133 wangwansendedian

MOTION by Plaintiff TV Tokyo Corporation to approve consent judgment as to Defendant No. 85 JINZHAOYOUJIU

NOTICE of Motion by Keith A. Vogt for presentment of motion to approve consent judgment 44 before Honorable Jorge L. Alonso on 3/26/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 117 ribinda and defendant no. 156 zhongshengdinghang

MINUTE entry before the Honorable Jorge L. Alonso:The parties' Joint Motion for entry of consent judgment 44 is granted. Enter Consent Judgment. Motion hearing set for 3/26/25 is stricken. Notice mailed by Judge's staff

CONSENT Judgment. Signed by the Honorable Jorge L. Alonso on 3/26/2025. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: A notice of voluntary dismissal has been filed for the remaining Defendants. This case is dismissed. Status hearing previously set for 3/26/25 is stricken. Civil case terminated. Notice mailed by Judge's staff

MAILED trademark report to Patent Trademark Office, Alexandria VA.

SATISFACTION of Judgment as to defendant no. 85 JINZHAOYOUJIU and defendant no. 118 ruikangteyundongyongpin