2025-cv-00409

COMPLAINT filed by Roblox Corporation; Filing fee $ 405, receipt number AILNDC-22950098.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED DOCUMENT by Plaintiff Roblox Corporation Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Roblox Corporation by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Roblox Corporation by Adam Grodman

ATTORNEY Appearance for Plaintiff Roblox Corporation by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Roblox Corporation by Christopher Romero

ATTORNEY Appearance for Plaintiff Roblox Corporation by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Roblox Corporation by Yanling Jiang

ATTORNEY Appearance for Plaintiff Roblox Corporation by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Roblox Corporation

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Sara L. Ellis: The initial telephonic status conference in this matter is set for 3/13/2025 at 1:30PM. The parties are directed to review the procedures and requirements for this conference on Judge Ellis' web site and to submit the required Initial Status Report by 3/6/2025. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice

MEMORANDUM in Support of 15 Exparte Motion

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

Declaration of Keith A. Vogt

(Exhibit 1-2, of Keith A. Vogt's Declaration)

Presentment for Exparte Motion 15 NOTICE of Motion by Keith A. Vogt for presentment of before Honorable Sara L. Ellis on 2/19/2025 at 09:45 AM.

Schedule A to Complaint 1 and Schedule A to Complaint 2 [PUBLIC VERSION] by Roblox Corporation

MINUTE entry before the Honorable Sara L. Ellis: Plaintiff filed this case against 97 defendants for infringing six trademarks and two copyrights registered to Plaintiff. Under Rule 20, a plaintiff may join multiple defendants in a single action if: (1) the claims against them are asserted with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences, and (2) a question of law or fact common to all defendants exists. Fed. R. Civ. P. 20(a)(2)(A)(B). In reviewing the complaint in this case, it does not appear that joinder is proper as to all Defendants. As the Court stated in Roadget Business Pte. Ltd. v. The Individuals, Corporations, Limited Liability Cos., Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, alleging that multiple defendants have infringed on the same copyright, trademark, or patent in the same way, without more, does not create the substantial evidentiary overlap required to find joinder proper. No. 23 C 17036, 2024 WL 1858592, at *67 (N.D. Ill. Apr. 29, 2024). The Court directs Plaintiff to file an amended complaint by 3/12/2025, as well as a statement on joinder explaining how the remaining Defendants comply with the Court's order in Roadget. The Court sets a status hearing for 3/19/2025 at 9:30 AM. The Court grants Plaintiff's motion for leave to conduct expedited discovery and electronic service of process 15. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice

Motion by Roblox Corporation for Clarification

Presentment for 20 Motion for Clarification NOTICE of Motion by Keith A. Vogt for presentment of before Honorable Sara L. Ellis on 3/4/2025 at 09:45 AM.

ORDER FOR LEAVE TO CONDUCT EXPEDITED DISCOVERY AND SERVICE BY E-MAIL AND/OR ELECTRONIC PUBLICATION. Signed by the Honorable Sara L. Ellis on 2/19/2025:Emailed notice

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

Notice by Roblox Corporation to Strike Presentment Date of March 4, 2025

SUMMONS Returned Executed by Roblox Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/3/2025, answer due 3/24/2025.

(Declaration of Service)

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for clarification 20 and strikes the presentment date of 3/4/2025. Mailed notice. (jn,)

MINUTE entry before the Honorable Sara L. Ellis: The Court strikes the status dates set for 3/13/2025 and 3/19/2025 and resets them to 4/2/2025 at 9:30 AM. The parties should file their initial joint status report by 3/28/2025. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 2 notsafeforwear

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

MEMORANDUM by Roblox Corporation in support of motion for default judgment 30

Exhibit 1

Exhibit 2

Declaration of Christian Bayley

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 30 before Honorable Sara L. Ellis on 4/2/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 34 GFsafasfvafv

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for default and for default judgment 30. The Court finds Defendants identified in Amended Schedule A in default. The Court enters judgment in favor of Plaintiff and against Defendants identified in Amended Schedule A. Case terminated. Emailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 4/2/2025:Emailed notice

MAILED trademark report with certified copy of minute order dated 4/2/25 to Patent Trademark Office, Alexandria VA

SATISFACTION of Judgment as to defendant no. 88 wuqin