2025-cv-00434

COMPLAINT filed by Bug Art Limited; Filing fee $ 405, receipt number AILNDC-22954091.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Bug Art Limited Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bug Art Limited by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Bug Art Limited by Adam Grodman

ATTORNEY Appearance for Plaintiff Bug Art Limited by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Bug Art Limited by Christopher Romero

ATTORNEY Appearance for Plaintiff Bug Art Limited by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Bug Art Limited by Yanling Jiang

ATTORNEY Appearance for Plaintiff Bug Art Limited by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bug Art Limited

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 3).

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

SURETY BOND in the amount of $ 10,000 posted by Bug Art Limited (Document not Imaged)

NEW PARTIES: HENNIDE, FUALMSALS, ITWhalo, Qi Xian Cao Cheng Shang Mao You Xian Gong Si, KhRoimsP, CincMury, CHOKyUN, Hu Bei Tian Fen Fei Mao Yi You Xian Gong Si, JwAeraisx, Woohuyrz, Defendant No. 11, Black Friady of Deals 2024, mcdzsw, SSPDMBCURT, klaeiodf, Defendant No. 16, Hasuiu, nxyeol Warehouse Clearance, HiLeyJey, ALEBEE-Costume, YOOHOO Clothes, Hirdy, Betest, Qbily Co., Ltd, encolax, Fencomer, fuahas, Brewee, KACC BABY STORES, zhenmay-us, FSHYJUIFB, Heirloom Garden, holdridge, Leon3513, Ian Commercial Center, A2JN1M8VY7K8UF, lovemsy, Traverse City, SUMBERY, Sunny2018, BVUPL-US, KIPrints, TBRM ZKJ, Defendant No. 46, Rocket-Gid, Quinni Mall, foshanshichanchenquc and HongXianMuCai added to case caption.

NEW PARTIES: Defendant No. 43 added to case caption.

NEW PARTIES: HENNIDE, FUALMSALS, ITWhalo, Qi Xian Cao Cheng Shang Mao You Xian Gong Si, KhRoimsP, CincMury, CHOKyUN, Hu Bei Tian Fen Fei Mao Yi You Xian Gong Si, JwAeraisx, Woohuyrz, Defendant No. 11, Black Friady of Deals 2024, mcdzsw, SSPDMBCURT, klaeiodf, Defendant No. 16, Hasuiu, nxyeol Warehouse Clearance, HiLeyJey, ALEBEE-Costume, YOOHOO Clothes, Hirdy, Betest, Qbily Co., Ltd, encolax, Fencomer, fuahas, Brewee, KACC BABY STORES, zhenmay-us, FSHYJUIFB, Heirloom Garden, holdridge, Leon3513, Ian Commercial Center, A2JN1M8VY7K8UF, lovemsy, Traverse City, SUMBERY, Sunny2018, BVUPL-US, KIPrints, TBRM ZKJ, Defendant No. 46, Rocket-Gid, Quinni Mall, foshanshichanchenquc and HongXianMuCai added to case caption.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Bug Art Limited to Keith Vogt, Ltd. 33 West Jackson Boulevard Unit #2W Chicago, IL 60604 via certified mail # 9589 0710 5270 0579 7827 24.

SEALED DOCUMENT by Plaintiff Bug Art Limited [Amended] Schedule A to Complaint [1] and Schedule A [2]

MOTION by Plaintiff Bug Art Limited for leave to file under seal

MOTION by Plaintiff Bug Art Limited for leave to file excess pages

MEMORANDUM in Support of [15] Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Jane Crowther

Exhibit 1, of Jane Crowther's Declaration

SEALED EXHIBIT by Plaintiff Bug Art Limited Sealed Exhibit 2, Declaration of Jane Crowther regarding memorandum in support of motion, [16]

Exhibit 2-1

(Exhibit 2-2)

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal [13], motion for leave to file excess pages [14], and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and electronic service of process [15] are granted as to the defendants on Amended Schedule A. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and 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 effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 3/14/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice.

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 1/21/2025. Mailed notice

NOTICE of Correction

SURETY BOND in the amount of $ 10,000 posted by Bug Art Limited. (Document not imaged)

MOTION by Plaintiff Bug Art Limited for preliminary injunction

MEMORANDUM by Bug Art Limited in support of motion for preliminary injunction[23]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's Declaration

SUMMONS Returned Executed by Bug Art Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/29/2025, answer due 2/19/2025.

Declaration of Service

ATTORNEY Appearance for Defendant Ladily by Steven G Kalberg

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 23. In connection with that motion, plaintiff must serve all remaining defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by or before February 13, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's order entering the TRO, the TRO is extended to and including the date upon which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under Fed.R.Civ.P. 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice

CERTIFICATE of Service by Plaintiff Bug Art Limited regarding text entry, 27

MEMORANDUM by Ladily in Opposition to motion for preliminary injunction 23

Exhibit List

Declaration of Vivi Chow

Exhibit A Ladily Sales Data

(Exhibit B Screenshot of Ladily's Amazon.com Account Balance)

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

MOTION by Plaintiff Bug Art Limited for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by Bug Art Limited in support of motion for default judgment[31]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

ATTORNEY Appearance for Defendant Women Tops- 20243-5Days Delivery by Zhiwei Hua

MOTION by Defendant Women Tops- 20243-5Days Delivery for extension of time to file answer regarding summons returned executed 25

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff shall file a reply to defendant Ladily's (No. 42) opposition to the motion for preliminary injunction on or before 3/14/25. The Court will review the parties' submissions and will either issue a ruling by mail or set a hearing if appropriate. Defendant Women Tops' (No. 43) motion for extension of time to answer or otherwise plead 34 is granted. If plaintiff and defendant No. 43 do not resolve this matter through settlement, defendant No. 43 shall answer or otherwise plead and file any opposition to the motion for preliminary injunction by 3/14/25. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 23 is granted as to the defendants on Amended Schedule A EXCLUDING defendant No. 42, which has filed an opposition to the motion, and defendant No. 43, which has appeared and is engaged in settlement negotiations with plaintiff. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Jeffrey I Cummings on 2/28/2025. Mailed notice

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant no. 42 Ladily

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 31 for entry of default and default judgment against all defendants. The remaining defendants, EXCLUDING Nos. 42 and 43, have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure against the remaining defendants, excluding defendant Nos. 42 and 43. Any objections to the motion for entry of default judgment must be filed on or before 3/14/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. The 3/14/25 tracking status hearing is stricken and re-set to 4/25/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

CERTIFICATE of Service by Plaintiff Bug Art Limited regarding terminate deadlines and hearings, set deadlines/hearings, 39

MOTION by Defendant Women Tops- 20243-5Days Delivery for extension of time to file answer

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

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff has filed a notice of voluntary dismissal as to certain defendants 42, including defendant no. 43. Accordingly, defendant no. 43's motion for extension of time to answer 41 is terminated as moot. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: In light of the joint stipulation to dismiss filed by plaintiff and defendant no. 42, and the notice of voluntary dismissal as to defendant no. 43, the motion for preliminary injunction 23 (which remained pending solely as to defendant nos. 42 and 43) is terminated as moot. The Court will issue a ruling on plaintiff's motion for default as to the remaining defendants in due course. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: No remaining defendant has responded to plaintiff's motion for entry of default judgment. Accordingly, the motion [31] is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's copyrights irreparably harms plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $15,000 is an appropriate award of statutory damages. Enter Final Judgment Order. All pending deadlines and hearings are stricken. Civil case terminated. Mailed notice

DEFAULT FINAL JUDGMENT ORDER. Signed by the Honorable Jeffrey I Cummings on 4/7/2025. Mailed notice

MAILED copyright report with order dated 4/7/2025 to Registrar, Washington DC

ENTERED JUDGMENT Mailed notice

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7827 24. (Received by mail in the Clerk's Office on 5/29/2025)

SATISFACTION of Judgment as to defendant no. 30 zhenmay-us