2025-cv-00443

COMPLAINT filed by Mob Entertainment, Inc.; Filing fee $ 405, receipt number BILNDC-22955232.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Mob Entertainment, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mob Entertainment, Inc.

Notice of Claims Involving Trademarks by Mob Entertainment, Inc.

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Georgia N Alexakis. 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.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's motion for leave to file under seal [3] is granted. Upon review of the complaint, the Court sua sponte raises the propriety of joining 86 defendants and multiple trademark registrations in a single action. By 1/30/25, plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). Plaintiff's memorandum should also address this Court's order in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28, as well as others orders expressing similar joinder-related concerns in cases of this size, including but not limited to Zaful (Hong Kong) Limited v. The Partnerships, 24 CV 11111, Dkt. 12; Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27; Xie v. The Partnerships, 24 CV 9791, Dkt. 14; and Bailie v. The Partnerships, 24 CV 02150, 2024 WL 2209698 (N.D. Ill. May 15, 2024). In the alternative, plaintiff has leave to file an amended complaint and Amended Schedule A by 1/30/25 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to the others. Estee Lauder, 334 F.R.D. at 189.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Mob Entertainment, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Amended Schedule A regarding amended complaint[14]

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 3/24/25 at 9:30 a.m. in person in Courtroom 1719. By 3/17/25,the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report.

MOTION by Plaintiff Mob Entertainment, Inc. for discovery Expedited

MOTION by Plaintiff Mob Entertainment, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mob Entertainment, Inc. in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for discovery[17], motion for miscellaneous relief[18] before Honorable Georgia N Alexakis on 3/13/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's motions for expedited discovery and electronic service of process [17, 18] are granted. No appearance is required on 3/13/25. The Court finds that expedited discovery is warranted to identify defendants. The Court also finds that electronic service does not violate any treaty and is consistent with due process because it is an effective way to communicate with the online marketplace defendants. The Court decides these issues, however, without the benefit of adversarial presentation. If any defendant were to appear and object, the Court will take a fresh look at the issues of electronic service and expedited discovery as well as any issues related to personal jurisdiction. Enter Order.

ORDER Signed by the Honorable Georgia N Alexakis on 3/11/25.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mob Entertainment, Inc.

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

SUMMONS Returned Executed by Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/14/2025, answer due 4/4/2025.

Declaration of Trevor C. Talhami

(Exhibit A)

STATUS Report Pursuant to [16] by Mob Entertainment, Inc.

Exhibit A

MINUTE entry before the Honorable Georgia N Alexakis: The Court has reviewed plaintiff's status report 27. Plaintiff's next status report is due by 4/18/25, unless a motion for entry of default and default judgment is filed by that date.

MINUTE entry before the Honorable Georgia N Alexakis: In light of the anticipated motion by plaintiff for entry of default and default judgment, the Court vacates the initial status hearing set for 3/24/25 at 9:30 a.m. 16.

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to Defendant c2vt

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal per Federal Rules of Civil Procedure 41(a)(1), Defendant c2vt is voluntarily dismissed. Civil case terminated.