2025-cv-00504

COMPLAINT filed by Those Characters from Cleveland, LLC; Filing fee $ 405, receipt number AILNDC-22960112.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Christopher Romero

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Those Characters from Cleveland, LLC

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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: LinGaoQiuFen, Xifabiao, Xin yu ying, Kasflag Pro Store, airu21, DOITIANS, NiceCloud, Shanxi Internet, WZSport, Xinliang my, AFTRYG, Anshu LDT, AOC ORGANIC VIETNAM COMPANY LIMITED, Cgtdvk, FENFGYU Co.Ltd, Godbay Co.Ltd, hecxina, heyali, JDEFEG Clothing, JINGXI, KUIYON, kuming, KunMingKuanYongShangMao, Longhang Co.ltd, Megabizz, meihuayang, Michellea, miehs, mIYEX, mnjdfregt, Moonlight Store, NaHanVN LTD, NEWPOWER, ngzhouyinhongshangmaoyo, niutiandianzi, Orangejuzi, orptlk, OuPin, pabo, PanSuYun, qike, Quseuen, Siqiy, standhustle, sunybea, SXDW, tanliruo, Three grass trade, TrendyGiftsShop, wanglianhonghongshui, Wangxiangcao, wbeb, WeiFangChunJianWang, XIAOCUI, XOQQiao, xzkw, Yanglrskjo, YHETTY, Yichaomaoyi, Yiqingling Trading Co, yuchengshangmao, YUHUO, YUYRY, Yuyuan Co.ltd, ZHAGHMIN Clothing, ZhangRui, zhangyuankeji, zhengtao and zhikaiweng added to case caption.

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file under seal

MOTION by Plaintiff Those Characters from Cleveland, LLC 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 Sean Gorman

Exhibit 1, of Sean Gorman's Declaration

(Exhibit 2, of Sean Gorman's Declaration)

SEALED EXHIBIT by Plaintiff Those Characters from Cleveland, LLC Sealed Exhibit 3, Declaration of Sean Gorman regarding memorandum in support of motion, 15

Exhibit 3-1

Exhibit 3-2

(Exhibit 3-3)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Motion for Leave to File under Seal 12, Motion to Exceed Page Limitation 13, and Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication 14 are granted. Enter sealed order. Telephonic hearing set for 1/29/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 1/17/2025. Emailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Those Characters from Cleveland, LLC

MOTION by Plaintiff Those Characters from Cleveland, LLC for extension of time of the Temporary Restraining Order

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs' Motion to Extend the Temporary Restraining Order ("TRO") 22 is granted. The TRO entered on 1/17/2025 21 is extended through 2/14/2025. Telephonic hearing set for 1/29/2025 is stricken and reset to 2/13/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

MINUTE entry before the Honorable Robert W. Gettleman: Due to a change in the court's schedule, telephonic hearing before this court set for 2/13/2025 is stricken and reset to 2/11/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

MOTION by Plaintiff Those Characters from Cleveland, LLC for preliminary injunction

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for preliminary injunction 26

Declaration of Keith A. Vogt

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

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/29/2025, answer due 2/19/2025.

(Declaration of Service)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 2/11/2025. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion for Entry of a Preliminary Injunction 26 is granted. Enter order. The Law Firms of JiangIP LLC and Keith Vogt, Ltd., are 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: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf The Clerk is directed to unseal Plaintiff's Schedule A to the Complaint 2, Exhibit 3 to the Declaration of Sean Gorman 16, and the TRO 21. Telephonic hearing set for 3/18/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 2/11/2025. Emailed notice

ATTORNEY Appearance for Defendant FENFGYU Co.Ltd by He Cheng

MOTION by Defendant FENFGYU Co.Ltd to dismiss for lack of jurisdiction

Exhibit Ex. 1 - Declaration of Dandan Chen

MINUTE entry before the Honorable Robert W. Gettleman: The court sets the following briefing schedule on Defendant's Motion to Dismiss Under Rule 12(b)(2) and Incorporated Memorandum of Law [32]: plaintiff's response due 3/6/2025; defendant's reply due 3/13/2025. The court will issue its ruling on CM/ECF. Emailed notice

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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 43 Siqiy

MOTION by Plaintiff Those Characters from Cleveland, LLC for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for default judgment[36]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

Motion by Those Characters from Cleveland, LLC and Incorporated Memorandum in Support to Stay Defendants Motion [32], and for Leave to Conduct Jurisdictional Discovery

Exhibit 1

ATTORNEY Appearance for Defendant NEWPOWER by Yong Chen

MOTION by Defendant NEWPOWER for extension of time to amend complaint[1]

MOTION by Defendant NEWPOWER for extension of time to file answer regarding complaint[1]

MOTION by Defendant NEWPOWER for extension of time to file answer regarding complaint[1], CONSENTED [UPDATED]

MINUTE entry before the Honorable Robert W. Gettleman: Defendant NEWPOWER's Updated, uncontested Motion for Extension of Time to answer or otherwise plead 42 is granted and the motions filed at 40 and 41 are denied as moot. Defendant NEWPOWER's responsive pleading due on or before 3/14/2025. Emailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 65 ZHAGHMIN Clothing

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 1 LinGaoQiuFen

STATUS Report JOINT STATUS REPORT by Those Characters from Cleveland, LLC

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 3/18/2025. Defendant FENFGYU did not appear on the hearing. Plaintiff's Motion to Stay Defendant's Motion 32 and for Leave to Conduct Jurisdictional Discovery 38 is granted. Telephonic status hearing set for 7/8/2025 at 9:15 a.m. The court will set a briefing schedule on Defendant FENFGYU Co., Ltd's Motion To Dismiss Under Rule 12(b)(2) 32 at the 7/8/2025 hearing. For the reasons stated on the record, Plaintiff's Motion For Entry Of Default And Default Judgment Against The Defendants Identified In First Amended Schedule A 36 is granted. Enter order. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

DEFAULT JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 3/18/2025. Emailed notice

MOTION by Defendant FENFGYU Co.Ltd to clarify

MINUTE entry before the Honorable Robert W. Gettleman: Defendant FENFGYU Co. Ltd's Motion To Clarify 49 is granted. The court's order entered on 3/18/2025 47 is modified to allow mutual jurisdictional discovery. Defendant and plaintiff are allowed to conduct limited jurisdictional discovery. Emailed notice

SATISFACTION of Judgment as to defendant no. 64 Yuyuan Co.ltd

STIPULATION of Dismissal JOINT Stipulation of Dismissal as to Defendant No. 15 FENFGYU Co.Ltd

MINUTE entry before the Honorable Robert W. Gettleman: On the parties' Joint Stipulation [52] and pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i) all claims against defendant No. 15 FENFGYU Co.Ltd are dismissed without prejudice. Defendant's Motion to dismiss [32] is stricken as moot. Telephonic status hearing set for 7/8/2025 is stricken. Civil case terminated. Emailed notice

MAILED trademark report with order dated 6/10/2025 to Patent Trademark Office, Alexandria VA

MAILED copyright report with order dated 6/10/2025 to Registrar, Washington DC

SATISFACTION of Judgment as to defendant no. 4 Kasflag Pro Store

NOTICE of Voluntary Dismissal by Those Characters from Cleveland, LLC as to Defendant No. 59 Yichaomaoyi

SATISFACTION of Judgment as to defendant no. 58 YHETTY