2025-cv-00653

COMPLAINT filed by Anna Melis; Filing fee $ 405, receipt number AILNDC-22972433.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Anna Melis Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Anna Melis by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Anna Melis by Adam Grodman

ATTORNEY Appearance for Plaintiff Anna Melis by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Anna Melis by Christopher Romero

ATTORNEY Appearance for Plaintiff Anna Melis by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Anna Melis by Yanling Jiang

ATTORNEY Appearance for Plaintiff Anna Melis by Yi Bu

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. Please note that the table's requirements were revised on October 10, 2024. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. The submission must also provide a listing of all prior Schedule A cases filed in any court in the United States in which Plaintiff was a plaintiff, and a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Finally, by filing the template, Plaintiff certifies that Plaintiff has not used any of the screenshot evidence supplied in support of a motion for a TRO in this case in any prior proceeding. If the template is not completed by February 5, 2025, the Court may dismiss this matter for failure to prosecute. Mailed notice.

EXECUTIVE COMMITTEE ORDER: Case 24 CV 4372, Nava Romero et al v. Jaddou, is currently pending before the Hon. Sunil R. Harjani; and Case 25 CV 653, Anna Melis v. The Partnership and Unincorporated Associations Identified on Schedule A., is currently pending before the Hon. Lindsay C. Jenkins; and Judge Harjani and Judge Jenkins have agreed that 24 CV 4372, Nava Romero et al v. Jaddou, be reassigned to Judge Jenkins and 25 CV 653, Anna Melis v. The Partnerships and Unincorporated Associations Identified on Schedule A., be reassigned to Judge Harjani; therefore It is hereby ordered that 24 CV 4372, Nava Romero et al v. Jaddou, be reassigned to Judge Jenkins, and 25 CV 653, Anna Melis v. The Partnerships and Unincorporated Associations Identified on Schedule A., is to be reassigned to Judge Harjani pursuant to Internal Operating Procedure 13(d). Case reassigned to the Honorable Sunil R. Harjani for all further proceedings. Honorable Lindsay C. Jenkins no longer assigned to the case. Signed by Executive Committee on 01/27/2025.

[Amended] Schedule A to Complaint 1 and Schedule A 2 by Anna Melis

MEMORANDUM in Support of 14 Exparte Motion

Exhibit 1

Declaration of Keith A. Vogt

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

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's ex parte motion for leave to conduct expedited discovery and electronic service of process is granted as to Defendant No. 1 14. 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 defendant. Expedited discovery is warranted to identify the individuals or business entities who own and/or operate the e-commerce store under the seller alias, the nature of their operations, all associated sales, and the financial accounts used for their operations. By 3/13/2025, Plaintiff shall file a status report with an update on the case. Telephone status hearing is set for 3/20/2025 at 9:15 a.m. The call-in number is (855) 2448681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

ORDER FOR LEAVE TO CONDUCT EXPEDITED DISCOVERY AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION. Signed by the Honorable Sunil R. Harjani on 1/30/2025. Mailed notice

SUMMONS Returned Executed by Anna Melis as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/5/2025, answer due 2/26/2025.

(Declaration of Service)

MINUTE entry before the Honorable Sunil R. Harjani: Defendant's response to the complaint is due by 2/26/2025. Plaintiff should file any motion for entry of default and default judgment by 3/13/2025. If default and default judgment are not being sought, Plaintiff is ordered to file a status report advising whether the parties anticipate a settlement or further litigation. Otherwise, plaintiff need not file the status report due 3/13/2025 as directed by the Court's order dated 1/30/2025. Status hearing set for 3/20/2025 at 9:15 a.m. stands. Mailed notice

MOTION by Plaintiff Anna Melis for default judgment as to the Defendant Identified in [Amended] Schedule A

MEMORANDUM by Anna Melis in support of motion for default judgment 20

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

(Declaration of Anna Melis)

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is plaintiff's motion 20 for entry of default and default judgment against the defendant identified in [Amended] Schedule A. Defendant has 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. Any objection to the motion for entry of default judgment must be filed on or before 3/10/2025. If no objection is filed by that date, the Court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by 3/10/2025. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon defendant within one business day of its entry on the docket and must promptly file proof of that service. A tentative default judgment hearing is set for 3/18/2025 at 9:15 a.m. Telephone status hearing set for 3/20/2025 is stricken. Mailed notice

CERTIFICATE of Service by Plaintiff Anna Melis regarding terminate hearings, set/reset hearings, 22

MINUTE entry before the Honorable Sunil R. Harjani: Defendant has not responded to plaintiff's motion for entry of default judgment. Accordingly, the motion 20 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 copyright 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 defendant (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 $50,000 is an appropriate award of statutory damages. Plaintiff has also certified and established 23 that it provided electronic notice to defendant of the objection deadline, but no objection to the motion for entry of default judgment has been filed on behalf of defendant. Because no default judgment hearing has been requested, the default judgment hearing tentatively set for 3/18/2025 is stricken. Enter separate Final Default Judgment Order. Civil case terminated. Mailed notice

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Sunil R. Harjani on 3/11/2025. Mailed notice