2025-cv-00673

COMPLAINT filed by Christine Sharon Arnall; Filing fee $ 405, receipt number AILNDC-22974356.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Christine Sharon Arnall Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Yanling Jiang

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Yi Bu

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Adam Grodman

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Christine Sharon Arnall by Christopher Romero

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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

NEW PARTIES: hourz, LXJ998855 and HaiDiShangMao89 added to case caption.

MAILED original three-thousand-dollar ($3,000) surety bond posted by Christine Sharon Arnall to Keith Vogt, Ltd. 33 West Jackson Boulevard Unit #2W Chicago, IL 60604 via certified mail # 9589 0710 5270 0579 7776 45.

MAILED original three-thousand-dollar ($3,000) surety bond posted by Christine Sharon Arnall to Keith Vogt, Ltd. 33 West Jackson Boulevard Unit #2W Chicago, IL 60604 via certified mail # 9589 0710 5270 0579 7776 45.

MAILED copyright report to Registrar, Washington DC.

MOTION by Plaintiff Christine Sharon Arnall for leave to file under seal

MOTION by Plaintiff Christine Sharon Arnall for leave to file excess pages

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion 15 for temporary restraining order and other relief is granted. An order will be entered under seal separately. Joinder is proper given the unique 16-word advertising text, which are exactly the same across the Defendants, in the same sequence, and otherwise not even grammatically correct. Moreover, the brand name and ASIN identification are the same across the Defendants. Separately, although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. § 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion 13 for leave to file under seal is granted in light of the asset-restraint goal. The redacted public version of the TRO will be posted. The Plaintiff's request for electronic service of process is granted for good cause given the absence of a reliable address. The motion 14 for extra pages is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 02/14/2025 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 02/07/2025. Emailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Edmond E. Chang on 1/31/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY Restraining Order signed by the Honorable Edmond E. Chang on 1/31/2025. Emailed notice

MOTION by Plaintiff Christine Sharon Arnall for preliminary injunction

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction 23 is granted. Given the answer deadline of 02/27/2025, R. 27, the tracking status hearing of 02/14/2025 is reset to 03/14/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). The joint initial status report is due by 03/05/2025. If the Defendants do not answer on time, then they are deemed in default, and the Plaintiff shall file the default-judgment motion by 03/05/2025 instead. Emailed notice

(Status Report Requirements)

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 02/10/2025. Emailed notice

MOTION by Plaintiff Christine Sharon Arnall for default judgment as to the Defendants Identified in the [Amended] Schedule A

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely response to the amended complaint, the motion for default judgment 30 is granted. Judgment entered in favor of the Plaintiff and against the Defendants in the amount of fifteen-thousand dollars ($15,000) from each Defendant, separately. Given the willfulness established by the default, a permanent injunction shall be entered. The status hearing of 03/14/2025 is vacated. Civil case terminated. Emailed notice

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 03/03/2025. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 03/03/2025. Emailed notice

MAILED copyright report with order dated 3/3/2025 to Registrar, Washington DC

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7776 45. (Received by mail in the Clerk's Office on 3/13/2025)