2025-cv-00674

COMPLAINT filed by Sega Corporation, Sega of America, Inc.; Filing fee $ 405, receipt number AILNDC-22975122.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sega Corporation, Sega of America, Inc.

Notice of Claims Involving Trademarks by Sega Corporation, Sega of America, Inc.

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Alexander Whang

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

NEW PARTIES: linalinshop, QingSongShangMao, AE3HCAUXL, ANH VOO, chengduyihaojiajidianshebeiyouxiangongsi, China Commercial Department Store, ChiyuYue-Z, CONGLE, CUONGSHOP2003, Dang Dai US, DUCMANHSHOP842, fdhaeruhfdy, Feixi County Haonanren E-commerce Co., Ltd, GIANG GIA BAO, Guangzhoumianzaishangmaoyouxiangongsi, HangZhouXiaoNiuKuaiChongKeJiYouXianGongSi, haolong1122, Haoyi shop, HENLIU, HGDAIZHE, hong mmb, huangbin1231, jingmenshirousishangmao, jinzhiweidianzishangwu, JINZHIYI, KIMTRAMKIMTRAM, L MINH STORE, LingAnCL, litangshangmao, Liu-Xiang, Liwentong123, LNN International Wall Art Decoration, LouiseHoanGifts, mengchengxianchengchishangmaoyouxiangongsi, mufanshangmaozhongxin, nan Chen, NGUYENTHUTHAO1126, NuoSiLvXing, PZMpanzhiming, QuhuShop, QZM688, renao Lamps, RuiGeE, SEXYOOXX Global Official Flagship Store, shangbinbin1122, ShengDaS, shiyaruishangmaoyouxiangongsi, SHOU YUN STORE, Sichuan Sunrise Pass Trading Co., songxiaodong1122, SWGXLB, taner er, Thanh Sn store, The Lighting Emporium, tonghuachuangzhikejigongsi, TRAN MINH NGOC, uyk600, VinegarCo22, wanglinxia, Wangxiaola123, wangxinmin1122, WearNow Direct, WENLIANGEPU, whdfuwqhbfud, wumeidishenglun, xiangyangshijiashanyoushangmaoyouxiangongsi, XianYangYuXiangLinShengWuKeJiYouXianGongSi, XumaGifts, Yangshang, YINGBOGAO, yuexishangmao ltd, ZHANGHUIZHANGHUI, ZHANGZE00, zhouhexiaoweimaoyi, zhuoxunliyishangmao, ZLi112233., ZS-Juyi, zucaibaihuoshanghang, A2MVFQWNMUSG1C, A98QQETREU9BX, A3D1FV8ZHJHXEQ, mnjghhjg13, party-outlet, quarkology, zozoshop19, Ningboshuanghehulianwangkejiyouxiangongsi, Shenzhen Deruikai Technology, Anime Ape, Bobotemp, Brettwearshop, BrightRoomy, Brixtee Store, buffalobillsfanstore, Craftmasterslate, daisystees, designbycrocodile, Digitalprintcustom.com, dilyboutique, Dreamrooma, dresskiss, Fashionstoreaz, fashionveroshop, Global Cycling Gear, graphicteestore, Haillierowe, Hogateeca, Love My Family Forever., MAZESHIRT, minisgiftshop, Momiratee, PrimeSporty, Print7s, PRINTCUSTOMTEE, San Stores, Sansan Design, Shirtgenics, Shirtsafa, Shop4fans, Skullridding, Tee For Sports, TeeHex, Teetickler, trendingteestoday, Trendstees, UFamily Gift, Viralustee, WeStore24, WhoopeeParty, xonomax, YRL, ABGFK, ACPBTMZB, AEGFK, AJHYGTCC, An old iron painter, Artigiano Posters, Big Sue wall art, Blanket Hunter, blanket of home, BLY Art Prints, CHP Online, CoutureEdge, CupShopx, CYshoping, Dreams A Shop, EDZXC, Encounter You Shop, Fable Custom, FAQWE, GBOWE, good Andy, Graceful Cups, Ho Ho Art, Holeda, HUGmall, hweyp, HXS Art Decoration, HYzhang, ICFCV, IELTS Home Textiles, KLOMP PRINT, lanmei Poster, LCKOP, Lnatis hu, Lovely Top Shop, Oil painting lll, PTARA, QCUHB, Qster vvp, Rich and lucky, RREP, SOUNDBLACK, Three dahua, TMxiuaitwo, TRPP, UrbansVogue, Vogue Vanguard Shop, VTsai, Warm blanket, womeiK, youBlanket House, YOURAN Patch, Yoyo Good Shop, Z Art, ZBKVK, ZCKVK, ZDKVK and Zhainiu added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file certain documents under seal [3] is granted. Mailed notice.

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Entry of a Temporary Restraining Order Including a Temporary Injunction, and a Temporary Assest Restraint, as to Certain Defendants

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[11]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Exhibit 3, Parts 1-2 regarding declaration[13]

Exhibit 3, Part 1

(Exhibit 3, Part 2)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[15]

Declaration of Martin F. Trainor

Exhibit 1

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Expedited Discovery

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold and shipped at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Exhibit 1 regarding MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Expedited Discovery [17]

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order including a temporary injunction, and a temporary asset restraint, as to certain defendants [11] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [15] is granted. Motion for expedited discovery [17] is granted. Mailed notice.

ORDER. Signed by the Honorable Thomas M. Durkin on 2/7/2025. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 2/7/2025. Mailed notice.

INJUNCTION BOND in the amount of $ 93,000 posted by Sega Corporation, Sega of America, Inc. (Document not scanned).

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[24]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [24] is granted. The Temporary Restraining Order that went into effect on 2/7/2025 is extended by a period of fourteen (14) days until 3/7/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

SUMMONS Submitted (Court Participant) for defendant(s) THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE "A" by Plaintiffs Sega Corporation, Sega of America, Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships And Unincorporated Associations Identified On Schedule A

SUMMONS Returned Executed by Sega Corporation, Sega of America, Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 3/4/2025, answer due 3/25/2025.

Declaration of Sydney Fenton

Exhibit A

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for preliminary injunction[32]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [32] is set for 3/6/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 3/6/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [32] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Paul Varley [14], and the Temporary Restraining Order [22]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 4/21/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 3/6/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 4/21/2025. No one was present on behalf of defendants. A telephone status hearing is set for 6/4/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 6/4/2025. A telephone status hearing is set for 7/8/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for entry of default, MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, [52]

Exhibit 1

Exhibit 2

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[53]

Exhibit 2

EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Exhibit 1, Parts 1-11 regarding declaration[54]

Exhibit 1, Part 1

Exhibit 1, Part 2

Exhibit 1, Part 3

Exhibit 1, Part 4

Exhibit 1, Part 5

Exhibit 1, Part 6

Exhibit 1, Part 7

Exhibit 1, Part 8

Exhibit 1, Part 9

Exhibit 1, Part 10

Exhibit 1, Part 11

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 7/8/2025 is vacated. A telephone hearing as to the motion for entry of default and default judgment, [52] is set for 7/15/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 7/15/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and default judgment [52] is granted. Enter order. The ninety-three thousand dollar ($93,000) surety bond posted by Sega is hereby released to Sega or its counsel, TME Law, P.C. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Sega or its counsel. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 7/15/2025. Mailed notice.

FULL SATISFACTION of Judgment as to a certain defendant

CITATION to Discover Assets issued as to WhaleCo, Inc. d/b/a Temu (No Notice Filed) (Third Party).

CITATION to Discover Assets issued as to PayPal, Inc. (No Notice Filed) (Third Party).

CITATION to Discover Assets issued as to Amazon.com, Inc. (No Notice Filed) (Third Party).

CITATION to Discover Assets issued as to Stripe, Inc. (No Notice Filed) (Third Party).

CITATION to Discover Assets issued as to eBay, Inc. (No Notice Filed) (Third Party).

CITATION to Discover Assets issued as to Payoneer Global, Inc. (No Notice Filed) (Third Party).

ANSWER to citation as to PayPal, Inc.

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Entry of a Turnover Order Directed to Third Parties

Exhibit A

MINUTE entry before the Honorable Thomas M. Durkin: Motion for entry of a turnover order directed to third parties [67] is granted. Mailed notice.

ORDER signed by the Honorable Thomas M. Durkin on 10/7/2025. Mailed notice.