2025-cv-00725

COMPLAINT filed by Roblox Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-22979884.

Exhibit 1

(Exhibit 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Roblox Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Roblox Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Roblox Corporation by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Roblox Corporation by John Wilson

MOTION by Plaintiff Roblox Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Roblox Corporation Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Roblox Corporation

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff is put on notice that it may be required to file a memorandum discussing the propriety of joinder under Federal Rule of Civil Procedure 20(a)(2) if it appears that defendants are too numerous or unconnected. In addition, should default judgment enter against defendant(s), Plaintiff should be prepared to prove up damages by affidavit or hearing. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's motion for leave to file under seal 7 is stricken for failure to comply with LR 5.3 and this Court's standing orders, which require all motions to be noticed up for presentment before this Court. Mailed notice.

MOTION by Plaintiff Roblox Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

AMENDED complaint by Roblox Corporation against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

(Exhibit 2)

SEALED DOCUMENT by Plaintiff Roblox Corporation Amended Schedule A

MOTION by Plaintiff Roblox Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Roblox Corporation for temporary restraining order Plaintiff's 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

MEMORANDUM by Roblox Corporation in support of motion for temporary restraining order, 16

Declaration Bayley Declaration

Exhibit 1

Exhibit 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 3 to Bayley Declaration

Notice of Claims Involving Trademarks by Roblox Corporation

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 16, motion to seal document 12, motion for leave to file excess pages 15 before Honorable Sharon Johnson Coleman on 4/1/2025 at 10:00 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED Copyright report to Registrar, Washington DC (Main Document 23 replaced on 3/28/2025).

NOTICE of Correction regarding Copyright Report 23

DECLARATION of Luis Figueroa

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit A to Figueroa Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit B to Figueroa Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit C to Figueroa Declaration

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 4/1/2025. Plaintiff's renewed motion for leave to file under seal 12, motion to exceed page limitation 15, 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 16 are granted. Enter Order. An in-person status hearing is set for 4/15/2025 at 10:00 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 4/1/2025. Mailed notice.

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

MOTION by Plaintiff Roblox Corporation for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 34 before Honorable Sharon Johnson Coleman on 4/15/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 4/15/2025. Plaintiff's ex parte motion to extend the temporary restraining order 34 is granted. The Temporary Restraining Order is extended to April 29, 2025. An in-person status hearing is set for 4/29/2025 at 10:00 AM. Mailed notice.

SUMMONS Returned Executed by Roblox Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 4/16/2025, answer due 5/7/2025.

MOTION by Plaintiff Roblox Corporation for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

(Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 38 before Honorable Sharon Johnson Coleman on 4/29/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 4/29/2025. Plaintiff's ex parte motion to extend the temporary restraining order 38 is granted. The Temporary Restraining Order is extended to May 6, 2025. An in-person status hearing is set for 5/6/2025 at 10:00 AM. Mailed notice.

MOTION by Plaintiff Roblox Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Roblox Corporation in support of motion for preliminary injunction 41

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 41

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 41 before Honorable Sharon Johnson Coleman on 5/6/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 5/6/2025. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction 41 is granted. Enter Order. The Clerk of Court is directed to unseal Plaintiff's Amended Schedule A to the Amended Complaint 14, Exhibit to the Declaration of Christian Bayley 18, and the Temporary Restraining Order 30. An in-person status hearing is set for 6/6/2025 at 10:00 AM. Law Firm of Hughes Socol Piers Resnick & Dym, Ltd. is 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Sharon Johnson Coleman on 5/6/2025. Mailed notice.

NEW PARTIES: Shop1104155456 Store, Fashion Pioneer No.1 Store and Bag-o-Rama Store added to case caption.

MAILED Original Three Thousand Dollar ($3,000) surety bond posted by to Roblox Corporation to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602 via certified mail #9589 0710 5270 0579 7842 16

ATTORNEY Appearance for Plaintiff Roblox Corporation by Elizabeth Aubree Miller

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Roblox Corporation

MOTION by Plaintiff Roblox Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

(Exhibit A)

MEMORANDUM by Roblox Corporation in support of motion for default judgment 49

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 49

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment 49 before Honorable Sharon Johnson Coleman on 6/4/2025 at 10:00 AM.

Supplemental Exhibit by Roblox Corporation

ATTORNEY Appearance for Plaintiff Roblox Corporation by Elizabeth Aubree Miller

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 6/4/2025. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of default 49 is granted. Default is entered in favor of plaintiff and against the defendants identified on the Amended Schedule A. Plaintiff's motion for default judgment 49 is taken under advisement. Counsel is to provide the Court with a revised proposed order adjusting the damages amount to $50,000 per defendant. Once received, the Court will review the revised proposed order and enter if appropriate. Status hearing set for 6/6/2025 is stricken. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's motion for default judgment 49 is granted. Default judgment is entered in favor of plaintiff and against defendants identified on the Amended Schedule A. Enter Order. The three thousand dollar ($3,000) surety bond posted by Plaintiff is hereby released via certified mail to counsel of record for Plaintiff, Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Sharon Johnson Coleman on 6/4/2025. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 6/4/2025 to Patent Trademark Office, Alexandria VA

MAILED Copyright report with certified copy of minute order dated 6/4/2025 to Registrar, Washington DC