2025-cv-00754

COMPLAINT filed by Mob Entertainment, Inc.; Filing fee $ 405, receipt number AILNDC-22983767.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Mob Entertainment, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mob Entertainment, Inc.

Notice of Claims Involving Trademarks by Mob Entertainment, Inc.

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Young B. Kim. 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: Changsha Fun Doers International Trade Co., Ltd., Dongguan Orui Toys & Gifts Co., Ltd., Fujian Kaopu Commodity Co., Ltd., Guangzhou Naisi Beauty Makeup Co., Ltd., Guangzhou Walk Technology Co.,LTD, Henan Yangteng Technology Co., Ltd., Jiangsu DHS Imp & Exp Co.,Ltd, Jinhua Chuang Xiang Lei Toys Co., Ltd., Nanjing Ruizheng Technology Co., Ltd., Qingdao Ever Fortune Industrial Co., Ltd., Shantou Chenghai He Ye Toys Firm, Shenzhen Handa Technology Co., Limited, Shenzhen Xingyi Toy Co., Ltd., Shenzhen Yihong Bo Electronic Technology Co.Ltd, Xian Cowrie Import And Export Trading Co., Ltd., Xiamen Rave Trading Co., Ltd., Yangzhou Chenze Toys And Gifts Co., Ltd., Yiwu Boyun E-Commerce Firm, Yiwu City Hapu E-Commerce Firm, Yiwu Ke Huan Trading Co., Ltd., Yiwu Leqi Toys Co., Limited, Yiwu Ruoque Trading Co.,ltd, Yiwu Weizhi Electronic Technology Co., Ltd., Yiwu Wopu Toy Co., Ltd., Yiwu Xirui Trade Co., Ltd., Zhejiang Veronica Toys Co., Ltd., Ebiccn, geinizhenshixing, GuangZhouChangJinBaiHuoShangHang, guchengxianxueyangshangmaoyouxiangongsi, hefeimengsishangmaoyouxiangongsi, Heluo.Zu, hgnv h dc, Jeshionthing, jinxianghonglibaihuoyouxiangongsi, khanhshopbv202, KKENZ, kulookuloo, Like Backpack-Us, muzhe shop, nanyangshilifushangmaoyouxiangongsi, prpr shop, saiwenfei, smilemore shop, wanglanshang, Yanglai, ZXDdd, cpqp, leadingwholesaler2, luckybaby2024, popular_district1, toptoywholesale, whiff, ylwdome, zqrzw8866, hshffw-8365, jinhaow, AFeng, Angel department store, Ashylly, changdeleiqierdianzishangwu, CHENWEIMING, ChuangXun, dapanji, FEIQINAG, Guosongsong123, haikoushihanjiedianzishangwu, HANFENGMEI, Huangpuhaiqin, Kunwukeji, KWOPSSA, LDKJ store, Phuong Tai Cloth LTD, Shenzhen Pingeyuan, xunizelai, yuedishipin and zhuhaiyujianerkejiyou added to case caption.

MAILED original eighty five thousand ($85,000) surety bond [24], posted by Justin R. Gaudio, Greer, Burns & Crain Ltd., 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7834 17.

MOTION by Plaintiff Mob Entertainment, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mob Entertainment, Inc. in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

DECLARATION of Zach Belanger regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Exhibit 4 Parts 1-2 regarding declaration 14

Exhibit 4-1

(Exhibit 4-2)

MOTION by Plaintiff Mob Entertainment, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mob Entertainment, Inc. in support of motion for miscellaneous relief 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11] is granted. Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [16] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/10/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mob Entertainment, Inc.

Registry Deposit Information Form by Mob Entertainment, Inc.

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

SURETY BOND in the amount of $85,000 posted by Mob Entertainment, Inc. (Document not scanned).

MOTION by Plaintiff Mob Entertainment, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mob Entertainment, Inc. in support of extension of time[25]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[26]

MINUTE entry before the Honorable Mary M. Rowland: Motion for extension of TRO 25 is granted. TRO extended to 4/7/25. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/20/2025. Mailed notice.

ATTORNEY Appearance for Defendant WEI KUN by Hua Chen

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain Defendants

MOTION by Plaintiff Mob Entertainment, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Mob Entertainment, Inc. in support of motion for preliminary injunction[32]

Declaration of Trevor C. Talhami

SUMMONS Returned Executed by Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/1/2025, answer due 4/22/2025.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for preliminary injunction [32] is due by 4/16/25. Status report from Plaintiff due by 4/23/25. Mailed notice.

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendants

ANSWER to Complaint by WEI KUN

STATUS Report Pursuant to [35] by Mob Entertainment, Inc.

Exhibit A

MOTION by Plaintiff Mob Entertainment, Inc. for entry of default, MOTION by Plaintiff Mob Entertainment, Inc. for default judgment as to all Defendants with the exception of a certain Defendant

(Exhibit A)

MEMORANDUM by Mob Entertainment, Inc. in support of motion for entry of default, motion for default judgment, 40

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 41

Exhibit 1

(Exhibit 2)

ATTORNEY Appearance for Defendant Joyjoin Tech by Adam Edward Urbanczyk

MOTION by Defendant Joyjoin Tech for extension of time UNOPPOSED

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [39]. Without objection, motion for preliminary injunction [32] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff 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. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for default [40] is due 5/15/25. Status report due 6/2/25. Defendant Joyjoin Tech's motion for extension of time to respond to the complaint [44] is granted. Joyjoin Tech to respond by May 20, 2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 4/30/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendants

MOTION by Defendant Joyjoin Tech for extension of time

MINUTE entry before the Honorable Mary M. Rowland: Joyjoin Tech's Motion for extension to respond to the complaint [49] is granted. Response due 6/10/25. Mailed notice.

STATUS Report Pursuant to [46] by Mob Entertainment, Inc.

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [51]. The motion for default judgment [40] is granted against the remaining defendants unopposed, except for defendants Joyjoin Tech (Def. No. 38) and Defendant WEI KUN (Def. No. 82). Enter Order. Status report due 6/23/25. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 6/3/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: The eighty-five thousand dollar ($85,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns, & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Mailed notice.

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendant

STATUS Report per [52] by Mob Entertainment, Inc.

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [56]. Negotiations continue as to the remaining defendant. Status report due 7/14/25. Mailed notice.

RETURN of U.S. Post Office Receipt, Article No. 9589 0710 5270 0579 7834 17. (Received via mail at the Clerk's Office on 6/30/2025)

STATUS Report Pursuant to [57] by Mob Entertainment, Inc.

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the status report 59. Plaintiff is to resolve the case with the remaining defendant or the two will need to begin actually litigating and engaging in discovery. Status report due in 4 weeks, 8/12/25. Mailed notice.

STATUS Report per [60] by Mob Entertainment, Inc.

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [61]. The matter as to Wei Kun has been resolved. Plaintiff failed to report on the matter as to Joyjoin Tech. Plaintiff is to file an updated status report regarding whether the matter is resolved as to Joyjoin Tech by 8/29/25. Mailed notice.

STATUS Report per [62] by Mob Entertainment, Inc.

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [63]. Plaintiff has settled with the only remaining defendant. Civil case terminated. Mailed notice.

STIPULATION of Dismissal as to a Certain Defendant