2025-cv-00969

COMPLAINT filed by Those Characters from Cleveland, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23016726.

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by John Wilson

MOTION by Plaintiff Those Characters from Cleveland, LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Those Characters from Cleveland, LLC

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

Registration Number(s) Part 1

(Registration Number(s) Part 2)

CASE ASSIGNED to the Honorable Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable M. David Weisman. 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: Zhejiang Youmi Baby Products Co., Ltd., Zhejiang Fantong Trading Co., Ltd., Yunnan Minglun Import And Export Co., Ltd., Yiwu Zhongkai Trading Co., Ltd., Yiwu Youyi Trading Co., Ltd., Yiwu Seaside Trading Co., Ltd., Yiwu Mingchi Toys Co., Ltd, Yiwu Mengxuan Trading Co., Ltd., Yiwu Lihong E-Commerce Co., Ltd., Yiwu Aifei Toy Factory, Yangzhou Shanhai Gift Co., Ltd., Yangzhou Page Toys Co., Ltd., Yangzhou Meiya Meiya Toys And Gifts Co., Ltd., Xi 'an Beilin District China E-Commerce Firm (individual Business), Wuhan Wuchang Canada Electronic Business Firm, Wuhan Baijia Shirui Trading Co., Ltd., Shenzhen Yuxun Technology Co., Ltd., Shenzhen Youweiyoupin Tech Co., Ltd., Shenzhen Xingman Industry Co., Ltd., Shenzhen Tulanduo Technology Co., Ltd., Shenzhen Shine Technology Co., Ltd., Shenzhen Shenman Technology Co., Ltd., Shenzhen Lanbowan Technology Co., Ltd., Shenzhen Fengli International Trade Limited., Shenzhen Dingchengxinrong Technology Company Limited, Shenzhen Beisike Technology Co., Ltd., Shantou Ever Prosperous Trading Co., Ltd., Quanzhou Taiya Trading Co., Ltd., Qingdao Hangyuhua Gift Co., Ltd., Guangzhou Shangxinsheng Gift Co., Ltd., SHUOLI Store, Shop5708075 Store, Shop1102651298 Store, Shiny-mi Store, Plush Toy Store, Magic Toy Planet Store, Lily foreign trade commodity store, KAYOU Anime Series Card Store Store, Heartbeat Plush Store, Disney Choice Store, 555 Cute Pony Store, Zhengzhou Daosen Digital Life Technology Co., Ltd., Shenzhen Jiumai E-Commerce Co., Ltd. and Nanping Yanping District Lufa Trading Co., Ltd. added to case caption.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Those Characters from Cleveland, LLC to John Wilson Hughes Socol Piers Resnick & Dym, Ltd. 70 W Madison St Ste 4000 Chicago, IL 60602 via certified mail #9589 0710 5270 0579 7779 59.

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.

AMENDED complaint by Those Characters from Cleveland, LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Amended Schedule A

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Those Characters from Cleveland, LLC 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 Those Characters from Cleveland, LLC in support of motion for temporary restraining order, 17

Declaration Gorman Declaration

Exhibit 1

Exhibit 2 Part 1

Exhibit 2 Part 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 1 of Gorman Declaration

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 2 of Gorman Declaration

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 3 of Gorman Declaration

Notice of Claims Involving Trademarks by Those Characters from Cleveland, LLC

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 17, motion to seal document 7, motion for leave to file excess pages 16 before Honorable Sharon Johnson Coleman on 2/11/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Due to the Court's trial calendar, presentment of plaintiff's motion for leave to file under seal 7, motion to exceed page limitation 16, and ex parte motion for entry of a temporary restraining order, including a temporary asset restraint, expedited discovery and service of process by email and/or electronic publication 17 set for 2/11/2025 at 10:00 AM is reset to 8:45 AM (NOTE TIME CHANGE ONLY) as an in-person hearing. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 2/11/2025. Plaintiff's motion for leave to file under seal 7, motion to exceed page limitation 16, 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 17 are granted. Enter Order. An in-person status hearing is set for 2/25/2025 at 10:00 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 2/11/2025. Mailed notice.

MOTION by Plaintiff Those Characters from Cleveland, LLC 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 27 before Honorable Sharon Johnson Coleman on 2/26/2025 at 10:00 AM.

SURETY BOND in the amount of $ 10,000.00 posted by Those Characters from Cleveland, LLC

MINUTE entry before the Honorable Sharon Johnson Coleman: The in-person status hearing set for 2/25/2025 is stricken and reset to 2/26/2025 at 10:00 AM, which is the same time as the presentment of plaintiff's ex parte motion to extend the temporary restraining order 27. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 2/26/2025. Plaintiff's ex parte motion to extend the temporary restraining order 27 is granted. The Temporary Restraining Order is extended to March 12, 2025. An in-person status hearing is set for 3/12/2025 at 10:00 AM. Mailed notice.

MOTION by Plaintiff Those Characters from Cleveland, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for preliminary injunction 33

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 33

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 33 before Honorable Sharon Johnson Coleman on 3/12/2025 at 10:00 AM.

MOTION by Plaintiff Those Characters from Cleveland, LLC for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

(Exhibit B)

SEALED EXHIBIT by Plaintiff Those Characters from Cleveland, LLC Exhibit A regarding MOTION by Plaintiff Those Characters from Cleveland, LLC for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order 37

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 37 before Honorable Sharon Johnson Coleman on 3/12/2025 at 10:00 AM.

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

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 3/12/2025. Defendants did not appear nor contact the Court. Plaintiff's ex parte motion to extend the temporary restraining order [37] is withdrawn. Plaintiff's motion for entry of preliminary injunction [33] is entered and continued. Mailed notice.

MOTION by Plaintiff Those Characters from Cleveland, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Nunc Pro Tunc to March 12, 2025 Against Defendant Nos. 233, 235, 236, 238, 240, 242, 243, 244, and 246

MEMORANDUM by Those Characters from Cleveland, LLC 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 3/19/2025 at 10:00 AM.

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 3/7/2025, answer due 3/28/2025.

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 3/13/2025, answer due 4/3/2025.

AFFIDAVIT of John Wilson

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit A to Affidavit of John Wilson

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit B to Affidavit of John Wilson

AFFIDAVIT of John Wilson

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 3/19/2025. Defendants did not appear nor contact the Court. Plaintiff's motions for entry of a preliminary injunction 33 and 41 are granted. Enter Order. The Clerk of Court is directed to unseal Plaintiff's Amended Schedule A to the Amended Complaint 15, Exhibit 3 to the Declaration of Sean Gorman [19, 20, 21], and the Temporary Restraining Order 26. 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 3/19/2025. Mailed notice.

MOTION by Plaintiff Those Characters from Cleveland, LLC for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

(Exhibit A)

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for default judgment, 54

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 54

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment, 54 before Honorable Sharon Johnson Coleman on 4/22/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Due to the Court's trial schedule, presentment of plaintiff's motion for entry of default and default judgment against the defendants identified in Amended Schedule A 54 set for 4/22/2025 at 10:00 AM is reset to 8:45 AM (NOTE TIME CHANGE ONLY). Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Due to the Court's trial schedule, presentment of plaintiff's motion for entry of default and default judgment against the defendants identified in Amended Schedule A 54 set for 4/22/2025 at 8:45 AM is reset to 4/29/2025 at 10:00 AM. At least three business days prior to the hearing, Plaintiff must file a supplement to its motion 54 to comply with the default judgment requirements for Schedule A cases as outlined in the Court's standing order. Mailed notice.

AFFIDAVIT of John Wilson

(Exhibit A)

NOTICE of Voluntary Dismissal by Those Characters from Cleveland, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 24

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to Defendant Kidz Party Store only. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 4/29/2025. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of default and default judgment against the defendants identified in Amended Schedule A 54 is granted. Default judgment is entered in favor of the plaintiffs and against the remaining defendants identified in the Amended Schedule A. Enter Order. The ten thousand dollar ($10,000) surety bond posted by Plaintiff is hereby released to counsel of record for Plaintiff via first class mail, 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 4/29/2025. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 4/29/2025 to Patent Trademark Office, Alexandria VA

SATISFACTION of Judgment