2025-cv-01109

COMPLAINT filed by Chapter 4 Corp.; Filing fee $ 405, receipt number AILNDC-23032288.

Exhibit 1

SEALED EXHIBIT by Plaintiff Chapter 4 Corp. Schedule A regarding complaint[1]

MOTION by Plaintiff Chapter 4 Corp. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chapter 4 Corp.

Notice of Claims Involving Trademarks by Chapter 4 Corp.

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Luana Faria De Souza (Faria De Souza, Luana)

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.

CASE ASSIGNED to the Honorable Steven C. Seeger. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2).

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MINUTE entry before the Honorable Steven C. Seeger: An initial status report is due by April 21, 2025. Counsel must read the Standing Order entitled "Initial Status Conferences and Joint Initial Status Reports" on the Court's website. The parties must confer as required by Rule 26(f) about the nature, scope, and duration of discovery. The parties must submit two documents to the Court. First, the parties must file the Joint Initial Status Report under Rule 26(f) on the docket. A Word version of the Joint Initial Status Report is available on the Court's website. All parties must participate in the preparation and filing of the Joint Initial Status Report. The Court requires a joint report, so a filing by one side or the other is not sufficient. Second, the parties must email a Word version of a proposed Scheduling Order under Rule 16(b) to the Court's proposed order inbox. Lead counsel for the parties must participate in filing the initial status report. Plaintiff must serve this Order on all other parties. If the defendant has not been served with process, plaintiff's counsel must contact the Courtroom Deputy at jessica_j_ramos@ilnd.uscourts.gov to reschedule the initial status report deadline. Plaintiff should not file the Joint Initial Status Report before the defendant(s) has been served with process. The parties must discuss settlement in good faith and make a serious attempt to resolve this case amicably. All counsel of record must read and comply with this Court's Standing Orders on its webpage. Please pay special attention to the Standing Orders about Depositions and Discovery. Mailed notice.

AMENDED complaint by Chapter 4 Corp. against 8576wpsfas and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

(Exhibit 2)

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Yu Hin Jeffrey Tsai (Tsai, Yu Hin)

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. 3) is hereby denied for the reasons stated by the Court in Zorro Productions, Inc. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (23-cv-5761). Mailed notice.

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Thomas Joseph Juettner

MOTION by Plaintiff Chapter 4 Corp. for discovery Expedited

MOTION by Plaintiff Chapter 4 Corp. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Chapter 4 Corp. in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

MINUTE entry before the Honorable Steven C. Seeger: At the plaintiff's request, the deadline to file a joint initial status report is extended to June 10, 2025. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to conduct expedited discovery (Dckt. No. 19) is hereby granted. Plaintiff's motion for electronic service of process (Dckt. No. 20) is hereby granted. Order to follow. Mailed notice

ORDER GRANTING EXPEDITED THIRD-PARTY DISCOVERY AND ELECTRONIC SERVICE OF PROCESS Signed by the Honorable Steven C. Seeger on 4/25/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) 8576wpsfas by Plaintiff Chapter 4 Corp.

SUMMONS Issued (Court Participant) as to Defendant 8576wpsfas

MINUTE entry before the Honorable Steven C. Seeger: On April 25, 2025, the Court granted Plaintiff's motion for expedited third-party discovery and electronic service of process (Dckt. No. 25). The Court permitted third parties 14 days to respond to discovery requests. Plaintiff had an obligation to serve those requests in a timely manner. Plaintiff must file a status report by May 9, 2025. Plaintiff must serve process by May 16, 2025. The Court expects Plaintiff to keep this case moving along. The Court directs the parties to engage in meaningful, good faith settlement discussions at the earliest opportunity. A failure to comply will lead to appropriate relief, including dismissal. Mailed notice

SUMMONS Returned Executed by Chapter 4 Corp. as to 8576wpsfas on 5/8/2025, answer due 5/29/2025.

Declaration Thomas J. Juettner

Exhibit A

STATUS Report Pursuant to 28 by Chapter 4 Corp.

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the status report. (Dckt. No. [30]) The answer is due by May 29, 2025. If Defendant misses the deadline, then Plaintiff must file a motion for the entry of default within two business days. A response is due two week later. A failure to comply will lead to appropriate relief, including dismissal or the entry of judgment. The Court directs the parties to engage in good faith, energetic settlement discussions. Plaintiff must press the case forward in a diligent manner, with a sense of purpose. Plaintiff must serve a copy of this order and file a certificate of service. Mailed notice

CERTIFICATE of Service by Plaintiff Chapter 4 Corp. regarding text entry, 31

(Exhibit A)

NOTICE of Voluntary Dismissal by Chapter 4 Corp. as to Defendant 8576wpsfas

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the notice of voluntary dismissal (Dckt. No. [33]), which is self-effectuating under Rule 41(a)(1)(A)(i). The complaint is dismissed without prejudice. The case is closed. Civil case terminated. Mailed notice.

MAILED final trademark report with a copy of minute entry 34 to Patent Trademark Office, Alexandria VA