2025-cv-01144

COMPLAINT filed by TV Tokyo Corporation; Filing fee $ 405, receipt number AILNDC-23036321.

Exhibit 1

Exhibit 2

Schedule A to Complaint [1] by TV Tokyo Corporation

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Keith A. Vogt

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Adam Grodman

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Christopher Romero

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Monica Rita Martin

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Yanling Jiang

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.

MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 02/28/2025 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the ***ATTACHED*** status report requirements (do ***not*** use templates from other cases) by 02/19/2025 Plaintiff must still file the report even if Defendants have not responded to requests to craft a joint report. If not all Defendants have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel (or the parties, if proceeding pro se) must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel (or the party, if proceeding pro se) must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

[Amended] Schedule A to Complaint [1] and Schedule A to Complaint [2] by TV Tokyo Corporation

MEMORANDUM in Support of [15] Exparte Motion

Exhibit 1

Declaration of Keith A. Vogt

Exhibit 1-2, of Keith A. Vogt's Declaration

Presentment for Exparte Motion [15] NOTICE of Motion by Keith A. Vogt for presentment of before Honorable Edmond E. Chang on 2/13/2025 at 08:30 AM.

MEMORANDUM by TV Tokyo Corporation Establishing that Joinder is Proper

Exhibit 1

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of joinder, R. 18, the Amended Schedule A Defendants appear to be properly joined given the use of the same advertising photos (at least four of the same on all sites, except one with two), and same Product details text along with unique capitalization, missing parenthesis, and missing words. (2.) The Plaintiff's motion [15] for expedited discovery and electronic service of process is granted for good cause. To track the case only (no appearance is required, the case will not be called), the status hearing set for 02/28/2025 is reset to 03/21/2025 at 8:30 a.m. Instead, the Plaintiff shall file the status report, R. 12-1, on 03/12/2025. Emailed notice

ORDER FOR LEAVE TO CONDUCT EXPEDITED DISCOVERY AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION Signed by the Honorable Edmond E. Chang on 02/10/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) laiersty and all other Defendants identified in the Complaint by Plaintiff TV Tokyo Corporation

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

SUMMONS Returned Executed by TV Tokyo Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/14/2025, answer due 3/7/2025.

Declaration of Service

MINUTE entry before the Honorable Edmond E. Chang: Given the return of service, any Defendant that has not answered by the 03/07/2025 deadline is deemed to be in default. Emailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 1 laiersty and defendant no. 2 MuiexsTnew

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment[26]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

Declaration of Hiroaki Saiki

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[26] before Honorable Edmond E. Chang on 3/18/2025 at 08:30 AM.

STATUS Report by TV Tokyo Corporation

MINUTE entry before the Honorable Edmond E. Chang: On review of the motion for default judgment, the Plaintiff shall file a supplement to the motion that cites where in the record the Court can find screenshots of the Defendants showing the infringing goods and their prices. If that information is not on the docket, then the supplement shall provide the evidence. The supplement is due by 03/18/2025. Emailed notice

SUPPLEMENT to text entry, [30], memorandum in support of motion[16] Sjupplemental Memorandum Pursuant to Minute Entry Order [30]

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely response to the amended complaint, the motion for default judgment [26] is granted. Judgment entered in favor of the Plaintiff and against the Defendants in the amount of fifteen-thousand dollars ($15,000) against each defendant. Giving the finding of willfulness established by the default, a permanent injunction is entered. A separate AO-450 judgment shall be entered. The status hearing of 03/21/2025 is vacated. Civil case terminated. Emailed notice

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 03/17/2025. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 03/17/2025. Emailed notice

MAILED Closing Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Minute Entry dated 3/17/2025)

SATISFACTION of Judgment as to defendant no. 6 SNOWKITTEN