2025-cv-01296

COMPLAINT filed by Khara Inc. and Ground Works Co., Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-23053176.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Khara Inc. and Ground Works Co., Ltd. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Khara Inc. and Ground Works Co., Ltd. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Khara Inc. and Ground Works Co., Ltd. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Khara Inc. and Ground Works Co., Ltd. by John Wilson

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Khara Inc. and Ground Works Co., Ltd.

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Maria Valdez. 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.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. 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 Khara Inc. and Ground Works Co., Ltd. in support of motion for temporary restraining order, 13

Declaration Kamimura Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 1 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 2 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 3 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 4 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 5 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 6 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 7 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 8 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 9 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 10 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 11 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 12 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 13 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 14 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 15 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 16 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 17 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 18 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 19 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 20 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 21 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 22 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 23 of Kamimura Declaration

SEALED DOCUMENT by Plaintiff Khara Inc. and Ground Works Co., Ltd. Exhibit 2 Part 24 of Kamimura Declaration

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 7 ; motion to exceed page limitation 12 ; and motion for electronic service of process 39 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order (etc.) 13 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 2/27/2025 at 9:00 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO must be filed by 2/24/2025. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. In addition an insufficient interval between electronic service of summons and the preliminary injunction hearing may result in denial of a preliminary injunction due to inadequate notice of the lawsuit. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 2/13/2025.

ORDER: Signed by the Honorable Matthew F. Kennelly on 2/13/2025. Mailed notice.

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiffs' motion to extend the temporary restraining order 43 is granted; the ex parte TRO entered by the Court on 2/13/2025 is extended through 3/13/2025. The telephonic preliminary injunction hearing set for 2/27/2025 is vacated and reset to 3/13/2025 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction must be filed by 3/10/2025 and must be accompanied by a certificate stating upon whom and how the motion has been served. The Court also repeats its earlier admonition that an insufficient interval between electronic service of summons and the preliminary injunction hearing may result in denial of a preliminary injunction due to inadequate notice of the lawsuit.

SURETY BOND in the amount of $ 10,000.00 posted by Khara Inc. and Ground Works Co., Ltd.

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

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Khara Inc. and Ground Works Co., Ltd. in support of motion for preliminary injunction 48

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 48

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Khara Inc. and Ground Works Co., Ltd.

(Exhibit 1)

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic preliminary injunction hearing held on 3/13/2025. The previously entered temporary restraining order from 2/13/2025 is extended through 3/18/2025. The case is set for a telephonic preliminary injunction hearing on 3/18/2025 at 8:45 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

SUMMONS Returned Executed by Khara Inc. and Ground Works Co., Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 3/10/2025, answer due 3/31/2025.

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Khara Inc. and Ground Works Co., Ltd.

(Exhibit 1)

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic preliminary injunction hearing held on 3/18/2025. Plaintiff's motion for preliminary injunction 48 is granted. Enter preliminary injunction order. Plaintiff's counsel is directed to send a proposed preliminary injunction order to Judge Kennelly's proposed order email address. The case is set for a telephonic status hearing on 5/22/2025 at 8:55 a.m. Plaintiff is directed to file a joint status report by 5/15/2025. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

STATUS Report by Khara Inc. and Ground Works Co., Ltd.

MINUTE entry before the Honorable Matthew F. Kennelly: The Court has reviewed plaintiff's status report. The telephonic status hearing set for 5/22/2025 is vacated and reset to 6/11/2025 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. The deadline for filing any and all motions for default judgment is 5/20/2025.

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. for extension of time Plaintiffs' Unopposed Motion for an Extension of Time to File Their Motion for Default and Default Judgment

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiffs' motion for a one-day extension of time to file their motion for default judgment 59 is granted.

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Khara Inc. and Ground Works Co., Ltd.

MOTION by Plaintiff Khara Inc. and Ground Works Co., Ltd. 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 Khara Inc. and Ground Works Co., Ltd. in support of motion for default judgment, 62

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 62

(Exhibit Hierl Exhibit 1)

Supplemental Chart by Khara Inc. and Ground Works Co., Ltd.

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Khara Inc. and Ground Works Co., Ltd.

(Exhibit 1)

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for default judgment 62 is granted. Final Judgment Order to follow. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 5/22/2025. Mailed notice.

SATISFACTION of Judgment