2025-cv-01474

COMPLAINT filed by Those Characters from Cleveland, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23075674.

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

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

CASE ASSIGNED to the Honorable Elaine E. Bucklo. 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.

NEW PARTIES: Yangyang fashionable dress, ShuiJingZhiJia, Krzia, How big is the decoration, HappyHub, ZSIIBO Punctuality Store, ZSIIBO Official Store, ZSIIBO mimi Store, YBFSKID Official Store, Tksmama Store, The Last Emperor Store, Sunflower Lucky Store, Ss Baby Store, Shop911046103 Store, Shop5592539 Store, Shop5004325 Store, Shop1103621528 Store, Shop1103600090 Store, Shop1103040574 Store, Shop1102726398 Store, Shop1102421077 Store, Shop1102086285 Store, Shop1100248024 Store, SES8 Store, PLstar Cosmos Home Textile NO-4 Store Store, PAPYBAL Party Store, PAPYBAL Official Store, Luxe Lane Store, Kids Flying Store, Kids Birthday Photography Background Store, Hey Building Block Toys Store, HAI DE Accessories Store, Glitter Party Backdrop Store, GL Home Dec Store, GFUITRR Design Backdrop Store, Gelvshi KaiFa 1 Store, FUDANL Party Balloons Store, Fashionable And Elegant Home Textiles Store, Elegant WishShape Store, DOUBLE ROMANTIC PARTY Store, Custom Party Backdrop Store, CASUALKIDS Store, Boutique Home Textile Products Shop Store, Babaite Simple Case 308 Store, Arcane Kids Store, ALLFIN Store, Aesthetics Mouse Mat B143 Store, Home Goods Home Textile Boutique Store and DuDu Store added to case caption.

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

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for temporary restraining order, 12

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)

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

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

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 4 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, 12, motion for leave to file excess pages 11, motion to seal document 7 before Honorable Elaine E. Bucklo on 2/19/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 7 ; Plaintiff's motion to exceed limitation 11 ; and Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 12 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 4/18/2025 any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/11/2025. 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 of the expiration of the TRO. 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 The case is set for a status hearing on 4/28/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 4/21/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 3/4/2025. 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 25 before Honorable Elaine E. Bucklo on 3/18/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex-Parte motion to extend the temporary restraining order 25 is granted to 4/1/2025. Mailed notice.

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

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[30]

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction[30]

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction[30] before Honorable Elaine E. Bucklo on 3/28/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction against defendant Nos. 1-11 AND 13-50 30 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Plaintiff's Schedule A to the Complaint Dkt. No. 8, Exhibit 3 to the Declaration of Sean Gorman Dkt. Nos. [16-19] and the TRO Dkt. No. 23. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 3/26/2025. Mailed notice.

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 3/25/2025, answer due 4/15/2025.

NOTICE of Voluntary Dismissal by Those Characters from Cleveland, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 49

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff have failed to file a status report required by minute entry no. 22. Status hearing is reset for 6/10/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 6/3/2025, plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

CERTIFICATE of Service by John Wilson on behalf of Those Characters from Cleveland, LLC

MOTION by Plaintiff Those Characters from Cleveland, LLC 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 Those Characters from Cleveland, LLC in support of motion for default judgment, 40

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 40

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment, 40 before Honorable Elaine E. Bucklo on 5/8/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment against the defendants identified in Amended Schedule A 40 is reset for 6/10/2025. The court will issue a ruling by mail. Mailed notice.

ENTERED IN ERROR. Modified on 5/9/2025.

MINUTE entry before the Honorable Elaine E. Bucklo: Docket entry no. 45 is stricken as Entered in Error. A Notice of Correction to follow. Mailed notice.

NOTICE of Correction regarding docket entry no. 45.

NOTICE of Voluntary Dismissal by Those Characters from Cleveland, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 46

STATUS Report by Those Characters from Cleveland, LLC

MINUTE entry before the Honorable Elaine E. Bucklo: The status hearing and motion hearings set for today 6/10/2025 are stricken and reset to 6/13/2025 at 9:45 a.m. Mailed notice

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff's motion for entry of default and default judgment against the defendants identified in amended Schedule A 40 is granted. Enter Final Default Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) via certified mail to counsel of record for Plaintiff, 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 Elaine E. Bucklo on 8/5/2025. Mailed notice.