2025-cv-01481

COMPLAINT filed by Laura Graves; Filing fee $ 405, receipt number AILNDC-23076476.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Laura Graves Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Laura Graves by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Laura Graves by Adam Grodman

ATTORNEY Appearance for Plaintiff Laura Graves by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Laura Graves by Christopher Romero

ATTORNEY Appearance for Plaintiff Laura Graves by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Laura Graves by Yanling Jiang

ATTORNEY Appearance for Plaintiff Laura Graves by Yi Bu

[Amended] Schedule A to Complaint 1 and Schedule A 2 by Laura Graves

MOTION by Plaintiff Laura Graves for leave to file under seal

MOTION by Plaintiff Laura Graves for leave to file excess pages

MEMORANDUM in Support of 14 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Laura Graves

(Exhibit 1, of Laura Graves' Declaration)

SEALED EXHIBIT by Plaintiff Laura Graves Sealed Exhibit 2, Declaration of Laura Graves regarding memorandum in support of motion, 15

(Exhibit 2)

Presentment for Exparte Motion 14 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 13, motion for leave to file 12 before Honorable Edmond E. Chang on 2/20/2025 at 08:30 AM.

MEMORANDUM by Laura Graves Establishing that Joinder is Proper

(Exhibit 1)

MINUTE entry before the Honorable Edmond E. Chang: The motion 12 file under seal is granted provisionally for now, given the goal of asset restraint. The motion 13 for extra pages is granted. The Court takes the TRO motion and joinder filing under consideration. To track the case only (no appearance is required, the case will not be called), a tracking status hearing is set for 03/07/2025 at 8:30 a.m. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder issue remains under consideration. The tracking status hearing of 03/07/2025 is reset to 03/21/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The filing on joinder, R. 18, is under advisement. The tracking status hearing of 03/21/2025 is reset to 04/11/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The filing on joinder, R. 18, remains under advisement. The tracking status hearing of 04/11/2025 is reset to 05/13/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's filing on joinder, R. 18, remains pending. The tracking status hearing of 05/13/2025 is reset to 06/06/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's filing on joinder, R. 18, remains pending. The tracking status hearing of 06/06/2025 is reset to 07/11/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

ATTORNEY Appearance for Defendants BINGESHANGMAO, Couture Line, DesignFlare, SewLovely, stitchmint, TheGiftedFit by Adam Edward Urbanczyk

NOTICE by BINGESHANGMAO, Couture Line, DesignFlare, SewLovely, TheGiftedFit, stitchmint re attorney appearance[25] withdrawal in error

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, R. 18, remains pending for consideration. The tracking status hearing of 07/11/2025 is reset to 08/15/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, R. 18, remains pending. The tracking status hearing of 08/15/2025 is reset to 09/12/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, R. 18, remains under consideration. The tracking status hearing of 09/12/2025 is reset to 10/10/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of the joinder filing, R. 18, the remaining two Defendants are sufficiently joined without the benefit of adversarial presentation. (2.) In this copyright-infringement case, the Plaintiff's motion [14] for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. § 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendants, who likely would seek to transfer the money elsewhere. The public redacted version of the TRO will be entered. The Plaintiff's request for electronic service of process is granted. The tracking status hearing of 10/10/2025 remains inplace. The Plaintiff shall file the TRO extension motion, if appropriate, no later than 10/03/2025, along with a status report. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/26/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/26/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) ganlifandian and all other Defendants identified in the Complaint by Plaintiff Laura Graves

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

SURETY BOND in the amount of $2,000.00 posted by Laura Graves (Document not scanned). (bi,)

MOTION by Plaintiff Laura Graves for extension of time of the Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time[36] before Honorable Edmond E. Chang on 10/10/2025 at 08:30 AM.

STATUS Report by Laura Graves

MOTION by Plaintiff Laura Graves for preliminary injunction

MEMORANDUM by Laura Graves in support of motion for preliminary injunction[39]

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction[39] before Honorable Edmond E. Chang on 10/10/2025 at 08:30 AM.

SUMMONS Returned Executed by Laura Graves as to All Defendants.

Declaration of Service, Keith A. Vogt

MINUTE entry before the Honorable Edmond E. Chang: The prior TRO motion [36] is terminated as superseded by the motion for preliminary injunction [39]. In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction [39] is granted. Given the answer deadline of 10/27/2025, R. 42, the tracking status hearing of 10/10/2025 is reset to 11/21/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 11/12/2025. If the Defendants do not answer on time, then they are deemed to be in default as of 10/28/2025, and the Plaintiff shall file a motion for default judgment by 11/12/2025. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 10/07/2025. Emailed notice

NEW PARTIES: ganlifandian and zhengqiufendianpu added to case caption. Terminating DesignFlare, SewLovely, TheGiftedFit, stitchmint, BINGESHANGMAO and Couture Line