2025-cv-01547

COMPLAINT filed by Sony Interactive Entertainment LLC; Filing fee $ 405, receipt number AILNDC-23082561.

Exhibit 1

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Sony Interactive Entertainment LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sony Interactive Entertainment LLC

Notice of Claims Involving Trademarks by Sony Interactive Entertainment LLC

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Lucas Allen Peterson

CASE ASSIGNED to the Honorable Jorge L. Alonso. 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.

NEW PARTIES: zhenkuangkeji, suizhoushigeyakejiyouxiangongsi, TUAN SHOP VIP999, yanchengshichuangzhifeishangmaoyouxiangongsi, xianlingLiZhi, THINHFASHION STORE, Uwitstar, Shengzhimao, WDY002, zhuibaiJianGuo, VAMSII, yuyuyang, xianyouxianbangtouzhenliuxueyubaihuolinshouchaoshi, XHS Direct, Shenlior, Smarttoou Road, Tuo Ding, XuaNBINBIN, tttllzoovcvdss, zhenglinbin, shanxiyuhangnuantongyouxiangongsi, SZLG, Zlwneh, xieningrumumaoyi, Yumujo, RGEEK US, SephSmith, zhang ziwen, TALinas, rtwetof, Saif Island, StoreUSA97, SiYue Inc, shanxixiaochengzhichunwenhualvyoufazhanyouxiangongsi, Yanmis, ZhengKangLong, Visual Artwork, XAYANCH, XuanShao, QUOCTUAANAT, Zweiy, yingyudianzishangwuQQ, zoazr, TOPWELLB, HL New Arrival, WARMTALS, Zhuangshanshan, Yan Xiang Art local, ZDR ART, xueyihongdier, Tee Trendz, TONGYANXIAN, XXLLshop, XINLANYY, The Unique Stop, The Sun Iluminates The Future Shop, Time Shift a, SurpriseTee, Yunpinhui, XX Art Decoration, XIELIUYON, ZH cute hat, ZHI YAN CC, WJN Decor, Zhou Yi Art Decor, Zoooooe, yujian art, YYYSTEE, WMTEESO, XUANBF, W Money comes from the old shopkeeper, XingGangPi, YDSTP, ZIFAN ART local, Jianxin, shenyangshihaochengdianzishangwuyouxiangongsi, Mevidflor, asafafdsgs, Qiu Leisure clothing, jinancheyunlinkejizixun, shanghaizhongshushiye, LONGSHI Co.Ltd, Wonder Controller LLC, Hou YuLongWireless, Jiahe Electronics, LiZhiLong and LIDEHUIGGG added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Sony Interactive Entertainment LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Jack Schecter regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Exhibit 2 - Parts 1-2 regarding declaration[16]

MOTION by Plaintiff Sony Interactive Entertainment LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[18], motion for leave to file[3], motion for temporary restraining order[13] before Honorable Jorge L. Alonso on 2/20/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3], [13], [18] are granted. As such, the Court strikes the hearing for February 20, 2025. The Plaintiff's written submissions establish that if Defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating Plaintiff's interests in identifying Defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to Plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the Plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to Defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with Defendants. Expedited discovery is warranted to identify Defendants and implement the asset freeze. If any Defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The Court finds that security in the amount of $87,000, $1,000 per Defendant, is sufficient to secure the injunctive relief. Telephonic status hearing set for March 4, 2025, at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 2/19/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Sony Interactive Entertainment LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Sony Interactive Entertainment LLC

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

SURETY BOND in the amount of $ 87,000 posted by Sony Interactive Entertainment LLC (Document not scanned)

MOTION by Plaintiff Sony Interactive Entertainment LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Sony Interactive Entertainment LLC in support of extension of time[28]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[29]

NOTICE of Motion by Rachel S Miller for presentment of extension of time[28] before Honorable Jorge L. Alonso on 3/4/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order 28 is granted. The temporary restraining order is extended to 3/19/25. Motion hearing date of 3/4/25 is stricken. Telephonic status hearing previously set for 3/4/25 is stricken and reset to 3/19/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MOTION by Plaintiff Sony Interactive Entertainment LLC for preliminary injunction

Exhibit A

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for preliminary injunction[33]

Declaration of Rachel S. Miller

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction[33] before Honorable Jorge L. Alonso on 3/19/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Sony Interactive Entertainment LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/14/2025, answer due 4/4/2025.

Declaration of Lucas A. Peterson

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 4/17/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [33] is granted. Enter Preliminary Injunction Order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 3/19/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

ATTORNEY Appearance for Defendants Shenlior, Yanmis, Yumujo by Timothy Tiewei Wang

MOTION by Defendants Shenlior, Yanmis, Yumujo for extension of time to file answer regarding complaint[1] Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer[43] before Honorable Jorge L. Alonso on 4/15/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: Defendants' Unopposed Motion to extend deadline to answer or otherwise respond [43] is granted to 4/22/25. Motion hearing date of 4/15/25 is stricken. Telephonic status hearing previously set for 4/17/25 is stricken and reset to 4/30/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Defendant LONGSHI Co.Ltd by He Cheng

MOTION by Defendant LONGSHI Co.Ltd for extension of time to file answer regarding complaint[1]

NOTICE of Motion by He Cheng for presentment of motion for extension of time to file answer[48] before Honorable Jorge L. Alonso on 4/22/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: Defendant LONGSHI Co. Ltd's Unopposed Motion for extension of time to answer or otherwise respond to Plaintiff's complaint [48] is granted to 5/4/25. Motion hearing date of 4/22/25 is stricken. Telephonic status hearing previously set for 4/30/25 is stricken and reset to 5/8/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Jennifer Van Nacht

ATTORNEY Appearance for Defendant RGEEK US by Adam M. Berger

ATTORNEY Appearance for Defendant RGEEK US by Jianwei Du

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

ANSWER to Complaint by LONGSHI Co.Ltd

MOTION by Plaintiff Sony Interactive Entertainment LLC for entry of default, MOTION by Plaintiff Sony Interactive Entertainment LLC for default judgment as to all Defendants with the exception of a certain Defendant

Exhibit A

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for entry of default, motion for default judgment, [58]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[59]

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment, [58] before Honorable Jorge L. Alonso on 5/14/2025 at 09:30 AM.

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing previously set for 5/8/25 is stricken and reset to 5/14/25 at 9:30 a.m. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Kahlia Roe Halpern

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 5/29/25 at 9:30 a.m. The parties are directed to file a joint status report by 5/28/25. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants with the exception of Defendant No. 82 58 is granted. Enter Default Judgment Order. Defendant RGeek is given to 5/28/25 to respond. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 5/14/2025. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order[65] in the amount of $200,000 as to certain defendant

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to a certain Defendant

STATUS Report per 64 (Joint) by Sony Interactive Entertainment LLC

MINUTE entry before the Honorable Jorge L. Alonso: The Court is in receipt of the parties' joint status report 68. The status report indicates that RGEEK US is a remaining Defendant but it was previously dismissed from this case 67. Accordingly, the Court sets a fact discovery deadline for Plaintiff and LONGSHI Co.Ltd. of 7/15/25. Telephonic status hearing previously set for 5/29/25 is stricken and reset to 8/5/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Hannah Alexa Abes

MINUTE entry before the Honorable Jorge L. Alonso: The Court resets the telephonic status hearing previously set for 8/5/25 to 7/22/25 at 9:30 a.m. The parties shall submit a joint status report by 7/18/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

STATUS Report per [71] (Joint) by Sony Interactive Entertainment LLC

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Status hearing held. Plaintiff's Motion for summary judgment shall be filed by 8/22/25; Defendant's response shall be filed by 9/19/25; Plaintiff's reply shall be filed by 10/3/25. Notice mailed by Judge's staff

STIPULATION of Dismissal as to Defendant LONGSHI Co.Ltd (Joint)

MINUTE entry before the Honorable Jorge L. Alonso: A stipulation to dismiss has been filed. The remaining non-defaulted Defendant LONGSHI Co. Ltd is dismissed. Civil case terminated. Notice mailed by Judge's staff