2025-cv-01578

COMPLAINT filed by Khara Inc. and Ground Works Co., Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-23086319.

(Exhibit 1)

CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

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.

Notice of Claims Involving Trademarks by Khara Inc. and Ground Works Co., Ltd.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Trademark)

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, and Expedited Discovery

MEMORANDUM by Khara Inc. and Ground Works Co., Ltd. in support of motion for temporary restraining order, 14

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

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 John F. Kness: On the Court's initiative, all pending motions are held in abeyance, and the case is stayed pending further order. This stay, which the Court is entering in other so-called "Schedule A" cases on its docket where requests for temporary restraining orders remain pending, is intended to permit the Court the opportunity to reassess its previous approach in Schedule A litigation involving Lanham Act, Copyright Act, and Patent Act claims typically brought on an ex parte basis against various online merchants. This reassessment will consider, among other things, whether: (1) ex parte proceedings are appropriate in these types of cases; (2) the routine sealing of parts or all of the docket is appropriate; (3) the routine granting of temporary restraining orders on an ex parte basis is a sound exercise of judicial discretion; (4) the routine granting of prejudgment asset restraints is a sound exercise of judicial discretion; and (5) the mass joinder of defendants is appropriate under the circumstances typically present in Schedule A cases. Plaintiff remains free, of course, to dismiss this action voluntarily if they wish to pursue their claims in another District, but no supplemental briefing on the pending motions may be filed absent advance leave of Court. Mailed notice.

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for an ex parte temporary restraining order, prejudgment asset restraint, and expedited discovery (Dkt. 14) is denied substantially for the reasons provided in the opinion denying similar requested relief in Eicher Motors Limited v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, F. Supp. 3d, 2025 WL 2299593 (N.D. Ill. Aug. 8, 2025). Plaintiff's motion to seal (Dkt. 7) is granted subject to later reconsideration; the documents provisionally filed under seal may remain under seal for the time being. The request for alternative service (Dkt. 20) and motion for leave to file excess pages (Dkt. 13) are granted. An in-person status hearing is set for 8/26/2025 at 11:00 a.m.; lead counsel must appear in person at the hearing, which will be stricken if Plaintiff elects to dismiss this action voluntarily. Plaintiff is invited to file a motion seeking certification of an interlocutory appeal of this ruling. Mailed notice.

NOTICE of Voluntary Dismissal by Khara Inc. and Ground Works Co., Ltd. Plaintiff's Notice of Voluntary Dismissal Without Prejudice of All Remaining Defendants

MINUTE entry before the Honorable John F. Kness: Plaintiff has filed a notice of voluntary dismissal 23. Because the notice of dismissal was filed before the opposing parties served either an answer or a motion for summary judgment, the case is dismissed without prejudice consistent with the terms of the notice and by operation of Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure. See Nelson v. Napolitano, 657 F.3d 586, 587 (7th Cir. 2011) (Rule 41(a)(1)(A) notice of dismissal "is self-executing and effective without further action from the court"). Each party is to bear its own fees and costs. The hearing set for 8/26/2025 is stricken. Civil case terminated. Mailed notice. (jcc,)

MAILED trademark report with certified copy of minute order dated 8/25/25 to Patent Trademark Office, Alexandria VA.