2025-cv-01625

COMPLAINT filed by Jonas Sebastian Jodicke; Filing fee $ 405, receipt number AILNDC-23091842.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Jonas Sebastian Jodicke Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Yanling Jiang

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Yi Bu

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Adam Grodman

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Christopher Romero

SEALED DOCUMENT by Plaintiff Jonas Sebastian Jodicke [Amended] Schedule A to Complaint 1 and Schedule A 2

MOTION by Plaintiff Jonas Sebastian Jodicke for leave to file under seal

MOTION by Plaintiff Jonas Sebastian Jodicke for leave to file excess pages

MEMORANDUM in Support of 15 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Jonas Sebastian Jodicke

(Exhibit 1, of Jonas Sebastian Jodicke's Declaration)

SEALED EXHIBIT by Plaintiff Jonas Sebastian Jodicke Sealed Exhibit 2, Declaration of Jonas Sebastian Jodicke regarding memorandum in support of motion, 16

(Exhibit 2)

MEMORANDUM by Jonas Sebastian Jodicke Establishing that Joinder is Proper

(Exhibit 1)

Presentment for Exparte Motion 15 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 13, motion for leave to file excess pages 14 before Honorable Edmond E. Chang on 2/26/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: The motion 14 for extra pages is granted. The motion 13 to seal is granted provisionally, given the goal of asset restraint. The TRO motion 15 and joinder issue are taken under advisement. 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., 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 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 joinder filing, R. 18, remains 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 joinder filing, R. 18, remains under advisement, so the tracking status hearing of 04/11/2025 is reset to 05/16/2025 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 advisement. The tracking status hearing of 05/16/2025 is reset to 06/20/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Mailed notice. (jn,)

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, R. 18, remains under advisement, so the tracking status hearing of 06/20/2025 is reset to 07/25/2025 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, given the unique similarities between the two Defendants, joinder is proper (at least absent adversarial presentation). The 26-word advertising text is exactly the same and, just as importantly, use unique (and sometimes bizarre) words to describe the product in an uncommon, non-grammatical sequence. Also, the proffered brand name is the same, as is the ASIN. (2.) In this copyright-infringement case, the Plaintiff's motion [15] for temporary restraining order and other relief is granted. An order will be entered under seal separately and will become effective when posted on the docket (which means that the 14-day clock does not start to run until posted). 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 Plaintiff's request for electronic service of process is granted. The Plaintiff's TRO extension motion, if appropriate, is due by 10/07/2025, and a status report is due on that date as well. The tracking status hearing of 10/10/2025 remains in place. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/29/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/29/2025. Emailed notice

Extension of Time

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the initial TRO, the motion for extension [35] is granted through 10/27/2025. The TRO remains in effect through that date. On review of the status report, R. 37, the tracking status hearing of 10/10/2025 is reset to 10/31/2025 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 a status report by 10/24/2025 and, if appropriate, the motion for preliminary injunction. Emailed notice