2025-cv-01662

COMPLAINT filed by Hollywood Chamber of Commerce; Filing fee $ 405, receipt number AILNDC-23095784.

Exhibit 1

SEALED EXHIBIT by Plaintiff Hollywood Chamber of Commerce Schedule A regarding complaint[1]

MOTION by Plaintiff Hollywood Chamber of Commerce for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hollywood Chamber of Commerce

Notice of Claims Involving Trademarks by Hollywood Chamber of Commerce

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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: Yiwu Yifan Accessories Co., Ltd., A3CHY19FPN7MK2, AAT20O21LZP86, Artenrich, bobauna, BWWKTOP-US, Chengxiang Trading, EIXU, HopeMusicCHAO, HOWDOUDO, jealance, Mimiclub1993, NGZS and Orange You added to case caption.

SUMMONS - ERROR UNPROCESSED due to Case caption incorrect. Case caption on Summons form must match case caption on Amended Complaint.

MINUTE entry before the Honorable John J. Tharp, Jr: By 2/26/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file document under seal [3] is granted. Plaintiff's Schedule A, provisionally under seal pending order, is permitted to remain under seal. Mailed notice

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

RESPONSE by Plaintiff Hollywood Chamber of Commerce to text entry, 11

MOTION by Plaintiff Hollywood Chamber of Commerce for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for temporary restraining order 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

DECLARATION of Steve Nissen regarding memorandum in support of motion 17

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Hollywood Chamber of Commerce Exhibit 2 regarding declaration 19

(Exhibit 2)

MOTION by Plaintiff Hollywood Chamber of Commerce for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for miscellaneous relief 21

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 22

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motions for entry of a temporary restraining order [16] and electronic service of process [21] are taken under advisement. Upon review of Exhibit 2 to the plaintiff's declaration, [20] the screenshots do not show a common trademark that was allegedly infringed by each of the defendants listed in the plaintiff's Schedule A, raising a question as to the propriety of joinder. Plaintiff is directed to supplement the TRO motion with a brief explaining why joinder is proper notwithstanding the lack of a single trademark common to all defendants. (In other words, the brief should explain why joinder of claims of infringement of different trademarks is appropriate in this case.) Alternatively, the plaintiff may amend its complaint to include only defendants alleged to have violated the same trademark and file a renewed motion for entry of a TRO. Mailed notice

AMENDED complaint by Hollywood Chamber of Commerce against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

SEALED EXHIBIT by Plaintiff Hollywood Chamber of Commerce Amended Schedule A regarding amended complaint[25]

MOTION by Plaintiff Hollywood Chamber of Commerce for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery (Renewed)

SEALED EXHIBIT by Plaintiff Hollywood Chamber of Commerce Amended Exhibit 2 regarding declaration[19]

MINUTE entry before the Honorable John J. Tharp, Jr:In light of the amended complaint, 25 the plaintiff's initial motion for a temporary restraining order 16 is denied as moot. Mailed notice

ORDER Signed by the Honorable John J. Tharp, Jr on 2/27/2025. Mailed notice

NOTICE of Voluntary Dismissal by Hollywood Chamber of Commerce as to Certain Defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 31, defendant nos. 9-11, 15, 16, 18, 20, and 21 are dismissed without prejudice. Mailed notice

MOTION by Plaintiff Hollywood Chamber of Commerce for reconsideration regarding order[30]

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for reconsideration of the Court's denial of a TRO 33 is denied. The Court finds no "manifest error" of law or fact in its earlier decision that an insufficient likelihood of success existed to warrant injunctive relief. The defendants' products, with the notable exceptions of defendants 1 and 12, depict cartoon visual references to the Hollywood sign that, while admittedly mirroring the font of the plaintiff's mark, also mirror the physical Hollywood sign itself, a real-life landmark whose mere depiction definitively does not constitute infringement. Given the overall layout of the defendants' products, and specifically the fact that the Hollywood sign is but one small component among dozens of visual references to California, the Court finds it unlikely that consumers would be confused regarding the products' sponsorship or affiliation. A TRO remains unwarranted at this stage. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for electronic service of process [21] is granted. In light of the Court's denial of a TRO, see ECF nos. [30], [34], the Schedule A attached to the plaintiff's complaint [2] is hereby unsealed, and the plaintiff is directed to enter in CM/ECF no later than 4/4/25 each defendant named in the original Schedule A as a party in this case. Failure to timely comply with this requirement may result in dismissal. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

MOTION by Plaintiff Hollywood Chamber of Commerce for discovery Expedited

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff's motion for expedited discovery [36] is granted. Enter order. Mailed notice

ORDER Signed by the Honorable John J. Tharp, Jr on 4/7/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) YIWU YIFAN ACCESSORIES CO., LTD., et al., by Plaintiff Hollywood Chamber of Commerce

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Hollywood Chamber of Commerce

SUMMONS Issued (Court Participant) as to Defendant Yiwu Yifan Accessories Co., Ltd.

SUMMONS Returned Executed by Hollywood Chamber of Commerce as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/22/2025, answer due 5/13/2025.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

NOTICE of Voluntary Dismissal by Hollywood Chamber of Commerce as to certain Defendants

MOTION by Plaintiff Hollywood Chamber of Commerce for entry of default, MOTION by Plaintiff Hollywood Chamber of Commerce for default judgment as to all remaining Defendants

(Exhibit A)

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for entry of default, motion for default judgment, 44

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 45

(Exhibit 1)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 43, defendant nos. 5 and 6 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 44 is taken under advisement. Any objections or responses are due by 7/9/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 6/18/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, (2) send an email to all email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website, and (3) in each email include attached PDFs of the pending motion for default judgment, the supporting memorandum, this Minute Order, and the Court's Order denying the motion for a temporary restraining order 30. Mailed notice

CERTIFICATE of Service by Plaintiff Hollywood Chamber of Commerce regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 48

Exhibit A

(Exhibit B)(Faria De Souza, Luana)

NOTICE of Voluntary Dismissal by Hollywood Chamber of Commerce as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr:Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 50, defendant nos. 3, 4, 7, 8, 13, 14, 17, and 19 are dismissed from this case. Mailed notice

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Rachel Meira Ackerman

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 44 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/4/2025. Mailed notice

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff Hollywood Chamber of Commerce for reconsideration regarding order 54

(Exhibit A)

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for reconsideration 56 is granted. The previous default judgment award 53 54 is hereby stricken. ***Enter revised default judgment order.*** Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/8/2025. Mailed notice