2025-cv-01703

COMPLAINT filed by Zorro Productions, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-23101213.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Zorro Productions, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Zorro Productions, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Zorro Productions, Inc. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Zorro Productions, Inc. by John Wilson

MOTION by Plaintiff Zorro Productions, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Zorro Productions, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Zorro Productions, Inc.

Notice of Claims Involving Trademarks by Zorro Productions, Inc.

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

Order on Motion for TRO

Order on Motion for Leave to File Excess Pages

Order on Motion for Extension of Time

NEW PARTIES: Zezhong Optimum Trading Co., SLENDY, Masen-Shop, MAHAVIMOKSA, Luxdesc, HUANQIUTONG and Huan Direct added to case caption.

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file document under seal 7 is granted. Plaintiff's Schedule A, provisionally under seal pending order, is permitted to remain under seal. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: By 2/27/25, 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

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

Supplemental List by Zorro Productions, Inc.

MOTION by Plaintiff Zorro Productions, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Zorro Productions, Inc. for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Zorro Productions, Inc. in support of motion for temporary restraining order, 17

Declaration Gertz Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED EXHIBIT by Plaintiff Zorro Productions, Inc. Exhibit 2 Part 1 of Gertz Declaration regarding memorandum in support of motion, 18

SEALED EXHIBIT by Plaintiff Zorro Productions, Inc. Exhibit 2 Part 2 of Gertz Declaration regarding memorandum in support of motion, 18

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file excess pages 16 is granted. The motion for a temporary restraining order 17 is taken under advisement. By 4/16/25, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. Mailed notice

SEALED DOCUMENT by Plaintiff Zorro Productions, Inc. Supplemental Index

MINUTE entry before the Honorable John J. Tharp, Jr: Upon review of the supplemental index 22, the screenshots do not show a single 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.) If the brief contains new screenshots, those screenshots must be included in an updated version of the certification and index attached to Plaintiff's TRO motion. 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 Zorro Productions, Inc. against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Zorro Productions, Inc. Amended Schedule A

MOTION by Plaintiff Zorro Productions, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Zorro Productions, Inc. for temporary restraining order Plaintiff's Renewed Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Zorro Productions, Inc. in support of motion for temporary restraining order, 27

Declaration Gertz Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

ENTRY MADE IN ERROR

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, the plaintiff's renewed ex parte motion for TRO 27 is granted. Plaintiff's original ex part motion for TRO 17 is denied as moot. Plaintiff's motion to exceed page limitation 26 is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/23/2025. Mailed notice

SURETY BOND in the amount of $ 50,000.00 posted by Zorro Productions, Inc.

SUMMONS Issued (Court Participant) as to Defendant AngYi and all other Defendants identified in the Complaint

MOTION by Plaintiff Zorro Productions, Inc. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

ENTRY MADE IN ERROR. REMOVED FROM DOCKET

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's motion to extend the temporary restraining order 35 is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 5/5/2025. Mailed notice

NOTICE of Voluntary Dismissal by Zorro Productions, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Plaintiff Zorro Productions, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Certain Defendants

MEMORANDUM by Zorro Productions, Inc. in support of motion for preliminary injunction 40

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 40

SUMMONS Returned Executed by Zorro Productions, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 5/16/2025, answer due 6/6/2025.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 39, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 17, 18, 20, 24, 26, 28, 29, 31, 33, 34, 36, 37, 40, 41, 44, 45, and 49 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for preliminary injunction against certain defendants 40 is taken under advisement. Any objection or response is due before 5/23/2025. Upon review of the declaration of service, the Court directs the plaintiff, by 5/21/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 5/23/2025. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by William Benjamin Kalbac on behalf of Zorro Productions, Inc.

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction against certain defendants 40 is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 5/30/2025 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. 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

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 5/28/2025. Mailed notice

NOTICE of Voluntary Dismissal by Zorro Productions, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 32

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 49, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 32 is dismissed from this case. Mailed notice

ATTORNEY Appearance for Defendant IDOUU by Jianyin Liu

NOTICE of Voluntary Dismissal by Zorro Productions, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendant Luxdesc by Jianyin Liu

MOTION by Defendant Luxdesc for extension of time to file answer regarding summons returned executed, [43], complaint[1]

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 52, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 13, 22, and 23 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Luxdesc's motion for an extension of time to answer the complaint 54 is granted. The deadline to respond is now 6/29/2025. Mailed notice

ANSWER to amended complaint by Luxdesc

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff and defendant Luxdesc are directed to review the procedures for initial status reports, located at [https://www.ilnd.uscourts.gov/judge_display.php?LastName=Tharp+Jr.] and to submit an initial status report 7/7/2025. The report should include a proposed case management schedule reflecting any disputes between the parties as to the proposed schedule. Mailed notice

STATUS Report Joint Initial Status Report by Zorro Productions, Inc.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon review of the parties' joint status report 59, the Court adopts the parties' proposed case management schedule. The matter is referred to the assigned magistrate judge for all further discovery scheduling and supervision as well as any settlement conference the parties may jointly seek. All protective orders and confidentiality orders are included within this referral. Mailed notice

MOTION by Plaintiff Zorro Productions, Inc. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

MINUTE entry before the Honorable John J. Tharp, Jr:MPlaintiff's motion for entry of default and default judgment 62 is taken under advisement. Any objections or responses are due by 8/11/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 8/4/2025. 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, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by John Wilson on behalf of Zorro Productions, Inc.

ENTERED IN ERROR. Modified on 8/6/2025.

MINUTE entry before the Honorable John J. Tharp, Jr: Referred to Magistrate Judge Beth W. Jantz pursuant to Local Rule 72.1. Reasons for referral to conduct hearings and enter appropriate orders on the following pretrial motion/matter: discovery supervision, settlement conference and for all further discovery scheduling and supervision as well as any settlement conference the parties mayjointly seek.Mailed notice

(request for referral) (gmm)

NOTICE of Correction regarding text entry 67

MINUTE entry before the Honorable Beth W. Jantz: This case has been referred to Judge Jantz for "all further discovery scheduling and supervision as well as any settlement conference the parties may jointly seek. All protective orders and confidentiality orders are included within this referral." Dkt. 60. The parties report that only three Defendants remain in this case: Defendants No. 15 (HUANQIUTONG), No. 21 (Luxdesc), and No. 46 (Zezhong Optimum Trading Co.). See Dkt. 59 at 1. Defendant No. 21 (Luxdesc) has appeared in this action. The September 30, 2025 fact discovery deadline entered by the District Judge as to Defendant No. 21 (Luxdesc) stands. See Dkt. 60 (entering the proposed case management schedule at Dkt. 59). This Court vacates the expert discovery deadlines, which will be reset later, if necessary. Plaintiff and Defendant No. 21 (Luxdesc) shall appear for a status hearing on 8/28/25 at 3:15pm Central, to discuss the status of discovery and Plaintiff's request for a settlement conference. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. Members of the public and media will be able to call in to listen to this hearing. 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. Defendants No. 15 (HUANQIUTONG) and No. 46 (Zezhong Optimum Trading Co.) have not appeared in this action, and Plaintiff has moved for entry of default and default judgment against them. See Dkts. 62, 63, 64. Accordingly, the Court does not enter any discovery schedule as to those Defendants at this time. The Court will readdress such a schedule at the appropriate juncture, if necessary and appropriate. Mailed notice.

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 62 is granted. Enter default judgment order. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 8/13/2025. Mailed notice

MINUTE entry before the Honorable Beth W. Jantz: Telephonic Status hearing held on 8/28/25 and continued to 9/4/25 at 9:45 a.m. The parties provide an update on settlement positions. At the next status, Counsel should come prepared with theirs and their clients' availability to set a settlement conference date via video, and each client representative will be expected to reserve at least half a day for such a conference, if the parties cannot resolve the matter on their own. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. Members of the public and media will be able to call in to listen to this hearing. 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. Fact discovery will close as of 9/30/25. Mailed notice.

MINUTE entry before the Honorable Beth W. Jantz: Telephonic status hearing on settlement held on 9/4/25 and continued to 9/25/25 at 2:30 p.m. The parties report that a settlement has been reached as to all remaining Defendant(s). All discovery deadlines are stayed pending execution of this settlement. To join the hearing by phone, dial 1-650-479-3207 and enter access code 2308 182 1801. Entering an attendee code is not required. The status hearing will be cancelled, and no one need call in, if a stipulation to dismiss is filed with the District Judge prior to the hearing. Mailed notice.

STIPULATION of Dismissal Stipulation of Voluntary Dismissal with Prejudice

MINUTE entry before the Honorable Beth W. Jantz: The parties have filed a stipulation to dismiss 75, all matters relating to the referral being completed, the referral is closed and Magistrate Judge Beth W. Jantz is no longer on the case. Status hearing set for 9/25/25 is stricken. Mailed notice.

MINUTE entry before the Honorable John J. Tharp, Jr:Upon receipt of the parties' stipulation of dismissal 75 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii), this matter is concluded. All future dates and deadlines are stricken; all pending motions are denied as moot. Civil case terminated. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA