2025-cv-01785

COMPLAINT filed by Viacom International Inc.; Filing fee $ 405, receipt number AILNDC-23110627.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Viacom International Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Viacom International Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Viacom International Inc.

Notice of Claims Involving Trademarks by Viacom International Inc.

ATTORNEY Appearance for Plaintiff Viacom International Inc. by Martin Francis Trainor

CASE ASSIGNED to the Honorable Manish S. Shah. 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.

NEW PARTIES: Guangzhou Funtoys Co., Ltd., New Game Party Store, TianYuom, AAJNB, ABS 01, Aisann, Alcho, ASTTG, AW AnimeWRLD, BenGoInk, chuntong dian, dahengshop, DaTongShiYunGangQuLiLiPingShangMaoZhongXin, department store retail supermarket, DinglingH, FCHUANG, FCZENG, hexong888, Jeff6421, JIE Store, JoyEn, KENTSING, LAIMINGJUN, LEYILI, LISHUMING, LISISI11, liuliurjingsdan, MARIFW, nHaiQuRu, rizhaokuncairiyongpinhang, ronghanshangmaoyouxiangongsi, ruowenshangmao, Seyiti Store, shangaoshuiyuan123, Shinchitsu, ShowerWay, Siwei Lifei, SLZ124, taiyuanquchenshangmaoyouxiangongsi, tongfeishangmao, Wang Hsiao-xian stationery store, WANGFAFA, wen Fang, WenJoy, WXXJJJ, XINSIY, XST shopping, Yang An Bin An department store, YANGtong, YANQHZ, YEap, yichangshiwujiagangquyungangwujinyouxianzerengongsi, Yin Huarong, yingkeqinwenhuachuanmeigongzuoshi, YXYUAN, Zhang11, A291CW74T05RYK, AQXFXLZLVYEVC, A201EDNG48AFEJ, AU6T2Y2VCXA7C, goodluck_666, toyland-85, l94-32, soktoi-1, Shen Zhen Shi De Rui Kai Ke Ji You Xian Gong Si, Shenzhen Defeng Electronics, 1stshark, abctoyshop, ANGELIDECOR, AnuCustoms, Arcticfootwear, baalency, beddingaholic, bekindproduct, Blackdop, BOUDT, caselone, CENTRONILO, Comfimerch, DAYMIRA, DelightedStore, Eletees, Fantasy Pillow, favomerch, Flazzstore, Footwearelite, Footwearmerch, Gear Fandom, GEARHUMANS, gifury, GOLFGENTRY, icestork, Milionoz, Moon Best Print., Ninosbedding, outlettrends, ova venture, Owl Ohh, Perspirature, plushyspace, PRINIGHT, PROCOSPLAY, tidense, tinykem, wibuprint, Womyso, HOU HOU PLAY TOYS, American Ty, ARTFUL DECOR TREASURY, BLJTOY, F Dreamer, JINMANSI, Little Bunny Toys, Paco Artistic Home, Pika digital, Purple garland, Bihealth, LingyuKejiyouxian Co.ltd, Prove, WONIMA and Yingyongkeji added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

ATTORNEY Appearance for Plaintiff Viacom International Inc. by Alexander Whang

ATTORNEY Appearance for Plaintiff Viacom International Inc. by Sydney Paige Fenton

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Viacom International Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Viacom International Inc. in support of motion for miscellaneous relief 12

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Paul Varley regarding memorandum in support of motion 13

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Viacom International Inc. Exhibit 3, Parts 1-14 regarding declaration 14

Exhibit 3, Part 1

Exhibit 3, Part 2

Exhibit 3, Part 3

Exhibit 3, Part 4

Exhibit 3, Part 5

Exhibit 3, Part 6

Exhibit 3, Part 7

Exhibit 3, Part 8

Exhibit 3, Part 9

Exhibit 3, Part 10

Exhibit 3, Part 11

Exhibit 3, Part 12

Exhibit 3, Part 13

(Exhibit 3, Part 14)

MOTION by Plaintiff Viacom International Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Viacom International Inc. in support of motion for miscellaneous relief 16

Declaration of Martin F. Trainor

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 16, motion for miscellaneous relief 12, motion for miscellaneous relief 3 before Honorable Manish S. Shah on 3/4/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [12] [16] are granted, and no appearance is necessary. The court sets security in the amount of $100,000. Enter Sealed TRO. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Manish S. Shah on 3/3/2025. Mailed notice

MOTION by Plaintiff Viacom International Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Viacom International Inc. in support of motion for miscellaneous relief[21]

Declaration of Martin F. Trainor

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[21] before Honorable Manish S. Shah on 3/13/2025 at 09:45 AM.

SURETY BOND in the amount of $ 100,000.00 posted by Viacom International Inc.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motion to extend the TRO [21] is granted, and the TRO is extended to 3/31/25. Notices Mailed.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Viacom International Inc.

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

ATTORNEY Appearance for Defendant Make Me Surprise by Hua Chen

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

SUMMONS Returned Executed by Viacom International Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 3/24/2025, answer due 4/14/2025.

Declaration of Alexander Whang

Exhibit A

MOTION by Plaintiff Viacom International Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Viacom International Inc. in support of motion for preliminary injunction[32]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction[32] before Honorable Manish S. Shah on 3/27/2025 at 09:45 AM.

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

MOTION by Defendant Make Me Surprise for extension of time to file answer regarding complaint[1] UNOPPOSED

NOTICE of Motion by Hua Chen for presentment of motion for extension of time to file answer[36] before Honorable Manish S. Shah on 4/2/2025 at 09:45 AM.

ATTORNEY Appearance for Defendant Make Me Surprise by Daniel I. Konieczny

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [32] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. The motion for extension of time to respond to the complaint [36] is granted. Defendant 86, Fantasy Pillow, must respond by 6/25/25, and no appearance on the motion is necessary. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 3/27/2025. Notices Mailed.

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Viacom International Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Viacom International Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Viacom International Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Viacom International Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Viacom International Inc. as to certain Defendants

MOTION by Plaintiff Viacom International Inc. for entry of default, MOTION by Plaintiff Viacom International Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Viacom International Inc. in support of motion for entry of default, motion for default judgment[50]

Exhibit 1

Exhibit 2

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[51]

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment[50] before Honorable Manish S. Shah on 8/14/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment [50] is granted. Enter Default Judgment. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 8/14/2025. Notices Mailed.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment as to a certain defendant