2025-cv-02107

COMPLAINT filed by Sesame Workshop; Filing fee $ 405, receipt number AILNDC-23146413.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Sesame Workshop Schedule A regarding complaint[1]

MOTION by Plaintiff Sesame Workshop for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sesame Workshop

Notice of Claims Involving Trademarks by Sesame Workshop

ATTORNEY Appearance for Plaintiff Sesame Workshop by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Sesame Workshop by Alexander Whang

ATTORNEY Appearance for Plaintiff Sesame Workshop by Sydney Paige Fenton

CASE ASSIGNED to the Honorable Jeremy C. Daniel. 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: [REDACTED] added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

NEW PARTIES: Sun Dan Men's wear store added to case caption. Terminating [REDACTED]

MAILED original one thousand-dollar ($1,000) surety bond posted by Sesame Workshop to Attorney, Martin Francis Trainor TME Law, P.C. 10 S. Riverside Plaza, Suite 875 Chicago, IL 60606 via certified mail #9589 0710 5270 0579 7830 80

MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff has filed a complaint alleging infringement by 165 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 20 is rarely appropriate in Schedule A cases. See, e.g., Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27 (N.D. Ill. Nov. 18, 2024). Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder on or before March 17, 2025. Alternatively, by the same date, the plaintiff may file an amended complaint naming one or more defendants; however, if the plaintiff names multiple defendants, the plaintiff must show that joinder of those defendants is proper. All pending motions are hereby stayed pending resolution of the joinder issue. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

Trademarks

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

AMENDED complaint by Sesame Workshop against [REDACTED]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Sesame Workshop Schedule A regarding amended complaint[13]

MOTION by Plaintiff Sesame Workshop for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sesame Workshop in support of motion for miscellaneous relief[15]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Sesame Workshop Exhibit 3, Part 1 regarding declaration[17]

(Exhibit 3, Part 1)

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

MEMORANDUM by Sesame Workshop in support of motion for miscellaneous relief[19]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[19], motion for miscellaneous relief[3], motion for miscellaneous relief[15] before Honorable Jeremy C. Daniel on 3/19/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Motions to seal [3], for temporary restraining order [15] and for electronic service [19] are granted. Counsel shall send the proposed temporary restraining order to the Court's proposed order email on or before 3/20/2025. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 3/20/2025. Mailed notice.

SURETY BOND in the amount of $ 1,000 posted by Sesame Workshop. Document not imaged.

MOTION by Plaintiff Sesame Workshop to Extend the Temporary Restraining Order

MEMORANDUM by Sesame Workshop in support of motion for miscellaneous relief[25]

Declaration of Martin F. Trainor

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[25] before Honorable Jeremy C. Daniel on 4/3/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Plaintiff's ex parte motion to extend the temporary restraining order [28] is granted. The TRO now expires on 4/17/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) [REDACTED] by Plaintiff Sesame Workshop

SUMMONS Issued (Court Participant) as to Defendant [REDACTED]

SUMMONS Returned Executed by Sesame Workshop as to [REDACTED] on 4/14/2025, answer due 5/5/2025.

Declaration of Alexander Whang

Exhibit A

MOTION by Plaintiff Sesame Workshop for preliminary injunction

Exhibit A

MEMORANDUM by Sesame Workshop 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 Jeremy C. Daniel on 4/17/2025 at 09:30 AM.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 4/17/2025. Motion hearing held. Plaintiff's motion for preliminary injunction [32] is granted. The plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on court's website located www.ilnd.uscourts.gov/instructions. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: The parties shall file a status report on or before July 3, 2025. Mailed notice (gel,)

STATUS Report by Sesame Workshop

Exhibit A

MOTION by Plaintiff Sesame Workshop for entry of default, MOTION by Plaintiff Sesame Workshop for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Sesame Workshop in support of motion for entry of default, motion for default judgment[38]

Exhibit 1

Exhibit 2

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[39]

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment[38] before Honorable Jeremy C. Daniel on 7/17/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: The Court has received the plaintiff's proposed order. The plaintiff shall file a copy of its proposed order on the docket. At the motion hearing, the plaintiff shall identify the record evidence and law that supports the relief sought in the proposed order. Mailed notice.

Proposed Final Judgment Order by Sesame Workshop

MOTION by Plaintiff Sesame Workshopto Reschedule Hearing on Plaintiffs Motion for Entry of Default and Default Judgment

Exhibit A

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[44] before Honorable Jeremy C. Daniel on 7/17/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion to reschedule hearing on plaintiff's motion for entry of default and default judgement [44] is granted. The motion hearing set for 7/17/2025 is reset to 7/31/2025 at 9:30 a.m. Mailed notice.

FINAL JUGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 7/31/2025. Motion hearing held. Motion for entry of default and default judgment [29] is granted. Civil case terminated. Mailed notice.

EMAILED Trademark report with certified copy of minute order dated 7/31/25 to Patent Trademark Office, Alexandria VA

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7830 80. (Received by mail in the Clerk's Office on 08/15/2025)

TRANSCRIPT OF PROCEEDINGS held on 07-31-2025 before the Honorable Jeremy C. Daniel. Order Number: 52644. Court Reporter Contact Information: Krista Burgeson, krista_burgeson@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 10/8/2025. Redacted Transcript Deadline set for 10/20/2025. Release of Transcript Restriction set for 12/16/2025.

MINUTE entry before the Honorable Jeremy C. Daniel: Any party to this action has until October 21, 2025, to justify the continued need to seal any documents in this case. The Court intends to unseal all documents in this case after that date. Mailed notice.