2025-cv-02221

COMPLAINT filed by Michael Buxton; Filing fee $ 405, receipt number AILNDC-23155381.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Michael Buxton Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Michael Buxton by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Michael Buxton by Adam Grodman

ATTORNEY Appearance for Plaintiff Michael Buxton by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Michael Buxton by Christopher Romero

ATTORNEY Appearance for Plaintiff Michael Buxton by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Michael Buxton by Yanling Jiang

ATTORNEY Appearance for Plaintiff Michael Buxton by Yi Bu

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 3).

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.

SEALED DOCUMENT by Plaintiff Michael Buxton Amended Schedule A to Complaint 1 and Schedule A 2

MOTION by Plaintiff Michael Buxton for leave to file under seal

MOTION by Plaintiff Michael Buxton for leave to file excess pages

MEMORANDUM in Support of 14 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Michael Buxton

(Exhibit 1, of Michael Buxton's Declaration)

SEALED EXHIBIT by Plaintiff Michael Buxton Sealed Exhibit 2, Declaration of Michael Buxton regarding memorandum in support of motion, 15

Exhibit 2-1

(Exhibit 2-2)

MAILED Copyright report to Registrar, Washington DC.

((List of Copyrights))

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal 12, motion for leave to file excess pages 13, and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and for electronic service of process 14 are granted as to Amended Schedule A. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and offering sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 5/19/25 at 9:00 a.m. to track the case only. (to track the case only, no appearance is required). Mailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Jeffrey I Cummings on 4/4/2025. Mailed notice

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

MOTION by Plaintiff Michael Buxton for preliminary injunction

MEMORANDUM by Michael Buxton in support of motion for preliminary injunction 23

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's Declaration)

SUMMONS Returned Executed by Michael Buxton as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/11/2025, answer due 5/2/2025.

(Declaration of Service)

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 23. In connection with that motion, plaintiff must serve all remaining defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by or before April 25, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's order entering the TRO, the TRO is extended to and including the date upon which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under Fed.R.Civ.P. 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice

CERTIFICATE of Service by Plaintiff Michael Buxton regarding text entry, 26

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 23 is granted as to the remaining defendants. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. If plaintiff intends to move for an order of default and default judgment, plaintiff shall file its motion on or before 6/6/25. The 5/19/25 tracking status hearing is stricken and re-set to 6/23/25 at 9:00 a.m. (to track the case only, no appearance is required).

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Jeffrey I Cummings on 5/6/2025.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 35 ISAASE

MOTION by Plaintiff Michael Buxton for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by Michael Buxton in support of motion for default judgment 32

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 32 for entry of default and default judgment against defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 5/23/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice

CERTIFICATE of Service by Plaintiff Michael Buxton regarding terminate deadlines and hearings, 34

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable Jeffrey I Cummings: The remaining defendants have not responded to plaintiff's motion for entry of default judgment. Accordingly, the motion [32] is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's copyrights irreparably harms plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendant (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $15,000 is an appropriate award of statutory damages. Enter Final Judgment Order. All pending deadlines and hearings are stricken. Civil case terminated. Mailed notice

ENTERED JUDGMENT Mailed notice