2025-cv-02376

COMPLAINT filed by TV Tokyo Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-23172858.

Exhibit 1

(Exhibit 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by John Wilson

MOTION by Plaintiff TV Tokyo Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation

Notice of Claims Involving Trademarks by TV Tokyo Corporation

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Laura K. McNally. 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: TaiYuanShiXuKongShang, TaiYuanNuoPuMingDianZi, MMINGY Choice, Enhong and CYK womens wear store added to case caption.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Andrea R. Wood for all further proceedings pursuant to Local Rule IOP 13(f)(1). Mailed notice

(Request for Reassignment)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic initial status hearing set for 5/6/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. The parties are directed to meet and conduct a planning conference pursuant to Federal Rule of Civil Procedure 26(f). At least seven days before the initial status hearing, the parties shall file a joint written status report, not to exceed five pages in length. The initial status report shall provide the information described on the Court's website at www.ilnd.uscourts.gov under District Judges, Judge Andrea R. Wood, Initial Status Conference. Mailed notice

MOTION by Plaintiff TV Tokyo Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff TV Tokyo Corporation 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 TV Tokyo Corporation in support of motion for temporary restraining order, 17

Declaration Saiki Declaration

Exhibit 1

Exhibit 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 1 of Saiki Declaration

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 2 of Saiki Declaration

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Exhibit 3 Part 3 of Saiki Declaration

STATUS Report Initial Status Report by TV Tokyo Corporation

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Amended Schedule A

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion and status hearing held on 5/6/2025. Plaintiff's counsel to submit amended Schedule A by 5/9/25. Telephonic status hearing set for 5/23/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 5/23/2025. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/23/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 7, motion to exceed page limitation 16, and 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 17 are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A 8, (2) Exhibit 3 Part 1-3 of Saiki Declaration 19, 20, and 21, and (3) Amended Schedule A 23. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 5/23/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 6/6/2025 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Ex-Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 27 is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 6/20/2025. Telephonic status hearing set for 6/6/2025 is stricken and reset for 6/20/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

SURETY BOND in the amount of $ 10,000 posted by TV Tokyo Corporation (Document not scanned)

MOTION by Plaintiff TV Tokyo Corporation to substitute party Plaintiff's Motion to Substitute Defendants and Leave to File Amended Complaint

MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

(Exhibit B)

SEALED EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit A regarding MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order 31

MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction as to Certain Defendants

MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction 33

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 33

SUMMONS Issued (Court Participant) as to Defendant Joybuy Marketplace(U.S)(114) and all other Defendants identified in the Complaint

AMENDED complaint by TV Tokyo Corporation against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

Exhibit 1

(Exhibit 2)

Amended Schedule A by TV Tokyo Corporation

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/20/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction as to Defendant nos. 3-4 and 41-43 33 is granted. Enter Preliminary Injunction Order as to Defendant nos. 3, 4, and 41, 42, and 43. Plaintiff's ex parte motion to extend the temporary restraining order 31 is granted. The Temporary Restraining Order is extended until 7/3/2025 as to the remaining Defendants to allow sufficient time for them to receive adequate notice and be heard regarding a motion for a preliminary injunction. Any party aggrieved by the continued Temporary Restraining Order may file a motion for relief and be heard on an emergency basis. The Clerk's Office is directed to unseal: (1) Schedule A 8, (2) Exhibit 3 Part 1-3 of Saiki Declaration 19, 20, and 21, (3) Amended Schedule A 23, and (4) the sealed temporary restraining order 25. Plaintiff's counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Plaintiff's motion to substitute Defendants and leave to file amended complaint 30 is granted. Telephonic status hearing set for 7/3/2025 at 9:00 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 6/20/2025. Mailed notice

MOTION by Plaintiff TV Tokyo Corporation to strike Plaintiff's Motion to Strike Amended Schedule A [Dkt. No. 39]

Second Amended Schedule A by TV Tokyo Corporation

MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction as to Defendant Nos. 1-2, 5-8 and 44-51

MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction 44

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 44

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Elizabeth Aubree Miller

SUMMONS Returned Executed by TV Tokyo Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 7/2/2025, answer due 7/23/2025.

CERTIFICATE of Service by Elizabeth Aubree Miller on behalf of TV Tokyo Corporation

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/3/2025. For the reasons stated on the record, Plaintiff's motion to strike amended schedule A (Dkt. No. 39) 42 is granted as follows. The "Amended Schedule A" at Dkt. No. 39 is stricken. The "Second Amended Schedule A" 43 is accepted as a Corrected Amended Schedule A related to the Amended Complaint 38. Plaintiff's motion for entry of a preliminary injunction as to Defendant nos. 1-2, 5-8, and 44-51 44 is entered and continued. Any party wishing to respond to Plaintiff's motion for preliminary injunction 44 shall file a written response by 7/11/2025 and appear at the telephonic motion and status hearing on 7/18/2025 at 9:30 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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. Plaintiff's counsel is directed to provide a copy of this order and their motion to the Defendants. Mailed notice

CERTIFICATE of Service by Elizabeth Aubree Miller on behalf of TV Tokyo Corporation

ANSWER to amended complaint by James Clayton Duncan. (Received via Box.com 7/7/25)

RESPONSE by James Clayton Duncan to MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction as to Defendant Nos. 1-2, 5-8 and 44-51 44. (Received via Box.com 7/7/25)

MOTION by Defendant James Clayton Duncan to compel initial disclosures. (Received via Box.com 7/7/25)

MOTION by Defendant Hokozan Anime Store to dismiss pursuant to Federal Rules of Civil Procedure Rule 12(b). (Received via Box.com 7/7/25)

MOTION by Defendant Hokozan Anime Store to Dismiss Pursuant to Federal Rules of Civil Procedure Rule 12(b). (Received via Pro Se Online Portal on 7/8/2025.)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/18/2025. For the reasons stated on the record, the Temporary Restraining Order entered 5/23/2025 25 is vacated as to Defendant SIDEQUEST.GG. Any restrained assets shall be released immediately. In addition, Plaintiff's motion for entry of a preliminary injunction as to Defendant nos. 1-2, 5-8, and 44-51 44 is denied as to Defendant SIDEQUEST.GG and granted as to the remaining Defendants. Enter Preliminary Injunction Order. By 7/25/2025, Defendant Hokozan Anime shall make a supplemental filing with a sworn affidavit or declaration supporting its request to release a portion of its PayPal account. Plaintiff and Defendant Hokozan Anime may engage in expedited discovery to confirm Defendant Hokozan Anime's revenues from the sale of the allegedly infringing products. If Plaintiff and Defendant Hokozan Anime have not resolved their dispute, the Court will set a briefing schedule on Defendant Hokozan Anime's motion to dismiss the complaint 54, 55 at the next status hearing. Telephonic status hearing set for 8/1/2025 at 8:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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. Mailed notice

ORDER PRELIMINARY INJUNCTION ORDER AGAINST DEFENDANT NOS. 12, 58, 4448, 50 AND 51. Signed by the Honorable Andrea R. Wood on 7/18/2025. Mailed notice

STIPULATION of Dismissal Stipulation of Voluntary Dismissal

AFFIDAVIT of Anas Taifour. (Exhibits) (Received via pro se online portal on 7/25/2025)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/1/2025. The Court sets the following briefing schedule on Defendant Hokozan Anime's motion to dismiss the complaint [55], [56]. Plaintiff shall file a response by 8/15/2025, and Defendant Hokozan Anime shall file a reply by 8/29/2025. As stated on the record, the asset freeze as to Defendant Hokozan Anime shall be limited to the amount of $70.00. Accordingly, the Court hereby orders PayPal, Inc. to modify any asset restraint as to Defendant Hokozan Anime that has been imposed as a result of the Preliminary Injunction Order in this case, No. 25-cv-02376 (N.D. Ill.), to restrain no more than $70.00. The asset restrain in this case, No. 25-cv-02376 (N.D. Ill.), shall be not be construed to restrain assets of Defendant Hokozan Anime in excess of $70.00. This order does not affect an asset restraint imposed as a result of any other lawsuit pending in the Northern District of Illinois or elsewhere. Plaintiff's counsel shall provide a copy of this Order to PayPal, Inc. immediately. By 8/8/2025, Plaintiff is directed to show cause in writing why the asset freeze in the Preliminary Injunction Order should not be further modified to release Defendant Hokozan Anime's PayPal account in its entirety. Defendant SIDEQUEST.GG's motion to compel initial disclosures [54] is terminated as moot in light of the stipulation of dismissal [59]. Telephonic status hearing set for 9/4/2025 at 9:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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. Mailed notice

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

(Exhibit A)

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment 61

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 61

(Exhibit Hierl Exhibit 1)

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 47 "Hozokan Anime"

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment 61 will be heard at the telephonic hearing set for 9/4/2025 at 9:45 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 9/4/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment [61] is granted. Enter Default Judgment Order. Defendant Hokozan Anime's motion to dismiss the complaint [55], [56] are terminated as moot. Civil case terminated. Mailed notice n

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 9/10/2025. Mailed notice