2025-cv-02585

COMPLAINT filed by Sega Corporation, Sega of America, Inc.; Filing fee $ 405, receipt number AILNDC-23197431.

Exhibit 1

Declaration of Martin F. Trainor

Exhibit 1

Exhibit 3, Part 1

Declaration of Martin F. Trainor

Declaration of Martin F. Trainor

Declaration of Sydney Fenton

Exhibit A

Declaration of Martin F. Trainor

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Schedule A regarding complaint[1]

Exhibit 2

Exhibit 1

Exhibit 2

Exhibit 3, Part 2

Exhibit 1

Exhibit A

Exhibit 1

Exhibit 2

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Leave to File Certain Documents Under Seal

Exhibit 3

Exhibit 3, Part 3

CIVIL Cover Sheet

Exhibit 4

Exhibit 3, Part 4

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sega Corporation, Sega of America, Inc.

Exhibit 5

Exhibit 3, Part 5

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

NEW PARTIES: Aivuidbs Retro Handheld Game, Brick A, CuiTby, DeComfort, dongsong Huang, Dory Fish, Fengtao patch, FuYouB, HAVY06SHOP, Ho30.ngSGCeng, HUBEIRUICHEN, hubeiyoushengdakejiyouxiangongsi, HuWenJing123, I love You Shop, ivan cornejo, JiangYiJie1688, Kris shop decals, LSonic, lzpzpl, ofo66, PermaBloom, Philevathan, PiLiSiShangMaoDian, pildianzishangwuyouxiangongsi, qixianhaoqishangmaoyouxiangongsi, Qurtalun, sWonders, yaqijingxuandian, yichangshiyaocubaihuoshanghang, YL-shop, yueqingqinghuanxiaozhuxiuxianguanguangyouxiangongsi, YZHjsuu160 UYTTPP, A2DPN62O6ZWRL6, ATIXHT5ZH9ZY2, A2T36IVOWIB04B, aildeman, Alitaiyi Direct, 9Teeshirt, Allonesie, Beebeetee, Beerug, Dramashirt, Ebuycos, Gear Fandom, giftcustom, Luca Jackets, Tinicloset, Tshirtprochip, AAXIAOYUB, Acker Li, Addxjnnrn, AZMUOUTOP, BAOZIWW, Blanket Candy, Blanket Flying Man, Candy Blanket, cattle horses Decorate, chelsia Decorate, chenrourou, Custom Blankets, Customised Blankets, Customized Plans, DDPIJJ, Design Olivia, durrud, Floating Cloud Decorate, FOUR O NE, GFOWE, Gorgeous Live, LaJoe shop, Love Fashion Poster shop, LZW shop, Many blankets, NUUOKWXH, Oil painting by Macson, OKC JLY, Pleasing Blankets, Progress Space, Purely Apparel, SLBKB, Space blanket, Spshian gua, Spshian xiong, TIME OAA, Trend Anime Kingdom, wonderful Blankets, yuhangchen, ZXSBO Shop, bengbutenghuanshangmao, Erxiakejiltd, HETUIWLO, Homgek, HuangYinZhuang, MOLIKE, shenzhenhuang026, TNSAWRRYOE, yuanhongBS, Zkysteio, fengwenshangmaoMingPan, GracePosters, henanshuntiangongfudaowenhuachuanboyouxiangongsi, Hulun&Buir, LGQMDHC, LiangShanChunHongGangCaiYouXianGongSi, LMliming, NHI HOA LC, Ningchao123, tongwanquanshop, vdfhbfgkm, weishansea, yangzaishangmaohang, zhanghongkuiouzhou, uan_xuan, angelnheaven, animedwarf, Arcticfootwear, BaoHanTee, BeBeHawaii, Buckeyeser, casefine, Chicabulls Apparel, Chow Down Movie Store, CORKYSHIRT, DUGO, Fanwells, Favorety, GhostTshirt.com, KidsRoomEssentials.com, KND Sport Room, MuFree, Oceandust, PH Travel Express, Sarfisek, TeeJB.com, Teetine Store, Vintage & Classic Store, Charming beautiful clothes workshop, HuiHuiWW, yan B poste, AFSKUSTORE, Bfliqian, EnYueKe, GFsafasfvafv, Glory Mart 2, helian shop, HiGlassArt, HTT Store, KW-Pest Killer, lizhengwei0101, QIMING Co.Ltd, RongS, SUGOYI, Toynit, Luziuiqi S, panpanpanA, ShirtActive, haikoushihanjiedianzishangwu, Haiyuebin, HuangDOU, HONG LONG 05 SHOP, Lazy Mercury and Furry Sculptures added to case caption. Terminating The Partnerships and Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

Notice of Claims Involving Trademarks by Sega Corporation, Sega of America, Inc.

Exhibit 3, Part 6

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Martin Francis Trainor

Exhibit 3, Part 7

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Sydney Paige Fenton

Exhibit 3, Part 8

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Alexander Whang

Exhibit 3, Part 9

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Exhibit 3, Part 10)

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

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[12]

DECLARATION of Paul Varley regarding memorandum in support of motion[13]

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Exhibit 3, Parts 1-10 regarding declaration 14

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[16]

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[16], motion for miscellaneous relief[3], motion for miscellaneous relief[12] before Honorable Jorge L. Alonso on 3/20/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [12] [16] are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. 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 is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $164,000 -- $1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 3/20/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 3/19/2025. Notice mailed by Judge's staff

SUMMONS Submitted (Court Participant) for defendant(s) THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE "A" by Plaintiffs Sega Corporation, Sega of America, Inc.

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

SURETY BOND in the amount of $ 164,000 posted by Sega Corporation, Sega of America, Inc. (Document not scanned)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief[24]

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[24] before Honorable Jorge L. Alonso on 4/2/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order [24] is granted. The temporary restraining order is extended to 4/16/25. Motion hearing date of 4/2/25 is stricken. Telephonic status hearing set for 4/16/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

SUMMONS Returned Executed by Sega Corporation, Sega of America, Inc. as to The Partnerships and Unincorporated Associations Identified On Schedule A on 4/11/2025, answer due 5/2/2025.

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for preliminary injunction

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for preliminary injunction[29]

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction[29] before Honorable Jorge L. Alonso on 4/16/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 5/29/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [29] is granted. Enter Preliminary Injunction Order. Plaintiff 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 at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 4/16/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

ATTORNEY Appearance for Defendant QIMING Co.Ltd by He Cheng

ANSWER to Complaint by QIMING Co.Ltd

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

ATTORNEY Appearance for Defendant Aivuidbs Retro Handheld Game by Timothy Tiewei Wang

MOTION by Defendant Aivuidbs Retro Handheld Game for extension of time to file answer regarding complaint[1] Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer[44] before Honorable Jorge L. Alonso on 5/22/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Defendant's Unopposed motion to extend deadline to answer or otherwise respond [44] is granted to 6/4/25. Motion hearing date of 5/22/25 is stricken. Telephonic Status hearing previously set for 5/29/25 is stricken and reset to 6/12/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for entry of default, MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for default judgment as to all Defendantswith the exception of Defendant Nos. 1 and 151

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, [50]

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

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment, [50] before Honorable Jorge L. Alonso on 6/12/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 6/25/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiffs' Motion for entry of default and default judgment against the Defendants identified on schedule A, with the exception of certain Defendants [50] is granted. Enter Default judgment order. The parties are directed to meet and confer and file a joint status report by 6/20/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/12/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by All Plaintiffs as to a certain Defendant

STATUS Report Joint by Sega Corporation, Sega of America, Inc.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Status hearing held and continued to 7/24/25 at 9:30 a.m. The parties are directed to file a joint status report by 7/21/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

STATUS Report Joint by Sega Corporation, Sega of America, Inc.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. All fact discovery shall be noticed in time to be completed by 12/4/25. This case is referred to the magistrate judge for discovery supervision, with the authority to set and extend deadlines, to set a briefing schedule for dispositive motions, and a settlement conference. The parties are directed to meet and confer to explore the possibility of settlement. Notice mailed by Judge's staff

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Maria Valdez for the purpose of holding proceedings related to: discovery supervision; settlement conference. Notice mailed by Judge's staff.

MINUTE entry before the Honorable Maria Valdez: This case has been referred to Judge Valdez for discovery supervision, to set a dispositive motion briefing schedule, and to conduct a settlement conference. The parties must file a joint status report no later than 9/24/25 detailing their discovery progress and the prospects of settlement. If they wish to begin the process of scheduling a settlement conference at any time prior to that date, they should notify the Court. The dispositive motion briefing schedule will be set at a later date. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

Notice of Withdrawal of Notice of Dismissal by Sega Corporation, Sega of America, Inc.

STIPULATION of Dismissal

MINUTE entry before the Honorable Maria Valdez: In light of the Stipulation of Dismissal [66], the status report date is stricken. All matters relating to the referral of this action having been resolved, the case is returned to the assigned judge. Mailed notice

MINUTE entry before the Honorable Jorge L. Alonso: A stipulation to dismiss has been filed. This case is dismissed with prejudice. Civil case terminated. Notice mailed by Judge's staff