2025-cv-02742

COMPLAINT filed by Julie Stiebritz; Filing fee $ 405, receipt number AILNDC-23214369.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Julie Stiebritz Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Yanling Jiang

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Yi Bu

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Adam Grodman

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Julie Stiebritz by Christopher Romero

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Young B. Kim. 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.

EMAILED Copyright report to Registrar, Washington DC

SEALED DOCUMENT by Plaintiff Julie Stiebritz Amended Schedule A to Complaint 1 and Schedule A 2

MOTION by Plaintiff Julie Stiebritz for leave to file under seal

MOTION by Plaintiff Julie Stiebritz for leave to file excess pages

MEMORANDUM in Support of 16 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Julie Stiebritz

(Exhibit 1, of Julie Stiebritz's Declaration)

SEALED EXHIBIT by Plaintiff Julie Stiebritz Sealed Exhibit 2, Declaration of Julie Stiebritz regarding memorandum in support of motion, 17

(Exhibit 2)

Presentment for Exparte Motion 16 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 15, motion for leave to file 14 before Honorable Edmond E. Chang on 3/26/2025 at 08:30 AM.

MEMORANDUM by Julie Stiebritz Establishing that Joinder is Proper

(Exhibit 1)

MINUTE entry before the Honorable Edmond E. Chang: The motion 15 for extra pages is granted. The motion 14 to seal is granted for now, given the goal of asset restraint. The TRO motion and joinder memorandum on the remaining three Defendants are taken under advisement. The tracking status hearing of 04/11/2025 remains in place. The status-report deadline of 04/01/2025, see R. 12, is vacated. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The TRO motion and joinder memorandum on the remaining three Defendants remain under advisement. The tracking status hearing of 04/11/2025 is reset to 04/25/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The TRO motion and the joinder memorandum on the remaining three Defendants remain under advisement. The tracking status hearing of 04/25/2025 is reset to 05/13/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The TRO motion and the joinder memorandum on the remaining three Defendants remain under advisement, so the tracking status hearing of 05/13/2025 is reset to 06/06/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The TRO motion and the joinder memorandum on the remaining three Defendants remain under advisement. The tracking status hearing of 06/06/2025 is reset to 06/27/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The TRO motion and the joinder memorandum on the remaining three Defendants remain under advisement, so the tracking status hearing of 06/27/2025 is reset to 07/25/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of the joinder memorandum, the case is properly joined (at least absent adversarial presentation). The three Defendants use the same 22-word product description, complete with unusual words in a non-grammatical, unusual sequence. And, importantly, the same brand name is used by all three Defendants. (2.) In this copyright-infringement case, the Plaintiff's motion [16] for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. � 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. �504(b). To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendants, who likely would seek to transfer the money elsewhere. The Plaintiff's request for electronic service of process is granted. The tracking status hearing of 10/03/2025 is reset to 10/17/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the Plaintiff shall file a status report by 10/10/2025. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion), but only if appropriate, by no later than 10/10/2025. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 10/02/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 10/02/2025. Emailed notice