2025-cv-02759

COMPLAINT filed by Roblox Corporation; Filing fee $ 405, receipt number AILNDC-23215884.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED DOCUMENT by Plaintiff Roblox Corporation Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Roblox Corporation by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Roblox Corporation by Adam Grodman

ATTORNEY Appearance for Plaintiff Roblox Corporation by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Roblox Corporation by Christopher Romero

ATTORNEY Appearance for Plaintiff Roblox Corporation by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Roblox Corporation by Yanling Jiang

ATTORNEY Appearance for Plaintiff Roblox Corporation by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Roblox Corporation

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

Schedule A to Complaint [1] and Schedule A [2] [PUBLIC VERSION] by Roblox Corporation

MEMORANDUM in Support of [13] Exparte Motion

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

Declaration of Keith A. Vogt

Exhibit 1-2, of Keith A. Vogt's Declaration

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 Honorable Thomas M. Durkin: Ex parte motion for leave to conduct expedited discovery and electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 13 is granted. Mailed notice.

ORDER for Leave to Conduct Expedited Discovery and Service by E-Mail and/or Electronic Publication. Signed by the Honorable Thomas M. Durkin on 3/18/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) ArtWear and all other Defendants identified in the Complaint by Plaintiff Roblox Corporation

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

SUMMONS Returned Executed by Roblox Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/27/2025, answer due 4/17/2025.

(Declaration of Service)

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

MEMORANDUM by Roblox Corporation in support of motion for default judgment[23]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

Declaration of Christian Bayley

MOTION by Plaintiff Roblox Corporation for default judgment as to the Defendants Identified in Schedule A [CORRECTED [23]]

MEMORANDUM by Roblox Corporation in support of motion for default judgment[25] [CORRECTED]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

Declaration of Christian Bayley

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for default judgment [25] is set for 4/24/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin: Motion hearing held on 4/24/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for default judgment 25 is granted. Enter order. Civil case terminated. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 4/24/2025 to Patent Trademark Office, Alexandria VA

MAILED Copyright report with certified copy of minute order dated 4/24/2025 to Registrar, Washington DC

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 4/24/2025. Mailed notice.

ATTORNEY Appearance for Defendants QzdMenFactory, mens clothing detail, beershirt by Jianyin Liu

MOTION by Defendants QzdMenFactory, beershirt, mens clothing detail to vacate order[31]

DECLARATION of Jin Long regarding motion to vacate[33]

DECLARATION of Jun Jun Wang regarding motion to vacate[33]

DECLARATION of Mangu Kong regarding motion to vacate[33]

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff's response to Defendants QzdMenFactory, beershirt, and mens clothing detail's motion to vacate order [33] is due by 8/28/2025. Defendants' reply is due by 9/8/2025. Plaintiff's response should specifically address the movants' assertion that they have not sold any allegedly infringing products in the U.S. and should include any evidence Plaintiff has of the movants' sales to this forum. If the parties would like to engage in settlement discussions before Plaintiff's response is due or while the briefing is taking place, they are free to do so. Mailed notice.

MOTION by Plaintiff Roblox Corporation to stay regarding MOTION by Defendants QzdMenFactory, beershirt, mens clothing detail to vacate order[31] [33], MOTION by Plaintiff Roblox Corporation for discovery

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion to stay Defendants' motion, and for jurisdictional discovery [38] is set for 9/10/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin: Motion hearing held on 9/10/2025. The parties are to contact the courtroom deputy to schedule an in-court hearing on the motion to stay Defendants' motion [33], and for jurisdictional discovery [38]. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: In-court hearing as to the motion to stay Defendants' motion [33], and for jurisdictional discovery [38] is set for 9/16/2025 at 2:00 p.m. in courtroom 1441. Mailed notice.

ATTORNEY Appearance for Defendants QzdMenFactory, beershirt, mens clothing detail by Benjamin Solter

MINUTE entry before the Honorable Thomas M. Durkin: The hearing as to the motion to stay Defendants' motion [33] and for jurisdictional discovery [38] is vacated. A joint status report is due by 9/23/2025. Mailed notice.

STATUS Report Joint Status Report by Roblox Corporation

MINUTE entry before the Honorable Thomas M. Durkin: Briefing on Defendants' Motion to Vacate [33] and Plaintiff's Motion to Stay [38] is stayed until a joint stipulation of dismissal is filed. A joint status report is due by 10/27/2025, unless the case is dismissed before then. Mailed notice.