2025-cv-02837

COMPLAINT for Copyright Infringement filed by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD; Jury Demand. Filing fee $ 405, receipt number AILNDC-23224176.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

SEALED EXHIBIT by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD Complaint for Copyright Infringement regarding complaint, [1]

CIVIL Cover Sheet

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to seal

Declaration of Katherine M. Kuhn in Support of Motion to Seal

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

SEALED EXHIBIT by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to seal [4]

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Gokalp Bayramoglu

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

NEW PARTIES: KAILINNA added to case caption.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Edmond E. Chang for all further proceedings pursuant to the provisions of 28 USC 294(b). Mailed notice

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 04/18/2025 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the ***ATTACHED*** status report requirements (do ***not*** use templates from other cases) by 04/10/2025. Plaintiff must still file the report even if Defendant has not responded to requests to craft a joint report. If Defendant has not have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel (or the parties, if proceeding pro se) must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel (or the party, if proceeding pro se) must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and Electronic Service

Exhibit Memorandum in Support of Motion for Electronic Service

Declaration of Katherine M. Kuhn In Support of Motion for Electronic Service

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages for Temporary Restraining Order

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

Exhibit Memorandum in Support of Temporary Restraining Order

Declaration of Katherine M. Kuhn in Support of Temporary Restraining Order

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Temporary Restraining Order

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for leave to file excess pages[15], motion to seal, [4], motion for service by publication, [14], motion for temporary restraining order, [16] before Honorable Edmond E. Chang on 4/15/2025 at 08:30 AM.

STATUS Report in Compliance with Docket 13 by Hong Kong Leyuzhen Technology Co. Limited

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion for temporary restraining order [16] is granted. An order will be entered 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 Defendant 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 Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion [4] for leave to file under seal is terminated as withdrawn: the courtroom deputy contacted the Plaintiff's counsel to inquire whether the TRO motion, which was publicly filed, was intended to be under seal, and the response was no. The Plaintiff's motion [14] for electronic service of process is granted for good cause and to provide reasonable notice. The motion [15] for extra pages is granted. The tracking status hearing of 04/18/2025 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). Instead, the Plaintiff shall file a status report by 04/21/2025. The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 04/21/2025. Emailed notice

TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 04/14/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) KAILINNA by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

SUMMONS Issued (Court Participant) as to Defendant KAILINNA

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to deposit funds into Court Registry

Exhibit Registry Deposit Information Form

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to ABC Corporation on 4/21/2025, answer due 5/12/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for preliminary injunction

Exhibit Memorandum in Support of Preliminary Injunction

Declaration of Joseph W. Droter in Support of Motion for Preliminary Injunction

Exhibit 1 to the Declaration of J. Droter

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [25] before Honorable Edmond E. Chang on 4/25/2025 at 08:30 AM.

STATUS Report in Compliance with Docket 19 by Hong Kong Leyuzhen Technology Co. Limited

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction [25] is granted. Given the answer deadline of 05/12/2025, the tracking status hearing of 04/25/2025 for Judge Chang is reset to 05/30/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file an updated joint initial status report, R. 13-1, by 05/23/2025. If the Defendant does not answer on time, then it is deemed to be in default, and the Plaintiff shall instead file a motion for default judgment by 05/23/2025. The motion to deposit funds into Court Registry [23] is granted. Emailed notice

ORDER FOR PRELIMINARY INJUNCTION Signed by the Honorable Edmond E. Chang on 04/22/2025. Emailed notice

SURETY BOND in the amount of $ 1,000.00 posted by Hong Kong Leyuzhen Technology Co. Limited

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to Defendant KAILINNA

Exhibit Memorandum in Support of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn in Support of Motion for Default Judgment

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Motion for Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [31] before Honorable Edmond E. Chang on 5/22/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: The default judgment motion [31] is under advisement. The notice of motion for 05/22/2025 is vacated. Mailed notice. (jn,)

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely answer, the motion for default judgment [31] is granted. Statutory damages is entered in favor of the Plaintiff and against each Defendant in the amount of seven-thousand and five-hundred dollars ($7,500) per Defendant. Given the finding of willfulness established by the default, a permanent injunction shall be entered. A separate AO-450 judgment shall be entered. The status hearing of 05/30/2025 is vacated. Civil case terminated. Emailed notice

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 05/28/2025. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 05/28/2025. Emailed notice

MAILED final copyright report with a copy of minute entry [34], the final default judgment order [35] and the entered judgment [36] to Registrar, Washington DC