2025-cv-02910

COMPLAINT filed by Tee Turtle, LLC.; Filing fee $ 405, receipt number AILNDC-23231318.

Exhibit 1

Exhibit 2

(Schedule A Slip Sheet)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Tee Turtle, LLC. by Samantha Diane Parrish

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tee Turtle, LLC.

CLAIM - AO 120 Form (Trademarks) by Tee Turtle, LLC.

CLAIM - AO 121 Form (Copyright) by Tee Turtle, LLC.

(Exhibit A)

SEALED DOCUMENT by Plaintiff Tee Turtle, LLC. - Schedule A to Complaint

CASE ASSIGNED to the Honorable Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff has filed a complaint alleging infringement by 167 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 19 and 20 is rarely appropriate in Schedule A cases. Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder at least 7 days before the filing of the motion for temporary restraining order. Alternatively, by the same date, Plaintiff may file an amended complaint and amended Schedule A reducing the number of defendants. However, if Plaintiff names multiple defendants, Plaintiff must show that joinder of those defendants is proper. The Court directs Plaintiff to this Court's standing order in Schedule A cases regarding joinder on the Court's website. Mailed notice.

AMENDED complaint by Tee Turtle, LLC. against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations identified on Schedule A of the Complaint

Exhibit 1 - Copyrights

Exhibit 2 - Trademarks

(Amended Schedule A Slip Sheet)

SEALED DOCUMENT by Plaintiff Tee Turtle, LLC. - Amended Schedule A

MEMORANDUM by Tee Turtle, LLC. in Support of Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

MOTION by Plaintiff Tee Turtle, LLC. for leave to file excess pages Regarding Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

(Exhibit A)

DECLARATION of Samantha Parrish regarding memorandum 13

Exhibit 1 - Jan 2011 MarkMonitor

Exhibit 2 - IP Rights Seizure Statistics

Exhibit 3 - BASCAP Report

Exhibit 4 - ICANN Registrar Accreditation Agreement

Exhibit 5 - Hague Convention of Service Abroad

(Exhibit 6 - Translation of Civil Procedure Law of the People of China)

DECLARATION of Lisa Gajjar regarding memorandum 13

Exhibit 1 - Copyrights

(Exhibit 2 - Trademarks)

SEALED DOCUMENT by Plaintiff Tee Turtle, LLC. - Exhibit 3 to Declaration of Lisa Gajjar (Part 1 of 2)

(Exhibit 3 (Part 2 of 2))

MOTION by Plaintiff Tee Turtle, LLC. for leave to appear as Attorney

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's sealed motions 7, 12, motion to exceed page limitation 14, and motion for leave to appear as attorney 18 are stricken for failure to comply with LR 5.3 and this Court's standing orders, which require all motions to be noticed up for presentment before this Court. Mailed notice.

ATTORNEY Appearance for Plaintiff Tee Turtle, LLC. by Jon Robert Neuleib

MOTION by Plaintiff Tee Turtle, LLC. for leave to file excess pages

(Exhibit A)

Notice of Presentment for Dkt. Entries 21, 22, and 23 NOTICE of Motion by Jon Robert Neuleib for presentment of motion for leave to file excess pages 23 before Honorable Sharon Johnson Coleman on 5/6/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 5/6/2025. After the Cout heard presentment by plaintiff's counsel as to their sealed motions 21, 22 and motion for leave to file excess pages 23. The Court gives plaintiff leave to file an updated memorandum in support of joinder. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: An in-person status hearing is set for 7/17/2025 at 10:15 AM. Mailed notice.

TRANSCRIPT OF PROCEEDINGS held on 5/6/2025 before the Honorable Sharon Johnson Coleman. Order Number: 52231. Court Reporter Contact Information: TRACEY D. McCULLOUGH, 312-435-5570, tracey_mccullough@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 7/31/2025. Redacted Transcript Deadline set for 8/11/2025. Release of Transcript Restriction set for 10/8/2025.

SEALED DOCUMENT by Plaintiff Tee Turtle, LLC. Amended Schedule A to Complaint

MINUTE entry before the Honorable Sharon Johnson Coleman: Status hearing held on 7/17/2025. Counsel for plaintiff reported that the Amended Schedule A has reduced the number of defendants. Plaintiff's sealed motions 21, 22, and motion to exceed page limitation 23 are granted. Enter Order. An in-person status hearing is set for 8/25/2025 at 10:15 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 7/17/2025. Mailed notice.

AMENDED SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 7/22/2025. Mailed notice.

MOTION by Plaintiff Tee Turtle, LLC. to withdraw sealed document[28], sealed document[8], SEALED Order[30]

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's motion to withdraw Schedule A (ECF No. 8), Amended Schedule A (ECF No. 28), and Sealed Temporary Restraining Order (ECF No. 30) [34] is granted. The Clerk of Court is directed to remove from the case docket documents [8], [28], and [30]. No appearance necessary on 8/5/2025. Mailed notice.

MOTION by Plaintiff Tee Turtle, LLC. for extension of time for TRO

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 8/5/2025. Plaintiff's sealed motion [38] is granted. The Temporary Restraining Order is extended to 8/19/2025. An in-person status hearing is set for 8/15/2025 at 10:00 AM. Status hearing set for 8/25/2025 is stricken. Mailed notice.

MOTION by Plaintiff Tee Turtle, LLC. to withdraw sealed document[11]

MOTION by Plaintiff Tee Turtle, LLC. for preliminary injunction and to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 8/15/2025. Plaintiff's motion to extend the temporary restraining order [48] is granted. The Temporary Restraining Order is extended to September 2, 2025. An in-person status hearing is set for 8/29/2025 at 10:00 AM. Plaintiff's motion for entry of a preliminary injunction [48] is entered and continued. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 8/29/2025. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction [48] is granted. Enter Order. An in-person status hearing is set for 10/6/2025 at 10:00 AM. Law Firm of Boies Schiller Flexner LLP is ordered to add ALL Defendant names listed in the Amended Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Sharon Johnson Coleman on 8/29/2025. Mailed notice.

MOTION by Plaintiff Tee Turtle, LLC. for default judgment as to the Defendants identified on the Third Amended Schedule A