2025-cv-02917

COMPLAINT filed by Those Characters from Cleveland, LLC; Filing fee $ 405, receipt number AILNDC-23232001.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Yi Bu

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Christopher Romero

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.

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file under seal

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file excess pages

MEMORANDUM in support of [13] Exparte motion

Declaration of Keith A. Vogt

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

Declaration of Sean Gorman

Exhibit 1, of Sean Gorman's declaration

Exhibit 2, of Sean Gorman's declaration

SEALED EXHIBIT by Plaintiff Those Characters from Cleveland, LLC Sealed Exhibit 2, Declaration of Sean Gorman regarding memorandum in support of motion, [14]

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

MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff has filed a complaint alleging infringement by 47 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. 20 is rarely appropriate in Schedule A cases. See, e.g., Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27 (N.D. Ill. Nov. 18, 2024). Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder on or before April 4, 2025. Alternatively, by the same date, the plaintiff may file an amended complaint naming one or more defendants; however, if the plaintiff names multiple defendants, the plaintiff must show that joinder of those defendants is proper. All pending motions are hereby stayed pending resolution of the joinder issue. Mailed notice.

Entered in error. Modified by Court's staff.

Amended Schedule A to Complaint [1] and Schedule A [2] by Those Characters from Cleveland, LLC

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file for Leave to Conduct Expedited Discovery and Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(F)(3)

MEMORANDUM in Support of [20] Exparte Motion

Exhibit 1

Declaration of Keith A. Vogt

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

NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file[20] before Honorable Jeremy C. Daniel on 4/3/2025 at 09:30 AM.

MEMORANDUM in Support of [23] Exparte Motion [CORRECTED]

Exhibit 1

Declaration of Keith A. Vogt

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

Presentment for [Corrected] Exparte Motion [23] NOTICE of Motion by Keith A. Vogt for presentment of before Honorable Jeremy C. Daniel on 4/3/2025 at 09:30 AM.

ORDER FOR LEAVE TO CONDUCT EXPEDITED DISCOVERY AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION. Signed by the Honorable Jeremy C. Daniel on 4/1/2025. Corrected plaintiff's ex parte motion for leave to conduct expedited discovery [23] is granted. Motion for leave to conduct expedited discovery and electronic service of process [20] is denied as moot. The motion hearing is stricken. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) MUrsmart by Plaintiff Those Characters from Cleveland, LLC

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

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/7/2025, answer due 4/28/2025.

(Declaration of Service)

MOTION by Plaintiff Those Characters from Cleveland, LLC for default judgment as to the Defendant Identified in the [Amended] Schedule A

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for default judgment[30]

Exhibit 1

Exhibit 2

Declaration of Sean Gorman

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[30] before Honorable Jeremy C. Daniel on 5/6/2025 at 09:30 AM.

DEFAULT FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 5/6/2025. Motion hearing held. Plaintiff's motion for entry of default and default judgment 30 is granted. Civil case terminated. Mailed notice.