2025-cv-02969

COMPLAINT filed by Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork; Filing fee $ 405, receipt number AILNDC-23236981.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Yanling Jiang

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Yi Bu

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Adam Grodman

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork by Christopher Romero

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Jantz & Jantz GbR d/b/a Anita's & Bella's Art/Artwork

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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: ReenRuuo and SunSing added to case caption. Terminating The Partnerships and Unincorporated Associations Identified on Schedule A

MAILED Copyright report to Registrar, Washington DC

SEALED DOCUMENT by Plaintiff Jantz & Jantz GbR [Amended] Schedule A to the Complaint [1] and Schedule A [2]

MOTION by Plaintiff Jantz & Jantz GbR for leave to file under seal

MOTION by Plaintiff Jantz & Jantz GbR 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 Anita Jantz

Exhibit 1, of Anita Jantz's declaration

SEALED EXHIBIT by Plaintiff Jantz & Jantz GbR Sealed Exhibit 2, Declaration of Anita Jantz regarding memorandum in support of motion, [17]

MEMORANDUM Establishing that Joinder is Proper

Exhibit 1

Presentment for [16] Exparte motion and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file[14], motion for leave to file excess pages[15] before Honorable Edmond E. Chang on 3/27/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of the joinder filings, R. 18, 19, joinder is proper for the remaining two Defendants because the used the same unique name for their online store, same unique serial number for the product, and same unique 17-word advertising text comprised of words in a random sequence. (2.) In this copyright-infringement case, the Plaintiff's motion [16] for temporary restraining order and other relief (including electronic service of process) 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 motion [14] for leave to file under seal is granted in light of the asset-restraint goal. The motion [15] for extra pages is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 04/04/2025 at 8:30 a.m. The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 03/31/2025. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 03/26/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 3/26/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) ReenRuuo and all other Defendants identified in the Complaint by Plaintiff Jantz & Jantz GbR

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

MOTION by Plaintiff Jantz & Jantz GbR for extension of time of the Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time[26] before Honorable Edmond E. Chang on 4/4/2025 at 08:30 AM.

INJUNCTION BOND in the amount of $2,000 posted by Jantz & Jantz GbR (Document not scanned).

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the Plaintiff's extension motion on the TRO [26] is granted through 04/23/2025. The tracking status hearing of 04/04/2025 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 parties shall file a status report by 04/18/2025. The Plaintiff shall file, if appropriate, the motion for preliminary injunction by 04/18/2025. Emailed notice

MOTION by Plaintiff Jantz & Jantz GbR for preliminary injunction

MEMORANDUM by Jantz & Jantz GbR in support of motion for preliminary injunction[30]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's declaration

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction[30] before Honorable Edmond E. Chang on 4/9/2025 at 08:30 AM.

SUMMONS Returned Executed by Jantz & Jantz GbR as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/2/2025, answer due 4/23/2025.

Declaration of Service

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 30 is granted. Given the answer deadline of 04/23/2025, R. 33, the tracking status hearing of 04/25/2025 is reset to 05/09/2025 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 the joint initial status report by 05/02/2025. If the Defendants have not answered by the answer deadline, then they shall be deemed in default and the Plaintiff shall file a motion for default judgment on 05/09/2025 instead of the report. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 04/03/2025. Emailed notice

MOTION by Plaintiff Jantz & Jantz GbR for default judgment as to the Defendants Identified in the [Amended] Schedule A

MEMORANDUM by Jantz & Jantz GbR in support of motion for default judgment[36]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[36] before Honorable Edmond E. Chang on 5/9/2025 at 08:30 AM.

ATTORNEY Appearance for Defendant SunSing by Yizhou Liu

MOTION by Defendant SunSing for extension of time to file answer or Otherwise Respond to Complaint (Unopposed)

MINUTE entry before the Honorable Edmond E. Chang: Defendant SunSing's unopposed extension motion to respond to the complaint 40 is granted to 05/05/2025. Emailed notice

STATUS Report by Jantz & Jantz GbR

MINUTE entry before the Honorable Edmond E. Chang: On review of the status report, R. 42, the Plaintiff and Defendant SunSing have agreed to a settlement in principle. Those parties shall promptly finalize the settlement and enter the stipulated dismissal. The Court takes the default-judgment motion 36 as to Defendant ReenRuuo under advisement. The tracking status hearing of 05/09/2025 is reset to 06/02/2025 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 a status report by 05/23/2025 (if a stipulate dismissal has been filed as to SunSing, then that defendant need not participate in the status report). Emailed notice

MOTION by Plaintiff Jantz & Jantz GbR for Consent Judgment and Permanent Injunction as to Defendant No. 2 SunSing [AGREED]

NOTICE of Motion by Keith A. Vogt for presentment of motion for miscellaneous relief[44] before Honorable Edmond E. Chang on 5/22/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: The agreed motion [44] to enter consent judgment and permanent injunction as to Defendant No. 2 SunSing is granted. The order of consent judgment and permanent injunction shall be entered. Mailed notice. (jn,)

CONSENT JUDGMENT and PERMANENT INJUNCTION. Signed by the Honorable Edmond E. Chang on 5/21/2025. Mailed notice. (jn,)

STATUS Report by Jantz & Jantz GbR

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely answer as to Defendant ReenRuuo, the default judgment motion against that Defendant [36] is granted. Judgment entered in favor of the Plaintiff and against Defendant ReenRuuo in the amount of fifteen-thousand dollars ($15,000). Given the willfulness established by the default, a permanent injunction shall be entered. A separate AO-450 judgment shall be entered. The status hearing of 06/02/2025 is vacated. Civil case terminated. Emailed notice

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 05/27/2025. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 05/27/2025. Emailed notice

EMAILED copyright report with certified copy of minute order dated 5/27/25 to Registrar, Washington DC

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 2 SunSing