2025-cv-03065

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23246062.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Complaint for Copyright Infringement regarding complaint, [1]

CIVIL Cover Sheet

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited 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. Limited Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal [4]

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Gokalp Bayramoglu

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Maria Valdez. 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: LMSXCT, ZonJie and LalaLin added to case caption.

MAILED Copyright report to Registrar, Washington DC

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 Declaration for Electronic Servic

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 Motion for Temporary Restraining Order

Declaration of Katherine M. Kuhn in Support of Motion for Temporary Restraining

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[13], motion for temporary restraining order, [14], motion to seal, [4], motion for service by publication, [12] before Honorable Manish S. Shah on 4/22/2025 at 09:45 AM.

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 4/16/2025, answer due 5/7/2025.

NOTICE of Correction [16].

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [4] [12] [13] [14] are granted in part, and no appearance on the motions is necessary. The court declines to issue any asset restraint and declines to allow plaintiff's copyright to be sealed. The TRO is limited to enjoining the infringing use of copyrighted images, and authorizing early and expedited discovery in aid of identifying defendants. The clerk shall unseal [2] and [2-1]. Docket entries [2-2] and [2-3] may remain under seal until the expiration of the TRO. Security is set at $3,000, to be posted within one week. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 4/21/2025. Notices Mailed.

SUMMONS Submitted (Court Participant) for defendant(s) THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A HERETO by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

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

Exhibit Registry Deposit Information Form

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time Plaintiff's First Motion to Extend Temporary Restraining Order

Exhibit Memorandum in Support of Motion to Extend Temporary Restraining Order

Declaration of Joseph W. Droter in Support of Motion to Extend Temporary Restrai

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of extension of time, [23] before Honorable Manish S. Shah on 5/7/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motions to deposit funds [22] and for an extension of time [23] are granted, and no appearance is necessary. The TRO is extended to 5/19/25. Plaintiff, through counsel Bayramoglu Law Offices, LLC, shall deposit with the Court three thousand dollars ($3,000.00), either cash, check, cashiers' check, certified funds, or surety bond, as security to be held in the Court Registry. Notices Mailed.

SURETY BOND in the amount of $ 3,000.00 posted by Hong Kong Leyuzhen Technology Co. Limited. (Document not imaged) (Received at the Intake Counter on 05/02/2025)

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 5/5/2025, answer due 5/26/2025.

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

Exhibit Memorandum in Support of Motion for 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, [28] before Honorable Manish S. Shah on 5/15/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 28 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 5/15/2025. Notices Mailed.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 3 Defendants

Exhibit Memorandum in Support of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn in Support of Motion for Default and Default Ju

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Motion for Default and Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [32] before Honorable Manish S. Shah on 6/10/2025 at 09:45 AM.

ATTORNEY Appearance for Defendant LMSXCT by Adam Edward Urbanczyk

MOTION by Defendant LMSXCT for extension of time

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time[35] before Honorable Manish S. Shah on 6/10/2025 at 09:45 AM.

ATTORNEY Appearance for Defendant LMSXCT by Brian Swift

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motion for extension of time [35] is granted, with no objection. Defendant LMSXCT must respond to the complaint by 6/30/25. For the reasons stated in open court, the motion for entry of default judgment [32] is granted. No attorneys' fees are awarded in connection with this action. Enter the revised Default Judgment Order. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 6/10/2025. Notices Mailed.

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited ONLY as to Defendant 2

FULL SATISFACTION of Judgment regarding order[39] ONLY as to Defendant 3