2025-cv-03067

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23246171.

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]

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

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 Andrea R. Wood. 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: BESRXXS, MOJICK, Ramdjalo, Waasmia and YAOMEI 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 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 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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal [4], motion for electronic service of process pursuant to FRCP 4(f)(3) [12], motion to exceed page limitation [13], and ex parte motion for entry of a temporary restraining order [14] are set for a telephonic motion hearing on 4/23/2025 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 4/23/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [4], motion for electronic service of process pursuant to FRCP 4(f)(3) [12], motion to exceed page limitation [13], and ex parte motion for entry of a temporary restraining order [14] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Sealed complaint [2], and (2) Exhibit 1 to the Declaration of K. Kuhn [5]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 3:00 p.m. on 4/25/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 5/9/2025 at 9:15 AM. [Note Date Change]. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 4/25/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) BESRXXS and the Other 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 BESRXXS and the Other The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

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 to deposit funds into Court Registry

Exhibit Registry Deposit Information Form

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time First Request 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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's first motion to extend the temporary restraining order [22] is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 5/23/2025. Telephonic status hearing set for 5/9/2025 is stricken and reset for 5/23/2025 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Hong Kong Leyuzhen Technology Co. Limited

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

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION

Declaration of J. Droter in Support of Motion for Preliminary Injunction

Exhibit 1 to the Declaration of J. Droter

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for preliminary injunction [25] will be heard at the telephonic hearing set for 5/23/2025 at 9:30 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 5/23/2025. For the reasons stated on the record, Plaintiff's motion for preliminary injunction [25] is granted. Enter Preliminary Injunction Order. Plaintiff's anticipated motion for default and default judgment shall include a spreadsheet that identifies up-to-date information on the amounts that are being restrained for each of the remaining defendants. The Clerk's Office is directed to unseal: (1) Sealed complaint [2], (2) Exhibit 1 to the Declaration of K. Kuhn [5], and (3) the sealed temporary restraining order [17]. Plaintiff's counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Plaintiff's motion for leave to deposit funds into court registry [21] is terminated as moot. Telephonic status hearing set for 6/17/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 5/23/2025. Mailed notice

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited ONLY as to Defendant 1

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 4 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

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/17/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against the identified Schedule "A" defendants [30] is taken under advisement. Telephonic status hearing set for 7/1/2025 at 10:45 AM. [Note Time Change]. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment against the identified Schedule "A" defendants [30] is granted. Enter Default Judgment Order. As all claims as to all Defendants have now been resolved. This case will be closed. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 6/30/2025. Mailed notice