2025-cv-03099

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-23250439.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Hannah A. Abes

Exhibit A

Exhibit A- Infringing Evidence Provided

Exhibit List

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint[1]

Exhibit 2

Exhibit 2

Exhibit A

Declaration of Jiali Wu

Exhibit 2

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

Exhibit 1 Home Brilliant Accused Sales

CIVIL Cover Sheet

Exhibit 2 Home Brilliant Restrained Balance

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

Exhibit A Home Brilliant Accuse Product

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal [3] is granted.Mailed notice

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

DECLARATION of Michael Moore regarding memorandum in support of motion[16]

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 3 - Parts 1-2 regarding declaration[18]

MOTION by Plaintiff Mattel, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[15], motion for miscellaneous relief[20] before Honorable Charles P. Kocoras on 4/1/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for a temporary restraining order [15] and motion for electronic service of process [20] are granted. Enter Temporary Restraining Order. Presentment hearing scheduled on 4/1/2025 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 3/27/2025. Mailed notice.

Registry Deposit Information Form by Mattel, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mattel, Inc.

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

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

MINUTE entry before the Honorable John F. Kness: On the Court's initiative, all pending motions are held in abeyance, and the case is stayed pending further order. This stay, which the Court is entering in other so-called "Schedule A" cases on its docket where requests for temporary restraining orders remain pending, is intended to permit the Court the opportunity to reassess its previous approach in Schedule A litigation involving Lanham Act, Copyright Act, and Patent Act claims typically brought on an ex parte basis against various online merchants. This reassessment will consider, among other things, whether: (1) ex parte proceedings are appropriate in these types of cases; (2) the routine sealing of parts or all of the docket is appropriate; (3) the routine granting of temporary restraining orders on an ex parte basis is a sound exercise of judicial discretion; (4) the routine granting of prejudgment asset restraints is a sound exercise of judicial discretion; and (5) the mass joinder of defendants is appropriate under the circumstances typically present in Schedule A cases. Plaintiff remains free, of course, to dismiss this action voluntarily if they wish to pursue their claims in another District, but no supplemental briefing on the pending motions may be filed absent advance leave of Court. Mailed notice.

MOTION by Plaintiff Mattel, Inc. for leave to file Motion to Extend Temporary Restraining Order Instanter

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time 32

DECLARATION of Rachel S. Miller regarding memorandum in support of motion 33

ATTORNEY Appearance for Defendant Home Brilliant by Steven G Kalberg

SURETY BOND in the amount of $ 10,000 posted by Mattel, Inc. (Document not scanned)

ATTORNEY Appearance for Defendant BYWIN by Shaoyi Che

ATTORNEY Appearance for Defendant BYWIN by Zhongyi Huang

MINUTE entry before the Honorable John F. Kness: Plaintiff's Motion for Leave to File Motion to Extend Temporary Restraining Order 31 and Motion to Extend Temporary Restraining Order 32 are granted. Enter separate order. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 4/8/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction[42]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[43]

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/21/2025, answer due 5/12/2025.

ATTORNEY Appearance for Defendants shen zhen shi chao ke fang ke ji you xian gong si, MC toy by Jianyin Liu

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion [42] for entry of a preliminary injunction. In connection with that motion, which is entered and continued, Plaintiff must forthwith serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects on or before 5/2/2025." Plaintiff must file proof of service of the Court's statement within two business days of service. For the reasons stated in the Court's order's entering and extending the temporary restraining order ("TRO"),[as well as in Plaintiff's earlier motion [32] [33] to extend the TRO, the TRO is further extended to and including the date on which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff Mattel, Inc. regarding text entry, [48]

ATTORNEY Appearance for Defendant JELLYMONI HOME by Steven G Kalberg

Agreed Statement Regarding Briefing Schedule of Plaintiff's Motion for Entry of a Preliminary Injunction [42] by Mattel, Inc.

RESPONSE by MC toyin Opposition to MOTION by Plaintiff Mattel, Inc. for preliminary injunction [42]

RESPONSE by shen zhen shi chao ke fang ke ji you xian gong siin Opposition to MOTION by Plaintiff Mattel, Inc. for preliminary injunction [42]

ANSWER to Complaint with Jury Demand by shen zhen shi chao ke fang ke ji you xian gong si

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant VIKESI by Zhiwei Hua

MOTION by Defendant VIKESI for extension of time to file answer

MOTION by Defendants Home Brilliant, JELLYMONI HOME for extension of time to file answer regarding complaint[1] or otherwise respond

MINUTE entry before the Honorable John F. Kness: Defendant VIKESI's motion for extension of time [58] is granted. Defendant VIKESI must answer or otherwise plead to Plaintiff's complaint on or before 6/2/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to Defendant MC toy

MEMORANDUM by JELLYMONI HOME in Opposition to motion for preliminary injunction[42]

EXHIBIT by Defendant JELLYMONI HOME Accused Product regarding memorandum in opposition to motion[62]

MEMORANDUM by Home Brilliant in Opposition to motion for preliminary injunction[42]

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MINUTE entry before the Honorable John F. Kness: Defendants' Motion for Extension of Time [59] is granted. Defendants Home Brilliant and JELLYMONI HOME must answer or otherwise plead to the complaint on or before 6/11/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. to Extend Briefing Scheduled of Plaintiff's Motion for Entry of a Preliminary Injunction [42] (Unopposed)

MINUTE entry before the Honorable John F. Kness: Plaintiff's Unopposed Motion to Extend Briefing Schedule of Plaintiff's Motion for Entry of a Preliminary Injunction 69 is granted. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Defendant Home Brilliant for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

MINUTE entry before the Honorable John F. Kness: Defendant No. 21 Home Brilliant's Motion for a Second Extension of Time to Answer or Otherwise Respond to Plaintiff's Complaint [72] is granted. Defendant No. 21 Home Brilliant must answer or otherwise respond to Plaintiff's complaint on or before 6/25/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment[75]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[76]

ORDER: Plaintiff's motion for entry of default [75] is granted. Plaintiff's motion for preliminary injunction [42] is dismissed as moot. Civil case terminated. Signed by the Honorable John F. Kness on 6/24/2025. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable John F. Kness on 6/24/2025. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED Copyright report to Registrar, Washington DC