2025-cv-03109

COMPLAINT filed by Sony Interactive Entertainment LLC; Filing fee $ 405, receipt number AILNDC-23251523.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Sony Interactive Entertainment LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sony Interactive Entertainment LLC

Notice of Claims Involving Trademarks by Sony Interactive Entertainment LLC

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Lucas Allen Peterson

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2).

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: NanTongYuanShengBaiFangZhiPin, NBYARTQ, OWNANRTHM, Plum Art Ornament, RBPRIDE, SAFAIRY, SRVOOZ, sunkailedexiaodian, Wall Decoration Shop, wangyingmiaofuzhuangpu, WLHARTT, xiangtingshangdian, BOXIANGTAIFUSHI, YuYaoHouseholdPaper, zhangzhoukafennizhizhipinyouxiangongsi and zhuoqiaodi added to case caption.

NEW PARTIES: MOCVSWO, qichaor, Rod Marion, Splwsm, UMIRIKO, wuyishanshiyimushishangshipinshanghang, JieRuiXing and Wenbin Clothing store added to case caption.

Terminating Rod Marion, Splwsm, UMIRIKO, Wenbin Clothing store, qichaor, wuyishanshiyimushishangshipinshanghang, JieRuiXing and MOCVSWO

MINUTE entry before the Honorable John J. Tharp, Jr: By 4/1/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file under seal [3] is granted in part and denied in part. The motion is granted insofar as it seeks to seal the plaintiff's Schedule A. As such, Schedule A [2], provisionally under seal pending order, is permitted to remain under seal. The motion is denied without prejudice insofar as it seeks the sealing of exhibit 3 to the declaration of Jack Schecter, as that document has not yet been filed. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Sony Interactive Entertainment LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for temporary restraining order[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

DECLARATION of Jack Schecter regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Exhibit 3 - Parts 1-2 regarding declaration[19]

MOTION by Plaintiff Sony Interactive Entertainment LLCfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for miscellaneous relief[21]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

SUPPLEMENT to motion for temporary restraining order[16] per [11]

MOTION by Plaintiff Sony Interactive Entertainment LLC for leave to file under seal (Second)

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for leave to file under seal [25] is granted. As such, exhibit 3 to the declaration of Jack Schecter [20], provisionally under seal pending order, is permitted to remain under seal for the time being. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motions for entry of a TRO [16] and for electronic service of process [21] are taken under advisement. By 4/4/25, the plaintiff is required to supplement its TRO motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. On review of exhibit 3 to the declaration of Jack Schecter, the screenshots do not appear to show a single trademark allegedly infringed by each defendant listed in Schedule A. This raises a question as to the propriety of joinder. Also by 4/4/25, then, the plaintiff is directed to supplement its TRO motion with a brief explaining why joinder is proper notwithstanding the lack of a single trademark common to all defendants. (In other words, the brief should explain why joinder of claims of infringement of different trademarks is appropriate in this case.) If the brief contains new screenshots, those screenshots must be included in (1) the certification, and (2) the index. Alternatively, the plaintiff may amend its complaint to include only defendants alleged to have infringed the same trademark and file a renewed motion for entry of a TRO. Should the plaintiff elect this option, its renewed motion must include (1) a certification, and (2) an index, but it need not include a brief regarding joinder. Mailed notice

AMENDED complaint by Sony Interactive Entertainment LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Amended Schedule A regarding amended complaint[28]

MOTION by Plaintiff Sony Interactive Entertainment LLC for temporary restraining order (Renewed)

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Renewed Exhibit 3 regarding declaration[19]

SUPPLEMENT to motion for temporary restraining order[30] per [27]

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Exhibit 1 regarding supplement[32]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's renewed motion for a TRO [30] is granted. Plaintiff's original motion for a TRO [16] is denied as moot. Plaintiff's motion for electronic service of process [21] is granted. Plaintiff's amended Schedule A [29], renewed exhibit 3 [31], and index [33], provisionally under seal pending order, are permitted to remain under seal. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/3/2025. Mailed notice

Registry Deposit Information Form by Sony Interactive Entertainment LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Sony Interactive Entertainment LLC

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

INJUNCTION BOND in the amount of $24,000 posted by Sony Interactive Entertainment LLC (Document not scanned).

MOTION by Plaintiff Sony Interactive Entertainment LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Sony Interactive Entertainment LLC in support of extension of time[40]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[41]

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary retraining order 40 is granted. Enter Order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/15/2025. Mailed notice

ATTORNEY Appearance for Defendant Quanzhou Jiachen Information Technology Co., Ltd. by Shaoyi Che

MOTION by Plaintiff Sony Interactive Entertainment LLC for preliminary injunction

Exhibit A

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for preliminary injunction[46]

Declaration of Rachel S. Miller

SUMMONS Returned Executed by Sony Interactive Entertainment LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/28/2025, answer due 5/19/2025.

Declaration of Lucas A. Peterson

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [46] is taken under advisement. Any objection or response is due before 5/1/25. Upon review of the declaration of service [48], the Court directs the plaintiff, by 4/29/25, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 5/1/25. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order [31]. Mailed notice

CERTIFICATE of Service by Plaintiff Sony Interactive Entertainment LLC regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, [49]

Exhibit A

Exhibit B

MOTION by Defendant quanzhoushijiachenxinxikejiyouxiangongsi to set a briefing schedule (Opposed)

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant no. 4 has objected to the motion for preliminary injunction against it [46]. The motion to set a briefing schedule [51] is granted. Defendant no. 4's response to the preliminary injunction motion is due 5/7/25; the plaintiff's reply is due 5/14/25. The TRO will be extended against defendant no. 4 beyond the 28-day limit while the motion for preliminary injunction is pending, i.e., until the Court reaches a decision on the motion as to defendant no. 4. This extension is technically a conversion of the TRO to an enforceable preliminary injunction subject to appellate review. H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 844-45 (7th Cir. 2012) (holding that a district court may extend the duration of a TRO beyond the statutory limit and without consent of the enjoined party until it reaches a decision on a preliminary injunction by technically converting the TRO into an enforceable preliminary injunction subject to appellate review). Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, the plaintiff's motion for entry of a preliminary injunction [46] is granted as to all defendants except defendant no. 4. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. The plaintiff is ordered to enter in CM/ECF no later than 5/7/25 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 5/1/2025. Mailed notice

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [55], defendant nos. 1, 6, 8, 10, 13, 17, and 20-21 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [57], defendant nos. 4 and 9 are dismissed from this case. The TRO is terminated as to defendant no. 4, and the deadlines for responses and replies set out in the Court's 4/30/25 order [52] are stricken.Mailed notice

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 59, defendant nos. 12, 14, 19, and 23 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain Defendants

MOTION by Plaintiff Sony Interactive Entertainment LLC for entry of default, MOTION by Plaintiff Sony Interactive Entertainment LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for entry of default, motion for default judgment, [62]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[63]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 61, defendant nos. 3 and 16 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff's motion for entry of default and default judgment 62 is taken under advisement. Any objections or responses are due by 6/6/25. The plaintiff is directed to provide the defendants with notice of the default proceedings against them by 5/29/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Sony Interactive Entertainment LLC regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 66

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [62] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 6/9/2025. Mailed notice

MAILED trademark report with certified copy of minute order dated 6/9/25 to Patent Trademark Office, Alexandria VA.

MAILED copyright report with certified copy of minute order dated 6/9/25 to Registrar, Washington DC.

NOTICE of withdrawal of bond 39 by John Summerfield.