2025-cv-03262

COMPLAINT filed by Those Characters from Cleveland, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23265493.

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by John Wilson

MOTION by Plaintiff Those Characters from Cleveland, LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Those Characters from Cleveland, LLC

Notice of Claims Involving Trademarks by Those Characters from Cleveland, LLC

CASE ASSIGNED to the Honorable April M. Perry. Designated as Magistrate Judge the Honorable Daniel P McLaughlin. 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.

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

EMAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Honorable April M. Perry: laintiff's Motion to Seal 7 is granted. It appearing that the case filed is a "Schedule A" case, Plaintiff is directed to the Court's standing order on its website directing the filing of the Court's Schedule A Template within 14 days. Upon review of the complaint, the Court sua sponte raises the propriety under Federal Rule of Civil Procedure 20(a)(2) of joining 50 defendants to this action. See, e.g, Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). When addressing joinder, Plaintiff is reminded that "[c]ourts in this district generally agree that alleging that multiple defendants have infringed on the same copyright in the same way does not create the substantial evidentiary overlap required to find a similar transaction or occurrence." See Roadget Bus. Pte. Ltd. v. Individuals, Corps, Ltd. Liab. Companies, Partnerships & Unincorporated Associations Identified on Schedule A, No. 23-cv-17036, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) (collecting cases). Plaintiff should also reference this Court's opinion in Zaful v. Schedule A Defs., 24-cv-11111, Doc. 12 (N.D. Ill. Jan. 10, 2025), where the Court expressed its views on joinder in such cases. By 4/11/2025, the plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the principles described above. In the alternative, plaintiff has leave to file an amended complaint by 4/11/2025 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Mailed notice. (jcc,)

AMENDED complaint by Those Characters from Cleveland, LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Amended Schedule A

MEMORANDUM by Those Characters from Cleveland, LLC Plaintiff's Memorandum in Support of Joinder

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit A

MINUTE entry before the Honorable April M. Perry: The Court finds that joinder of the three remaining defendants is proper at this stage based on representations made within plaintiff's memorandum on joinder 17. Plaintiff is also reminded to complete the Court's Schedule A Template, which can be found on the Court's website. Mailed notice. (jcc,)

MOTION by Plaintiff Those Characters from Cleveland, LLC Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MOTION by Plaintiff Those Characters from Cleveland, LLC to expedite Plaintiff's Motion for Expedited Discovery

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Schedule A Supplement

NOTICE of Motion by Michael A. Hierl for presentment of motion for miscellaneous relief 20, motion to expedite 21 before Honorable April M. Perry on 8/27/2025 at 10:00 AM.

MINUTE entry before the Honorable April M. Perry: Plaintiff's motions for Electronic Service of Process 20 and Expedited Discovery 21 are granted. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with an online marketplace defendant. Expedited discovery is warranted to identify Defendant. The Court strikes the motion hearing set for 8/27/2025. Enter order. Mailed notice. (jcc,)

ORDER for Leave to Conduct Expedited Discovery and Service of Process by E-Mail and/or Electronic Publication. Signed by the Honorable April M. Perry on 8/22/2025. Mailed notice. (jcc,)

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