2025-cv-03311

COMPLAINT filed by Michael Salcedo; Jury Demand. Filing fee $ 405, receipt number AILNDC-23270212.

(Exhibit A)(Quezada Hastings, Sofia)

SEALED DOCUMENT by Plaintiff Michael Salcedo Schedule A to Complaint (Quezada Hastings, Sofia)

CIVIL Cover Sheet (Quezada Hastings, Sofia)

ATTORNEY Appearance for Plaintiff Michael Salcedo by Sofia Quezada Hastings (Quezada Hastings, Sofia)

MOTION by Plaintiff Michael Salcedo for leave to file Certain Documents Under Seal (Quezada Hastings, Sofia)

ATTORNEY Appearance for Plaintiff Michael Salcedo by Karolina Jozwiak

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Maria Valdez. 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: Dongguan Yimeiyuan Gifts Co., Lt d., Guangzhou Shangxinsheng Gift Co., Ltd., Shanghai Qianjiu Trading Co., Lt d., Shanghai Zheyi Trading Co., Ltd., Shenzhen Shine Technology Co., L td., Wuhan Linkong Import And Export Co., Ltd., Yangzhou Tong Caiyan Internation al Trade Co., Ltd., Anime Peripheral Store Store, Dorothy Store, Fancy Anime Store, Kids Colorful Store, Lucky House Toy Store, OKALLA Toy Store, QM 6 Jewelry Store, Shop1102764491 Store, Shop1102846821 Store, Shop1104637031 Store, FQTrypd, GIFTRAD, Gogosha's homestore, GracesDawn, HA HUY KHANH01, HDEDRT, morenbaihuomaoyi, pxlrypd, ququwangwang, Roundtra, shen zhen shi xin zhi jia mao yi you xian gong si, yuzhoushizhiyimaoyiyouxiangongsi, ZLNDD, security11, fnaoinfaf, garykenzo, harley201707, moongodd, mototalk2011, pehu_6515, sunshine-639, tuanp98, ygh_54, zhiwa-6556, Australia Gifts, Chamberland Homes, City Kidz Toys, Giftod, Honeylives, Olashirt, plushstore and Seseable added to case caption.

NEW PARTIES: TEES.DESIGN, Toyland EU, Webfishing Plush, woowcool, Handsome outfit, High quality men, LHH shirt, LY Casual mens clothing, Machooy, Tee Era, WUXHS, ZIFAN ART local, aklmy, Anriop, Bailingrui shop, BAOshuiza, ChenJuXiang, Chiyuchao Co., Ltd., chongi, DengChengLin, ENGUAN, FanSyZe, GenuineGoodsHub, guangzhoukaimuxianshangmao, HETUIWLO, hiLiChengQuQianKouRongShangM, JIANXIONG SHOP, lizhengwei0101, maozhandianzishangwu, quanzhoushifengzequxiaonengxindi anzishangwuyouxiangongsi, shallalala, TIEGUZHENGZHENG, Vivay, xinjiuzx, YanTaiLiYiNan, youguansheng, ZhouWenJieWireless and ZRAKCHER added to case caption.

MOTION by Plaintiff Michael Salcedo for temporary restraining order Ex Parte Motion for TRO

MEMORANDUM in Support of its Ex Parte Motion for TRO

(Declaration of Stewart Miller)

SEALED EXHIBIT by Plaintiff Michael Salcedo

Exhibit to Miller Declaration

Exhibit to Miller Declaration

Exhibit to Miller Declaration

Exhibit to Miller Declaration

(Exhibit to Miller Declaration)

MOTION by Plaintiff Michael Salcedo for Electronic Service of Process

Supplement Memorandum in Support

(Declaration of Sofia Hastings)(Quezada Hastings, Sofia)

NOTICE of Motion by Karolina Jozwiak for presentment of motion for miscellaneous relief 10, motion for temporary restraining order 7 before Honorable Manish S. Shah on 4/8/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 5 7 10 are granted, and no appearance on 4/8/25 is necessary. The court limits the asset restraint to funds traceable to the proceeds of sales of infringing products. There are no defendant domain names listed in Schedule A, so the court will not order any domain name transfer. If third-party platforms restrain funds that are not traceable to infringement, plaintiff may be liable to defendant for damages from a wrongful injunction. The court sets security in the amount of $90,000. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 4/7/2025. Notices Mailed.

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

INJUNCTION BOND in the amount of $90,000 posted by Michael Salcedo. (Document not scanned).

MOTION by Plaintiff Michael Salcedo for extension of time of the Temporary Restraining Order

Supplement Memorandum in Support

(Declaration of Karolina Jozwiak)

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 17 is granted. The TRO is extended to 5/5/25. Notices Mailed.

MOTION by Plaintiff Michael Salcedo for preliminary injunction

Supplement Memorandum in Support

(Declaration Declaration of Karolina Jozwiak)

NOTICE of Motion by Karolina Jozwiak for presentment of motion for preliminary injunction 19 before Honorable Manish S. Shah on 5/6/2025 at 09:45 AM.

SUMMONS Returned Executed by Michael Salcedo as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/30/2025, answer due 5/21/2025.

Affirmative Defense. Received By Pro Se Mail On 5/2/25 by Michael Salcedo

Affirmative Defense. Received By Pro Se Mail On 5/2/25 by Michael Salcedo

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction, excluding defendant no. 54, 19 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 5/6/2025. Notices Mailed.

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

ATTORNEY Appearance for Defendant teacherabc.com by Yong Chen

MOTION by Defendant teacherabc.com for extension of time to file answer regarding complaint 1, CONSENTED

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 29 is granted. Defendant 51, teacherabc, has until 6/12/25 to respond to the complaint. Notices Mailed.

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

MOTION by Defendant teacherabc.com for extension of time to file answer regarding complaint 1, CONSENTED (2nd Request)

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 32 is granted. Defendant teacherabc.com has until 7/3/25 to respond to the complaint. Notices Mailed.

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

ATTORNEY Appearance for Defendant Teachersgram by Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Teachersgram

MOTION by Defendant Teachersgram for extension of time to file answer regarding complaint 1 (Unopposed)

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 37 is granted. Defendant Teachersgram has until 7/31/25 to respond to the complaint. Notices mailed.

MOTION by Defendant Teachersgram to Modify Asset Restraint (opposed)

(Declaration)

MINUTE entry before the Honorable Manish S. Shah: The motion to modify asset restraint 40 is denied without prejudice to renewal if plaintiff fails to properly enforce the existing injunction. The injunction 26 restrains only assets traceable to the proceeds of sales of infringing products. The court has not frozen defendant's accounts in their entirety. See 12. The bond of $90,000 is adequate to secure the injunction, and plaintiff will be required to pay damages caused by wrongful restraint. Plaintiff's counsel was ordered to add all defendants to the court's docket within three business days of 5/6/25. Counsel failed to do so. The court considers plaintiff's counsel's lack of diligence when considering statutory damages. All counsel are reminded that any motion must be noticed for in-person presentment on the court's motion call. Notices mailed.

ATTORNEY Appearance for Plaintiff Michael Salcedo by Matthew L. De Preter (De Preter, Matthew)

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

NOTICE of Voluntary Dismissal by Michael Salcedo of Certain Defendants

MOTION by Plaintiff Michael Salcedo for default judgment as to Defaulting Defendants

(Exhibit Schedule A of Defaulted Defendants)

MEMORANDUM by Michael Salcedo in support of motion for default judgment 46

Declaration of Karolina Jozwiak

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Karolina Jozwiak for presentment of motion for default judgment 46 before Honorable Manish S. Shah on 9/18/2025 at 09:45 AM.

ATTORNEY Appearance for Defendant City Kidz Toys by Jennifer Lynn Gordon and Dominick Provisiero, Jr.

MOTION by Defendant Australia Gifts for extension of time. (Received via pro se portal on 09/17/25)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 46 is granted, excluding Defendant No. 45 City Kidz Toys. Plaintiff's claims against City Kidz Toys are dismissed without prejudice, pursuant to settlement, and with leave to reinstate by 9/25/25. If no motion for leave to reinstate has been filed by 9/25/25, then the dismissal shall automatically convert to one with prejudice. Enter Default Judgment order as to all other defendants. Civil case terminated. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 9/18/2025. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 50 is denied. Although defendant Australia Gifts submitted the motion the day before the hearing on plaintiff's motion for default judgment, it was not docketed until after the hearing. Entities are not allowed to appear in United States federal court without an attorney and therefore, the motion is not properly presented. The court expects plaintiff's counsel to continue to negotiate with defendant Australia Gifts and file a satisfaction of judgment if the parties can settle the judgment. The court will consider a properly filed motion to vacate the default judgment against Australia Gifts. See Fed. R. Civ. P. 59(e) and 60(b). Notices Mailed.

FULL SATISFACTION of Judgment in the amount of $10,000 against Certain Defendants (Quezada Hastings, Sofia)