2025-cv-03551

COMPLAINT filed by Spin Master Ltd., Spin Master, Inc.; Filing fee $ 405, receipt number AILNDC-23293673.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Spin Master Ltd., Spin Master, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiffs Spin Master Ltd., Spin Master, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Spin Master Ltd., Spin Master, Inc.

Notice of Claims Involving Trademarks by Spin Master Ltd., Spin Master, Inc.

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master, Inc. by Amy Crout Ziegler

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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: 2511sfws, A1HDVJ35955CU1, A1HPUCVUTEUEV3, A1JG8EC0XY01B9, A1SC4DCB6UYOEQ, A1YTURTG0NBKA7, A34J0WWJO10J3Y, A38J9SQW4IVTSK, A3GB9CXA3NS3KK, A3JJPRQ8ORRC7Z, A3JWAA0OFCR2DK, A3QU48IBF8G8XV, aayouli, American Sea, AYVKU74IK6D1T, baifushengshangmao, BaoDingKuaBenShangMaoYouXianGongSi, Be first1, ChangChunShiAnT19, chengdutongrunzhishangmaoyouxiangongsi, chenpengya, DaYe88, dinganxiaqiaminshangmaoyouxiangongsi, Fangnianf, FUYU, ghwdsfgare, GOUMEIHUI, guangzhoubangshaishangmaoyouxiangongsi, guangzhouliangyangmaoyiyouxiangongsi, guangzhouruansanshangmaoyouxiangongsi, guangzhouwangyadianzishangwuyou, GuangZhouYiFanDianZiShangWuYouXianGongSi, GuangZhouYingFeiShangMaoYouXianGongSi, guangzhouyuanxiandianzishangwuyouxiangongsi, guangzhouzhujingkejigongzuoshigerenduzi2, guchengxianruantishangmaoyouxiangongsi, guoyif, HAHUYEN STORE, haikoushiguanyuchenshangmaoyouxiangongsi, hainanhaikouyuanbao, Happiparti-US, HeShui-US, HO HO HO VCMTRYE, HolidaySale, hongdongxiancheng, HONG-TE, HRXWZF, aoqing-tech, ArdorTee, BLAMM, Boxu Home Textiles, cinanfushi, Cosy Blankets, Customised Blankets, For kids clothing, ghshop, Global trade home textiles, han qi yi, haoyushandian, Happy Gathering Shop, happychild clothing, Jin mu lai home textiles, KAWAYI Art, KK childrens wear, La Mi Kids, lifeluckyon, Limeiqun, LNT FCustom, Lucky Global Shopping, Newest Blankets, Niceeee Mens Clothing, Rainbow SHOW, RSQtop, Sarlo, shimingchuanquantuo, SUNDAY RAINBOW, Sunshine Monica, teeing, TEMUCJ, TextileTreasures, WEI kkt, Whale grapefruit, Xi Yan Home textiles, XiaoGao applique, Xiaoyexixi, Zhao ZF, atyunb, changshashiyingyou, chenwangshangmaoyouxian, Co Dtian, foshanshihuiguihaoyunshangmao, guangzhouruleishiyouyouxiangongsi, GUZHEN, lichengweiyujimao, Lihao medical equipment coltd, mingchaodianzi, Teraluxe Inc., ToyssHi, WEI XU, YH Commerce Co.Ltd and YKHSG store added to case caption.

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master, Inc. by Rachel Ackerman

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

ATTORNEY Appearance for Plaintiffs Spin Master Ltd., Spin Master, Inc. by Christopher S Hermanson

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiffs Spin Master Ltd., Spin Master, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Spin Master Ltd., Spin Master, Inc. in support of motion for temporary restraining order[16]

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

DECLARATION of Susanne Teixeira regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Spin Master Ltd., Spin Master, Inc. Exhibit 3 regarding declaration[19]

MOTION by Plaintiffs Spin Master Ltd., Spin Master, Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Spin Master Ltd., Spin Master, Inc. in support of motion for miscellaneous relief[21]

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

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [16] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [21] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 4/8/2025. Mailed notice.

Registry Deposit Information Form by Spin Master Ltd., Spin Master, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiffs Spin Master Ltd., Spin Master, Inc.

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

SURETY BOND in the amount of $ 5,000 posted by Spin Master Ltd., Spin Master, Inc. (Document not scanned)

MOTION by Plaintiffs Spin Master Ltd., Spin Master, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Spin Master Ltd., Spin Master, Inc. in support of motion for preliminary injunction[31]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[32]

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [31] is set for 4/22/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

SUMMONS Returned Executed by Spin Master Ltd., Spin Master, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/17/2025, answer due 5/8/2025.

Declaration of Rachel M. Ackerman

Exhibit A

MINUTE entry before the Honorable Thomas M. Durkin: The telephone hearing as to the motion for preliminary injunction [31] set for 4/22/2025 at 9:15 a.m. is reset for 9:45 a.m. Time change only. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 4/22/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 31 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Seller Aliases screenshots attached to the Declaration of Susanne Teixeira 20, and the TRO 26. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 5/29/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 4/22/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Spin Master Ltd., Spin Master, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Spin Master Ltd., Spin Master, Inc. as to certain defendants

MOTION by Plaintiffs Spin Master Ltd., Spin Master, Inc. for entry of default, MOTION by Plaintiffs Spin Master Ltd., Spin Master, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Spin Master Ltd., Spin Master, Inc. in support of motion for entry of default, motion for default judgment, [41]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 5/29/2025 at 9:15 a.m. is converted to a telephone hearing as to the motion for entry of default and for default judgment 41. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 5/29/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and default judgment 41 is granted. Enter order. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 5/29/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $200,000 as to certain defendants

Full SATISFACTION of Judgment regarding order[46] in the amount of $200,000 as to certain defendants