2025-cv-03649

COMPLAINT filed by Iron Maiden Holdings Limited ; Filing fee $ 405, receipt number AILNDC-23304867.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Iron Maiden Holdings Limited Schedule A regarding complaint 1

MOTION by Plaintiff Iron Maiden Holdings Limited for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Iron Maiden Holdings Limited

Notice of Claims Involving Trademarks by Iron Maiden Holdings Limited

ATTORNEY Appearance for Plaintiff Iron Maiden Holdings Limited by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Iron Maiden Holdings Limited by Alexander Whang

ATTORNEY Appearance for Plaintiff Iron Maiden Holdings Limited by Sydney Paige Fenton

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Young B. Kim. 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: [REDACTED] added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

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

AMENDED complaint by Iron Maiden Holdings Limited against [REDACTED]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Iron Maiden Holdings Limited Schedule A regarding amended complaint 13

MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 05/02/2025 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the ***ATTACHED*** status report requirements (do ***not*** use templates from other cases) by 04/23/2025. Plaintiff must still file the report even if Defendants have not responded to requests to craft a joint report. If not all Defendants have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel (or the parties, if proceeding pro se) must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel (or the party, if proceeding pro se) must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice (Attachment: # 1 Status Report Requirement)

MOTION by Plaintiff Iron Maiden Holdings Limited for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Iron Maiden Holdings Limited in support of motion for miscellaneous relief 16

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Stewart Miller regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Iron Maiden Holdings Limited Exhibit 3, Part 1 regarding declaration 18

(Exhibit 3, Part 1)

MOTION by Plaintiff Iron Maiden Holdings Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Iron Maiden Holdings Limited in support of motion for miscellaneous relief 20

Declaration of Martin F. Trainor

(Exhibit 1)

STATUS Report by Iron Maiden Holdings Limited

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion [16] for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 15 U.S.C. § 1117(a) (and for the copyright claim, under 17 U.S.C. § 504(b)), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, trademark owners need only "prove defendant's sales only; defendant must prove all elements of costs or deduction claimed." 15 U.S.C. § 1117(a). And the analogous principle applies to the copyright claim under 17 U.S.C. § 504(b). To the extent that the restraint might be too broad, the Defendant may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion [3] for leave to file under seal is granted in light of the asset-restraint goal. By 05/02/2025, the Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the names of Defendants and omitting Amended Schedule A). The Plaintiff's motion [20] for electronic service of process is granted. To track the case only (no appearance is required, the case will not be called), the tracking status set for 05/02/2025 is reset to 05/09/2025 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion), if appropriate to do so, no later than 05/02/2025. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 04/25/2025. Emailed notice

SURETY BOND in the amount of $ 1,000.00 posted by Iron Maiden Holdings Limited. (Document not imaged)

MOTION by Plaintiff Iron Maiden Holdings Limited to Extend the Temporary Restraining Order

MEMORANDUM by Iron Maiden Holdings Limited in support of motion for miscellaneous relief[25]

Declaration of Martin F. Trainor

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[25] before Honorable Edmond E. Chang on 5/7/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the initial TRO, the Plaintiff's motion to extend the TRO [25] is granted through 05/23/2025. The tracking status hearing of 05/09/2025 is reset to 05/23/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the Plaintiff shall file, if appropriate, the preliminary injunction motion by 05/16/2025, and the parties (or the Plaintiff if the Defendant has not appeared) shall file the joint status report by 05/23/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) [REDACTED] by Plaintiff Iron Maiden Holdings Limited

SUMMONS Issued (Court Participant) as to Defendant [REDACTED]

SUMMONS Returned Executed by Iron Maiden Holdings Limited as to [REDACTED] on 5/16/2025, answer due 6/6/2025.

Declaration of Alexander Whang

Exhibit A

MOTION by Plaintiff Iron Maiden Holdings Limited for preliminary injunction

Exhibit A

Exhibit 1

MEMORANDUM by Iron Maiden Holdings Limited in support of motion for preliminary injunction[33]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction[33] before Honorable Edmond E. Chang on 5/21/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion 33 for preliminary injunction is granted. Given the answer deadline of 06/06/2025, the tracking status hearing of 05/23/2025 is reset to 06/20/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 06/13/2025. If the Defendant does not answer on time, then the Defendant is deemed to be in default and the Plaintiff shall instead file a motion for default judgment by 06/13/2025. Mailed notice. (jn,)

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Edmond E. Chang on 5/20/2025. Mailed notice. (jn,)

NOTICE of Voluntary Dismissal by Iron Maiden Holdings Limited as to a certain defendant

MINUTE entry before the Honorable Edmond E. Chang: Pursuant to the notice of voluntary dismissal, under Federal Rule of Civil Procedure 41(a)(1)(A)(i), the case is dismissed without prejudice. Status hearing of 06/20/2025 is vacated. Civil case terminated. Mailed notice.