2025-cv-03821

COMPLAINT filed by VIZ Media, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23324906.

Exhibit A

(Exhibit B)

SEALED EXHIBIT by Plaintiff VIZ Media, LLC Schedule A to Complaint regarding complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff VIZ Media, LLC by Karolina Jozwiak

MOTION by Plaintiff VIZ Media, LLC for leave to file Certain Documents Under Seal

ATTORNEY Appearance for Plaintiff VIZ Media, LLC by Sofia Quezada Hastings (Quezada Hastings, Sofia)

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.

Check BOND in the amount of $ 1000 Rcpt. No: 100019068 posted by VIZ Media, LLC

AMENDED complaint by VIZ Media, LLC against Partnerships and Unincorporated Associations Identified in Schedule A, The

Exhibit A

Exhibit B

MOTION by Plaintiff VIZ Media, LLC for temporary restraining order

MOTION by Plaintiff VIZ Media, LLCMotion for Electronic Service of Process

SEALED EXHIBIT by Plaintiff VIZ Media, LLC Amended Schedule A regarding amended complaint[7]

NOTICE of Motion by Karolina Jozwiak for presentment of motion for miscellaneous relief 14, motion for temporary restraining order 11 before Honorable Edmond E. Chang on 4/15/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion 11 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), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. (The same goes for the copyright claims in the case.) 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). 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 5 for leave to file under seal is granted in light of the asset-restraint goal. By 04/21/2025, the Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the name of Defendant and omitting Amended Schedule A). The Plaintiff's motion 14 for electronic service of process is granted for good cause and to provide reasonable notice. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 04/25/2025 at 8:30 a.m. The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 04/21/2025. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 04/14/2025. Emailed notice

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

MOTION by Plaintiff VIZ Media, LLC for extension of time of the Temporary Restraining Order

Supplement Memorandum in Support

(Declaration of Karolina Jozwiak)

MINUTE entry before the Honorable Edmond E. Chang: Given the continued applicability of the facts that justified entry of the initial TRO, the motion 22 to extend the TRO is granted. The TRO is extended through 05/12/2025. The tracking status hearing of 04/25/2025 is reset to 05/09/2025 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 a status report and, if appropriate, a preliminary injunction motion by 05/05/2025. Mailed notice

MOTION by Plaintiff VIZ Media, LLC for preliminary injunction

Supplement Memorandum in Support

(Declaration of Karolina Jozwiak)

NOTICE of Motion by Karolina Jozwiak for presentment of motion for preliminary injunction 24 before Honorable Edmond E. Chang on 5/8/2025 at 08:30 AM.

SUMMONS Returned Executed by VIZ Media, LLC as to Partnerships and Unincorporated Associations Identified in Schedule A, The on 5/5/2025, answer due 5/26/2025.

MINUTE entry before the Honorable Edmond E. Chang: Given the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction 24 is granted. In light of the answer deadline of 05/27/2025, the tracking status hearing of 05/09/2025 is reset to 06/13/2025 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 06/06/2025. 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 06/06/2025. Emailed notice

(Status Report Requirements)

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 05/06/2025. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff neither filed a status report or motion for default judgment. The status report and motion shall be filed by 06/20/2025, or else the case will be dismissed for lack of prosecution. The tracking status hearing of 06/13/2025 is reset to 06/27/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MOTION by Plaintiff VIZ Media, LLC for default judgment as to remaining defendant

(Exhibit Schedule A of Defaulted Defendants)

MEMORANDUM by VIZ Media, LLC in support of motion for default judgment 30

(Declaration of Karolina Jozwiak)

NOTICE of Motion by Karolina Jozwiak for presentment of motion for default judgment 30 before Honorable Edmond E. Chang on 6/27/2025 at 08:30 AM.

STATUS Report by VIZ Media, LLC

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely answer, the motion for default judgment is granted in part. Judgment shall be entered in favor of the Plaintiff and against the Defendant in the total amount of forty-thousand ($40,000) dollars. Given the willfulness established by the default, a permanent injunction shall be entered. A separate AO-450 judgment shall be entered. The status hearing of 06/27/2025 is vacated. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 6/17/2025. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Edmond E. Chang on 6/17/2025. Mailed notice.