2025-cv-03840

COMPLAINT filed by Dorit Maritta Fuhg; Filing fee $ 405, receipt number AILNDC-23326977.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Dorit Maritta Fuhg Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Adam Grodman

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Christopher Romero

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Monica Rita Martin

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 3).

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: Country Canvas, Qiioswiioo, LvLiangShiMingKaiDianZiShangWuYouXianGongSi, KangRongDianZiShangWuYouXianGongSi, heilongjiangchashunxiaoshangmaoyouxiangongsi, GuangZhouRuiJiaMaoYiYouXianGongSi, KongJiangMei254, yunchengshiyanhuqumijinzhushangmaoyouxiangongsi, Harlee-US, Geng Qin, GuangZhouLanKongShangMao, JIAXUGANGMAITOU, YuFei toys store, Retail Shop 4 Less, ChenWei toys store, liulishangmaoyouxiangongsi, zhouhang, LuLin, TunChangWeiBangXianShangMaoYouXianGongSi, yinchuanshizhiyushangmao, ZhongYueWen, XieJunJing, Fat Panda Shop, MINGYUYU, legendT, shunchengbbb, Print Home and Defendant 6 added to case caption.

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Yanling Jiang

ATTORNEY Appearance for Plaintiff Dorit Maritta Fuhg by Yi Bu

MOTION by Plaintiff Dorit Maritta Fuhg for leave to file under seal

MOTION by Plaintiff Dorit Maritta Fuhg for leave to file excess pages

MEMORANDUM in Support of 13 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Dorit Maritta Fuhg

(Exhibit 1, of Dorit Maritta Fuhg's Declaration)

SEALED EXHIBIT by Plaintiff Dorit Maritta Fuhg Sealed Exhibit 2, Declaration of Dorit Maritta Fuhg regarding memorandum in support of motion, 14

Exhibit 2-1

(Exhibit 2-2)

Presentment for Exparte Motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 11, motion for leave to file excess pages 12 before Honorable Jorge L. Alonso on 4/15/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 11 12 13 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $281,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 4/15/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 4/14/2025. Notice mailed by Judge's staff

MAILED copyright report to Registrar, Washington DC.

(Copyrights)

SUMMONS Issued (Court Participant) as to Defendant Country Canvas and all other Defendants identified in the Complaint

MOTION by Plaintiff Dorit Maritta Fuhg for extension of time to Post Bond

MOTION by Plaintiff Dorit Maritta Fuhg for extension of time of the Temporary Restraining Order

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion for extension of time to post bond 22 is granted to 4/25/25. Plaintiff's Motion to extend the temporary restraining order 24 is granted. The temporary restraining order is extended to 5/12/25. Motion hearing date of 4/24/25 is stricken. Telephonic status hearing set for 5/14/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MOTION by Plaintiff Dorit Maritta Fuhg for preliminary injunction

MEMORANDUM by Dorit Maritta Fuhg in support of motion for preliminary injunction 27

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 27 before Honorable Jorge L. Alonso on 5/6/2025 at 09:30 AM.

SUMMONS Returned Executed by Dorit Maritta Fuhg as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/24/2025, answer due 5/15/2025.

(Declaration of Service, Keith A. Vogt)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 5/6/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction 27 is granted. Enter Preliminary injunction order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Telephonic status hearing previously set for 5/14/25 is stricken and reset to 6/5/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 5/6/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 24 Fat Panda Shop and defendant no. 28 Print Home

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 1 Country Canvas

MOTION by Plaintiff Dorit Maritta Fuhg for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by Dorit Maritta Fuhg in support of motion for default judgment 37

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 37 before Honorable Jorge L. Alonso on 6/5/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 26 LegendT

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment against the Defendants identified in first amended schedule A 37 is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/5/2025. Notice mailed by Judge's staff