2025-cv-03881

COMPLAINT filed by Mob Entertainment, Inc.; Filing fee $ 405, receipt number AILNDC-23330129.

Exhibit 1

Exhibit 1

Exhibit 1

Exhibit 1

(Exhibit 1)

Exhibit A

Declaration of Jennifer V. Nacht

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

(Exhibit A)

Exhibit A

Exhibit A

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Schedule A regarding complaint[1]

Exhibit 2

Exhibit 2

Exhibit 2

Exhibit A

Exhibit B

Exhibit 2-1

MOTION by Plaintiff Mob Entertainment, Inc. for leave to file under seal

Exhibit 2-2

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mob Entertainment, Inc.

Notice of Claims Involving Trademarks by Mob Entertainment, Inc.

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Justin R. Gaudio

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

NEW PARTIES: StarrismW, ShanXiZhuanXingZongHeGaiGeShiFanQuBoTeDianZiShangWuJingYingBu, XIAO QIANG DE XIAO DIAN, menghongchundedianpu, hanfuhongshangmao, ADASDDDD, Pengpeng Shop, A2XCGR2RMDA9S0, A2YXP6HDY1JREF, xiaoyejingpin, huanghuaping, jinhuashipingkaidianzishangwushanghang, xianzhaofa, Route66 Threads, LIN-weixiong, glisten_star, lolit58, Luckiee, pake2188, ryan_76, shangcoa20, star_gazer, sunshine_9996, tostan9, yunhua7_0, MASTER QUEEN, reliable blanket, Trump Trendsetter, Lunar Luxe L, Kaitou Couture, penglin0504, AirGoodsS, linhuangyang, WUJIAJUN, jiangxinaaoyu, jijubaihuo, YiGong, FuYiBaiHuo, meichuang, EnYueKe, Aipengry, changshashigengzhou, Fine jewelry, guangzhoushixiaximaoyi, YARAKETA, SINGINGBOATS, Tiankai Co., Ltd, enzoei, Xbriter, ZYUQI, suchuankaishangpin, XYRKJ, kai.co and ouzheng added to case caption. (Text entry; no document attached.)

Terminating meichuang (Text entry; no document attached.)

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Jennifer Van Nacht

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file under seal [3] is granted. By 4/18/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

AMENDED complaint by Mob Entertainment, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Amended Schedule A regarding amended complaint[12]

Response to [11] by Mob Entertainment, Inc.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiff Mob Entertainment, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mob Entertainment, Inc. in support of motion for temporary restraining order[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

DECLARATION of Shelly Gayner regarding memorandum in support of motion[18]

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Exhibit 3 - Parts 1-2 regarding declaration[20]

MOTION by Plaintiff Mob Entertainment, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mob Entertainment, Inc. in support of motion for miscellaneous relief[22]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[23]

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for electronic service 22 is granted. The plaintiff's motion for a temporary restraining order 17 is taken under advisement. By 4/22/25, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. Mailed notice

SUPPLEMENT to motion for temporary restraining order 17 per 25

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for a temporary restraining order [17] is granted. Enter order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/25/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A by Plaintiff Mob Entertainment, Inc.

Registry Deposit Information Form by Mob Entertainment, Inc.

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

SURETY BOND in the amount of $ 55,000.00 posted by Mob Entertainment, Inc. (Document not imaged) (Received via the Clerk's Office drop box on 05/02/2025.)

MOTION by Plaintiff Mob Entertainment, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mob Entertainment, Inc. in support of extension of time[33]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[34]

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order [33] is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 5/7/2025. Mailed notice

MOTION by Plaintiff Mob Entertainment, Inc. for preliminary injunction

MEMORANDUM by Mob Entertainment, Inc. in support of motion for preliminary injunction[38]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[39]

SUMMONS Returned Executed by Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/7/2025, answer due 5/28/2025.

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [38] is taken under advisement. Any objection or response is due before 5/23/25. Upon review of the certificate of service, the Court directs the plaintiff, by 5/9/25, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 5/23/25. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by Plaintiff Mob Entertainment, Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, [42]

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 44, defendant no. 39 is dismissed from this case. Mailed notice

ANSWER to amended complaint by AdongPNCE

ATTORNEY Appearance for Defendant AdongPNCE by Longhao Wang

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [38] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 6/30/25 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 5/28/2025. Mailed notice

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by AdongPNCE

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff and defendant AdongPNCE are directed to review the procedures for initial status reports, located at [https://www.ilnd.uscourts.gov/judge-info.aspx?79eF+7uiX7ewBj/ITKrjoA==] and to submit an initial status report by 6/11/25. The report should include a proposed case management schedule reflecting any disputes between the parties as to the proposed schedule. Mailed notice

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to a certain Defendant

MOTION by Plaintiff Mob Entertainment, Inc. for entry of default, MOTION by Plaintiff Mob Entertainment, Inc. for default judgment as to all Defendants with the exception of a certain Defendant

MEMORANDUM by Mob Entertainment, Inc. in support of motion for entry of default, motion for default judgment, [53]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[54]

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 52, defendant no. 43 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 53 is taken under advisement. Any objections or responses are due by 6/12/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 6/4/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Mob Entertainment, Inc. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 57

STATUS Report Pursuant to 51 by Mob Entertainment, Inc.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon review of the joint status report filed by the plaintiff and defendant no. 41, Adong PNCE, [59], the Court adopts the parties' proposed case management schedule. The matter is referred to the assigned magistrate judge for all further discovery scheduling and supervision as well as any settlement conference the parties may jointly seek. Any protective orders and confidentiality orders are included within this referral. Mailed notice

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable M. David Weisman for the purpose of holding proceedings related to: for all further discovery scheduling and supervision as well as any settlement conference the parties may jointly seek. Any protective orders and confidentiality orders.Mailed notice.

MINUTE entry before the Honorable M. David Weisman: This case has been referred to Magistrate Judge Weisman for the purpose of holding proceedings related to further discovery scheduling and supervision (including entry of protective orders and confidentiality orders), as well as any settlement conference the parties may jointly seek. The Court sets the following schedule: Rule (26)(a)(1) disclosures shall be exchanged by 6/27/25; written discovery shall issue by 7/2/25; amendment of pleadings and joinder of parties to be completed by 8/22/25; and fact discovery shall be completed by 10/3/25. Initial round of discovery requests shall be propounded pursuant to the Federal Rules of Civil Procedure, and any additional requests must be made either by agreement between the parties or with Court approval, which will be granted liberally earlier in the discovery process but only with explanation later in the discovery process. Any motion for a confidentiality order or HIPAA order shall be filed by 7/25/25. The motion shall indicate whether it is agreed. The proposed confidentiality order should be based on the Form LR 26.2 Model Confidentiality Order, and the parties must submit a clean copy of their proposed order, along with a corresponding redlined copy of the Court's model order, to the Court's proposed order email address: Proposed_Order_Weisman@ilnd.uscourts.gov. If the proposed order is acceptable to the Court, it will be entered. Status hearing set for 8/13/25 at 9:15 a.m. Joint status report due by noon on 8/11/25 setting forth the status of written discovery; whether any third-party discovery is anticipated; a list of anticipated depositions; whether the parties request a settlement conference; and any other issues the parties wish to raise. If either party requires the Court's attention prior to the status conference, that party shall promptly file a motion. Mailed notice

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [63], defendant no. 51 is dismissed from this case. Mailed notice

STIPULATION of Dismissal as to a certain Defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the parties' joint stipulation to dismiss [65] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii), defendant no. 41, AdongPNCE, is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:All objecting defendants having been dismissed from this action, the plaintiff's motion for default judgment [53] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 6/25/2025. Mailed notice

MINUTE entry before the Honorable M. David Weisman: The District Court has entered a judgment of default as to the objecting defendants and terminated the case [[67],[68]]. Status hearing set for 8/13/25 is stricken. Accordingly, all issues relating to the referral of this matter having been resolved, the case is returned to the District Court. Referral terminated. Mailed notice

MOTION by Plaintiff Mob Entertainment, Inc. to amend/correct order[68]

MINUTE entry before the Honorable John J. Tharp, Jr:The motion to amend order [70] is granted in part and denied in part. Because the counterfeit images are being used primarily to sell more counterfeit product, the Court finds that the damages flowing from the defendants' copyright violations are largely derivative of the trademark violations and thus warrant a smaller statutory award than that proposed by the plaintiff. The Court's previous default judgment order [68] is hereby stricken. Enter amended order. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 7/2/2025. Mailed notice

FULL SATISFACTION of Judgment regarding order[72] in the amount of $50,000 as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 73, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant nos. 33 and 44. Mailed notice

MOTION by Plaintiff Mob Entertainment, Inc. to Correct Final Judgment Order

MINUTE entry before the Honorable John J. Tharp, Jr:The motion to correct final judgment order [75] is granted. Enter order.

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 7/22/25.