2025-cv-03976

COMPLAINT filed by Anagram International, LLC; Filing fee $ 405, receipt number AILNDC-23340755.

Exhibit 1 - Copyright Registrations

Exhibit 2 - CBP

Exhibit 3 - IP Rights

(Exhibit 4 - DHS)

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff Anagram International, LLC - Schedule A to Complaint - regarding complaint, 1

MOTION by Plaintiff Anagram International, LLC to seal document exhibit 3

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Anagram International, LLC

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Matthew A. Werber

MAILED copyright report to Registrar, Washington DC.

CASE ASSIGNED to the Honorable Joan B. Gottschall. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category 3). (qrtr,)

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. (qrtr,)

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Peter Krusiewicz

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 4 for leave to file certain documents temporarily under seal is granted. The Clerk is instructed to maintain the seal on all presently sealed documents until further order of court. Mailed notice

ORDER: An initial status report is due on or before June 18, 2025. Counsel and parties are directed to familiarize themselves with the pretrial procedures in Judge Gottschall's case management packet, which is available from the court's website at https://www.ilnd.uscourts.gov. Please pay particular attention to the requirement to exchange initial disclosures within fourteen days of the parties' initial discovery planning conference and the court's requirement that the parties are to explore settlement opportunities and identify areas of agreement prior to the filing of the first status report.If, by the due date of the scheduled status report, defendants have not been served, plaintiff should email chambers_gottschall@ilnd.uscourts.gov to reset the status date. Counsel in cases removed from another court should follow these procedures to the extent applicable. See the order and Judge Gottschall's case management packet for further details. Signed by the Honorable Joan B. Gottschall on 4/16/2025.Mailed notice

STANDING ORDER IN "SCHEDULE A" CASES Signed by the Honorable Joan B. Gottschall on 4/16/2025. Mailed notice

MEMORANDUM order 11 by Anagram International, LLC - regarding joinder --

MINUTE entry before the Honorable Joan B. Gottschall: Enter order. In accordance with the order, plaintiff has until and including April 24, 2025, to show cause why joinder in this case is permissible under Fed. R. Civ. P. 20(a)(2) and Bailie v. Schedule A Defendants, 734 F. Supp. 3d 798 (N.D. Ill. 2024). Mailed notice

ORDER Signed by the Honorable Joan B. Gottschall on 4/18/2025. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: In its memorandum of law 12 supporting the joinder of the 31 defendants, plaintiff urges the court to adopt the "swarm" theory of joinder under Rule 20(a)(2) rejected in Bailie v. Schedule A Defendants, 734 F. Supp. 3d 798 (N.D. Ill. 2024). This court will follow Bailie unless and until it is given a legally sufficient reason to revisit that decision. Plaintiff offers none in the instant memorandum 12. Plaintiff cites no intervening case law and repeats arguments considered and rejected in Bailie. In its memorandum, at 6, plaintiff states that if the court follows Bailie in the case at bar, "Plaintiff respectfully requests an order denying Plaintiff's request for joinder, and Plaintiff will proceed with an amended complaint naming one defendant." Because plaintiff concedes that defendants are improperly joined under Rule 20(a)(2) as construed in Bailie, plaintiff is instructed to amend its complaint by and including April 28, 2025, to eliminate all improperly joined defendants. Mailed notice

AMENDED complaint by Anagram International, LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

Exhibit 1 - Copyright Registrations

Exhibit 2 - CBP

Exhibit 3 - IP Rights

(Exhibit 4 - DHS)

SEALED EXHIBIT by Plaintiff Anagram International, LLC - Amended Schedule A - regarding amended complaint, 16

MOTION by Plaintiff Anagram International, LLC to seal document exhibit 17

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 18 for leave to file certain documents temporarily under seal is granted. The Clerk is instructed to maintain the seal on all presently sealed documents until further order of court. Mailed notice

MOTION by Plaintiff Anagram International, LLC-- expedited discovery and electronic service --

Werber Decl.

Ex. A - Amazon Registration

Ex. B - Hague

Ex. C - Listing

Ex. D - Shipping

Ex. E - storefront

Ex. F - Address search

(Ex. G - Business Name Search)

STATUS Report by Anagram International, LLC

ORDER FOR LEAVE TO CONDUCT EXPEDITED DISCOVERY AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION: Plaintiff's Ex Parte Motion 20 for Entry of an Order for leave to conduct Expedited Discovery and Service of Process by Email and/or Electronic Publication is granted. The Clerk of the Court is directed to issue a single original summons in the name of "ZYZMZ." Signed by the Honorable Joan B. Gottschall on 6/20/2025.Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: The next status report is due by and including July 21, 2025. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: The order dated June 20, 2025 (ECF No. 22), was entered in error and is withdrawn. See Fed. R. Civ. P. 60(a). Enter order dated June 23, 2025, granting plaintiff's motion 20 for leave to conduct expedited discovery and for leave to serve the summons and complaint by electronic means. In accordance with the order, the Clerk is directed to issue a single original summons in the name of "Fashion-bag." Mailed notice

ORDER GRANTING MOTION FOR EXPEDITED DISCOVERY AND ELECTRONIC SERVICE Signed by the Honorable Joan B. Gottschall on 6/23/2025.Mailed notice

SUMMONS Issued (Court Participant) as to Defendant Fashion-bag

SUMMONS Returned Executed by Anagram International, LLC as to All Defendants.

(Declaration)

STATUS Report by Anagram International, LLC

MINUTE entry before the Honorable Joan B. Gottschall: Defendant has not appeared. Plaintiff represents in its status report 29 filed July 21, 2025, that it intends to move for default judgment "in the coming days." If plaintiff has not filed a motion for default judgment by August 7, 2025, a further status report is due on that date. Mailed notice

MOTION by Plaintiff Anagram International, LLC for default judgment as to - Defaulting Defendants -, MOTION by Plaintiff Anagram International, LLC for entry of default

MEMORANDUM by Anagram International, LLC in support of motion for default judgment, motion for entry of default 31 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR ENTRY OF DEFAULT AND DEFAULT JUDGMENT

Exhibit A - Defaulting Defendants

Declaration of Matt Werber

(Unpublished)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a motion 31 for default judgment in the amount of $100,000 against defendant Fashion-bag. Dkt. No. [32-1]. Any written response to, or request for a hearing on, plaintiff's motion for default judgment against defendant is due on or before August 15, 2025. A hearing, to be conducted via teleconferencing, may be requested by sending a message to Chambers_Gottschall@ilnd.uscourts.gov with a copy to all parties and attorneys who have appeared. If no written response or request for a hearing is received by the deadline, the court will assume that defendant does not oppose the motion and will rule on the papers. Plaintiff is ordered to serve defendant with a copy of this order in accordance with Federal Rule of Civil Procedure 5 and to file a certificate of service on or before August 4, 2025. Mailed notice

CERTIFICATE of Service by Matthew A. Werber on behalf of Anagram International, LLC regarding set motion and R&R deadlines/hearings, 33

MINUTE entry before the Honorable Joan B. Gottschall: The deadline of August 15, 2025, to object to plaintiff's motion 31 for default judgment has come and gone, and no objection has been filed. Plaintiff's motion 31 for default judgment is granted. Enter default judgment. Civil case terminated. Mailed notice.

DEFUALT JUDGMENT ORDER: Signed by the Honorable Joan B. Gottschall on 8/22/2025. Mailed notice.

MINUTE entry before the Honorable Joan B. Gottschall: Orders entered on Friday, August 22, 2025, were entered erroneously. All orders dated August 22, 2025, are withdrawn. Corrected orders will follow later today. Case reopened. Mailed notice.

MINUTE entry before the Honorable Joan B. Gottschall: The deadline of August 15, 2025, to object to plaintiff's motion 31 for default judgment has come and gone, and no objection has been filed. Plaintiff's motion 31 for default judgment is granted. Plaintiff is ordered to resubmit a judgment order naming defendant "Fashion-bag" rather than the plural "defendants" by no later than September 2, 2025. See Dkt. No. 17. Plural references to "defendants" must be changed to reflect that the order is being entered against only one defendant. Mailed notice.

MINUTE entry before the Honorable Joan B. Gottschall: The deadline 33 of August 15, 2025, to object to plaintiff's motion 31 for default judgment has come and gone, and no objection has been filed. Plaintiff's motion 31 for default judgment is granted. Enter default judgment. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER Signed by the Honorable Joan B. Gottschall on 9/11/2025. Mailed notice