2025-cv-04372

COMPLAINT filed by Those Characters from Cleveland, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23381883.

Exhibit A

(Exhibit B)(De Preter, Matthew)

SEALED EXHIBIT by Plaintiff Those Characters from Cleveland, LLC Schedule A regarding complaint 1 (De Preter, Matthew)

CIVIL Cover Sheet (De Preter, Matthew)

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Matthew L. De Preter (De Preter, Matthew)

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file Certain Documents Under Seal (De Preter, Matthew)

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Sofia Quezada Hastings (Quezada Hastings, Sofia)

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Karolina Jozwiak

CASE ASSIGNED to the Honorable Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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: Enjoyment Party Backdrop Store added to case caption.

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

EMAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff has filed a complaint alleging infringement by 142 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 20 is rarely appropriate in Schedule A cases. See, e.g., Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27 (N.D. Ill. Nov. 18, 2024). Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder on or before May 8, 2025. Alternatively, by the same date, the plaintiff may file an amended complaint naming one or more defendants; however, if the plaintiff names multiple defendants, the plaintiff must show that joinder of those defendants is proper. All pending motions are hereby stayed pending resolution of the joinder issue. Mailed notice.

AMENDED complaint by Those Characters from Cleveland, LLC against The Partnership and Unincorporated Associations identified on Schedule A

Exhibit A

(Exhibit B)(Quezada Hastings, Sofia)

SEALED EXHIBIT by Plaintiff Those Characters from Cleveland, LLC Schedule A regarding amended complaint 12 (Quezada Hastings, Sofia)

MOTION by Plaintiff Those Characters from Cleveland, LLC for temporary restraining order (Quezada Hastings, Sofia)

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for temporary restraining order 14

(Declaration of Jay Paragoso)(Quezada Hastings, Sofia)

SEALED EXHIBIT by Plaintiff Those Characters from Cleveland, LLC Evidence Exhibits regarding memorandum in support of motion 15 (Quezada Hastings, Sofia)

MOTION by Plaintiff Those Characters from Cleveland, LLC for Electronic Service of Process

Memorandum in Support

(Declaration of Sofia Quezada Hastings)(Quezada Hastings, Sofia)

NOTICE of Motion by Sofia Quezada Hastings for presentment of motion for miscellaneous relief 17, motion for temporary restraining order 14, motion for leave to file 5 before Honorable Jeremy C. Daniel on 5/20/2025 at 09:30 AM. (Quezada Hastings, Sofia)

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Motions for leave to file certain documents 5, for electronic service of process 17 are granted. Motion for temporary restraining order 14 is granted in part. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 5/20/2025. Mailed notice.

SUMMONS Issued (Court Participant) as to Defendant The Partnership and Unincorporated Associations identified on Schedule A

MOTION by Plaintiff Those Characters from Cleveland, LLC for extension of time of the Temporary Restraining Order

Supplement Memorandum in Support

(Declaration of Karolina Jozwiak)

MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff's motion to extend the temporary restraining order 24 is granted. The temporary restraining order now expires June 17, 2025, at 11:00 a.m. Mailed notice.

SURETY BOND in the amount of $1,000 posted by Those Characters from Cleveland, LLC (Document not scanned).

MOTION by Plaintiff Those Characters from Cleveland, 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 26 before Honorable Jeremy C. Daniel on 6/18/2025 at 09:30 AM.

CORRECTED NOTICE of Motion by Karolina Jozwiak for presentment of motion for preliminary injunction 26 before Honorable Jeremy C. Daniel on 6/25/2025 at 09:30 AM.

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Partnership and Unincorporated Associations identified on Schedule A on 6/18/2025, answer due 7/9/2025.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 6/25/2025. Motion hearing held. The Court notes that the proposed order submitted by the plaintiff is broader than the temporary restraining order entered by the Court. For instance, the proposed order did not include the "traceable to sales of the accused products" limitation the Court included in the TRO's asset restraint. The Court cautions plaintiff's counsel that one could view this as an oversight or as intentional attempt to mislead the Court. In this instance, the Court will treat it as the former; but the Court will view any future occurrences as the latter. Plaintiff's motion for entry of a preliminary injunction [26] is granted. The plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on court's website located www.ilnd.uscourts.gov/instructions. Mailed notice.

NOTICE by Those Characters from Cleveland, LLC re lanham notification 9

MINUTE entry before the Honorable Jeremy C. Daniel: Status hearing set for 8/15/2025 at 9:30 a.m. Mailed notice.

MOTION by Plaintiff Those Characters from Cleveland, LLC for default judgment as to remaining defendant

(Exhibit Schedule A of Defaulted Defendant)

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for default judgment 35

(Declaration of Karolina Jozwiak)

NOTICE of Motion by Karolina Jozwiak for presentment of motion for default judgment 35 before Honorable Jeremy C. Daniel on 8/21/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: The motion hearing set for 8/21/2025 at 9:30 a.m., will be held by Webex. At least 10 mins prior to the hearing, you are directed to cut and paste this hyper link into a browser: https://us-courts.webex.com/meet/Judge_Daniel. ALL PARTICIPANTS MUST TYPE IN THEIR NAME WHEN JOINING THE VIDEO CONFERENCE AND YOUR CAMERA MUST BE ON WHEN YOUR CASE IS CALLED. You can use the dial in option ONLY if you do not have access to a device with video capability: (650)-479-3207, the access code is: 2315 750 8728. All participants must be in a quiet area while on the line and must be muted until your case is called. 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. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: Telephone motion hearing held. For the reasons stated, Plaintiff's motion for default and default judgment 35 is taken under advisement. Plaintiff's supplement to the motion for default judgment is due 8/28/2025. Mailed notice.

MEMORANDUM motion for default judgment 35 by Those Characters from Cleveland, LLC Supplemental Memorandum in Support of Motion for Default Judgment

Exhibit 1

Declaration of Jay Paragoso

(Declaration of Karolina Jozwiak)