2025-cv-04547

COMPLAINT filed by Sony Interactive Entertainment LLC; Filing fee $ 405, receipt number AILNDC-23400844.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Sony Interactive Entertainment LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sony Interactive Entertainment LLC

Notice of Claims Involving Trademarks by Sony Interactive Entertainment LLC

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Lucas Allen Peterson

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Sony Interactive Entertainment LLC against wangyong A, the Individuals and Entities Operating wangyong A and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Amended Schedule A regarding amended complaint, [14]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to file under seal, [3], is denied. Plaintiff seeks leave to file under seal so that plaintiff may obtain a temporary restraining order freezing the defendant's assets before revealing the defendant's identity. See [3]. "The Supreme Court has made clear that courts lack the power to issue an asset freeze at the beginning of a case, unless that party is seeking equitable monetary relief." Zorro Productions, Inc. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, No. 23-cv-5761, 2023 WL 8807254, at *4 (N.D. Ill., Dec. 20, 2023) (citing Grupo Mexicano de Desarrollo S.A. v. All. Bond Fund, Inc., 527 U.S. 308 (1999)); see also Shenzhen Yihong Lighting Co., Ltd. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 23-cv-1560, at Dkt. 15 (N.D. Ill. Nov. 22, 2023). Indeed, "[a]s a general matter [ ] prejudgment asset restraints are not proper simply to establish a fund from which a later award of money damages can be satisfied." Id. (second alteration in original) (quoting Banister v. Firestone, No. 17-cv-8940, 2018 WL 4224444, at *9 (N.D. Ill. Sept. 5, 2018)). In Schedule A cases, plaintiffs often initially demand equitable relief in the form of an accounting of profits, but after obtaining a temporary asset freeze, plaintiffs uniformly shift their focus to demanding statutory damages. Id. at *3-4. In substance, then, if not in form, Schedule A plaintiffs seek prejudgment asset restraints to establish a fund from which money damages may be awarded. So, despite the demand in plaintiff's complaint that it be awarded defendant's profits, the court is not persuaded that plaintiff will actually seek or obtain such equitable relief-as opposed to statutory damages-in this case. See Zorro, 2023 WL 8807254, at *3-4. Thus, even if plaintiff's initial demand for an accounting of profits could provide this court with the power to issue a prejudgment asset freeze, see Grupo Mexicano, 527 U.S. at 333; Banister, 2018 WL 4224444, at *9, the court is not persuaded that such a freeze is warranted. Because the court denies the motion for a temporary restraining order, there is no reason to seal plaintiff's filings pending such relief. Plaintiff's motion for leave to file under seal, [3], is therefore denied. Plaintiff's sealed exhibit, [2], is stricken. If plaintiff wishes to proceed with this case, plaintiff must file its exhibits publicly on the docket by 5/13/2025.

MINUTE entry before the Honorable Martha M. Pacold: On 4/30/2025, the court ordered plaintiff to file its exhibits publicly on the docket by 5/13/2025. To date, plaintiff has not done so. Plaintiff is directed to file its exhibits publicly on the docket by 5/29/2025. Plaintiff is also directed to file a status report by that date, updating the court on the status of service and how plaintiff seeks to proceed with this litigation. Failure to do so may result in dismissal of this case for failure to comply with a court order and/or failure to prosecute.

MOTION by Plaintiff Sony Interactive Entertainment LLC to clarify and Reconsider Minute Order [17]

MOTION by Plaintiff Sony Interactive Entertainment LLC for discovery (Expedited)

Exhibit 1

MOTION by Plaintiff Sony Interactive Entertainment LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for miscellaneous relief[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

STATUS Report per [17] by Sony Interactive Entertainment LLC

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to clarify, [18], discharges the court's order, [17]. The court will accept plaintiff's amended Schedule A, [15], in satisfaction of the order, [17].

ORDER Signed by the Honorable Martha M. Pacold on 6/3/2025: Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) wangyong A and the Individuals and Entities Operating wangyong A by Plaintiff Sony Interactive Entertainment LLC

SUMMONS Issued (Court Participant) as to Defendants wangyong A and the Individuals and Entities Operating wangyong A

MINUTE entry before the Honorable Martha M. Pacold: By 8/22/2025, plaintiff shall file a status report updating the court on the status of this case.

SUMMONS Returned Executed by Sony Interactive Entertainment LLC as to the Individuals and Entities Operating wangyong A on 8/22/2025, answer due 9/12/2025; wangyong A on 8/22/2025, answer due 9/12/2025.

Declaration of Lucas A. Peterson

(Exhibit A)

STATUS Report pursuant to 28 by Sony Interactive Entertainment LLC

(Exhibit A)