2025-cv-04585

COMPLAINT filed by TV Tokyo Corporation; Filing fee $ 405, receipt number AILNDC-23404407.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Keith A. Vogt

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Adam Grodman

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Christopher Romero

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Monica Rita Martin

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Yanling Jiang

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED copyright report to Registrar, Washington DC.

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. 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 to plaintiff(s) counsel Lanham Mediation Program materials.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. The submission must also provide a listing of all prior Schedule A cases filed in any court in the United States in which Plaintiff was a plaintiff, and a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Finally, by filing the template, Plaintiff certifies that Plaintiff has not used any of the screenshot evidence supplied in support of a motion for a TRO in this case in any prior proceeding. If the template is not completed by May 7, 2025, the Court may dismiss this matter for failure to prosecute. Mailed notice.

MOTION by TV Tokyo Corporation for Leave to Conduct Expedited Discovery and Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) (Docket Text modified by Clerk's Office) Modified on 5/8/2025.

MEMORANDUM in Support of 16 Motion for Leave to Conduct Expedited Discovery and Service of Process by E-Mail and/or Electronic Publication

Exhibit 1

Declaration of Keith A. Vogt

(Exhibit 1-2, of Keith A. Vogt's declaration)

Schedule A to the Complaint 1 and Schedule A 2 by TV Tokyo Corporation

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Schedule of Defendants to Complaint 1 ; Schedule A 2 & 18

NOTICE of Correction regarding MOTION 16.

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for expedited discovery 16 is granted. Separate order to issue. Based on the dates provided in the 'last date collected column' in the filing at 19, the Court advises counsel the information provided does not persuade the Court that without prompt relief, Plaintiff would suffer "immediate and irreparable injury" as required under FRCP 65(b)(1)(A) for a TRO to issue. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting the opinion issued in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025) (Alexakis, J.). Mailed notice.

ORDER for leave to conduct expedited discovery Signed by the Honorable Lindsay C. Jenkins on 5/8/2025. Mailed notice.

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

SUMMONS Returned Executed by TV Tokyo Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/22/2025, answer due 6/12/2025.

(Declaration of Service)

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 2 Business Line

MINUTE entry before the Honorable Lindsay C. Jenkins: Assuming no defendant appears beforehand, plaintiff is directed to file a motion for entry of default and default judgment by June 24, 2025. Mailed notice.

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment[28]

Exhibit 1

Exhibit 2

Declaration of Hiroaki Saiki

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before June 27, 2025. If no objections are filed by that date, the court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by June 25, 2025. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiff TV Tokyo Corporation regarding set motion and R&R deadlines/hearings, [30]

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 23 Dante fashion

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 21 Annie cherry LLC

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [28] is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The Clerk is directed to return the surety bond posted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Lindsay C. Jenkins on 6/30/2025. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.