2025-cv-04670

COMPLAINT filed by Queen B Productions; Filing fee $ 405, receipt number AILNDC-23413834.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Queen B Productions Schedule A regarding complaint[1]

MOTION by Plaintiff Queen B Productions for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Queen B Productions

Notice of Claims Involving Trademarks by Queen B Productions

ATTORNEY Appearance for Plaintiff Queen B Productions by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Queen B Productions by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff Queen B Productions by Alexander Whang

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Young B. Kim. 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: [REDACTED] added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MAILED Trademark report to Patent Trademark Office, Alexandria VA

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

AMENDED complaint by Queen B Productions against [REDACTED]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

EXHIBIT by Plaintiff Queen B Productions regarding amended complaint[12]

SEALED EXHIBIT by Plaintiff Queen B Productions Schedule A regarding amended complaint[12]

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. Plaintiff's motion for leave to file under seal 3 is granted. On or before 6/20/25, the parties shall file a joint initial status report in accordance with the template available on the Court's website under the case management procedure titled "Initial Status Report for Newly Filed Cases." The parties shall also review all of the case management procedures and standing orders available on the Court's website, including the Court's case management procedure for motions to dismiss. Initial tracking status hearing set for 6/30/25 at 9:00 a.m. to track the case only (no appearance is required and the case will not be called). Instead, the Court will review the parties' joint initial status report and enter further orders as appropriate. Mailed notice

MOTION by Plaintiff Queen B Productions for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Queen B Productions in support of motion for miscellaneous relief[16]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[17]

Exhibit 1

SEALED EXHIBIT by Plaintiff Queen B Productions Exhibit 2, Part 1 regarding declaration[18]

(Exhibit 2, Part 1)

MOTION by Plaintiff Queen B Productions for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Queen B Productions in support of motion for miscellaneous relief[20]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [16] and motion for electronic service [20] are granted as to Amended Schedule A. Plaintiff's submissions establish that, were defendant to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendant could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendant to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendant, stopping defendant's infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendant from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendant. Expedited discovery is warranted to identify defendant and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Mailed notice

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 5/20/2025. Mailed notice

SURETY BOND in the amount of $ 1,000.00 posted by Queen B Productions. (Document not imaged) (Received at the Intake Counter on 5/27/25)

MOTION by Plaintiff Queen B Productions to Extend the Temporary Restraining Order

MEMORANDUM by Queen B Productions in support of motion for miscellaneous relief[25]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to extend the TRO [25] is granted. The TRO entered on 5/20/25 is extended to 6/17/25. Mailed notice

NOTICE of Voluntary Dismissal by Queen B Productions as to a certain defendant

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff has filed a notice of voluntary dismissal [28], which is self-effectuating under Rule 41(a)(1)(A)(i). All pending deadlines and hearings are stricken. Civil case terminated. Civil case terminated. Mailed notice