2025-cv-05010

COMPLAINT filed by TV Tokyo Corporation; Filing fee $ 405, receipt number AILNDC-23450932.

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

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Maria Valdez. 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: Mankings, Mankingw and Mankingz added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Trademarks)

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

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Amended Schedule A to Complaint [1] and Schedule A [2]

MOTION by Plaintiff TV Tokyo Corporation for leave to file under seal

MOTION by Plaintiff TV Tokyo Corporation for leave to file excess pages

MEMORANDUM in Support of [17] Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Hiroaki Saiki

Exhibit 1, of Hiroaki Saiki's Declaration

Exhibit 2, of Hiroaki Saiki's Declaration

SEALED EXHIBIT by Plaintiff TV Tokyo Corporation Sealed Exhibit 3, Declaration of Hiroaki Saiki regarding memorandum in support of motion, [18]

MEMORANDUM by TV Tokyo Corporation Establishing that Joinder is Proper

Exhibit 1

Presentment for Exparte Motion [17] and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file[15], motion for leave to file excess pages[16] before Honorable Edmond E. Chang on 5/27/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of the joinder filing, R. 20, joinder is proper given that the remaining Defendants use an exact duplicate of their own very specific branding. (2.) The Plaintiff's motion [17] for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 15 U.S.C. § 1117(a), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, trademark owners need only "prove defendant's sales only; defendant must prove all elements of costs or deduction claimed." 15 U.S.C. § 1117(a). (The same principles apply to the copyright claims.) To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendants, who likely would seek to transfer the money elsewhere. The Plaintiff's motion [15] for leave to file under seal is granted in light of the asset-restraint goal. The public redacted version of the TRO will be posted. The Plaintiff's request for electronic service of process is granted. The motion [16] for extra pages is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 06/06/2025 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion), if appropriate, no later than 05/30/2025. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 05/23/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 05/23/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) Mankings and all other Defendants identified in the Complaint by Plaintiff TV Tokyo Corporation

SUMMONS Issued (Court Participant) as to Defendant Mankings and all other Defendants identified in the Complaint

SURETY BOND in the amount of $3,000 posted by TV Tokyo Corporation (Document not scanned).

MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction

MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction[28]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's Declaration

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction[28] before Honorable Edmond E. Chang on 6/6/2025 at 08:30 AM.

SUMMONS Returned Executed by TV Tokyo Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/30/2025, answer due 6/20/2025.

Declaration of Service

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that warranted the entry of the TRO, the motion for preliminary injunction 28 is granted. Given the response deadline of 06/20/2025, R. 31, the tracking status hearing of 06/06/2025 is reset to 07/03/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 06/27/2025. If the Defendants do not answer on time, then they shall be deemed to be in default as of 06/21/2025, and the Plaintiff shall file a motion for default judgment on 06/27/2025. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 06/02/2025. Emailed notice

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to The Defendants Identified In Amended Schedule A

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment[34]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[34] before Honorable Edmond E. Chang on 7/3/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely answer to the amended complaint, the motion for default judgment 34 is granted. Judgment shall be entered in favor of the Plaintiff and against the Defendants in the amount of fifteen-thousand dollars ($15,000) from each Defendant. Given the willfulness established by the default, a permanent injunction shall be entered. A separate AO-450 judgment shall be entered. The status hearing of 07/03/2025 is vacated. Civil case terminated. Emailed notice

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 07/01/2025. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The three thousand dollar ($3,000) surety bond posted by TV TOKYO is hereby released to TV TOKYO or TV TOKYO's counsel, Keith Vogt, Ltd., 33 W Jackson Blvd, #2W, Chicago, Illinois, 60604. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to TV TOKYO or TV TOKYO's counsel. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 07/01/2025. Emailed notice