2025-cv-05382

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-23488907.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Rachel S. Miller

Exhibit A

Declaration of Hannah A. Abes

Exhibit A- Zooyoo's Product

(Exhibit A)

Exhibit 1

(Exhibit A)

Exhibit 1

(Exhibit 1)

(Exhibit A)

Exhibit A- Defs Email

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint[1]

Exhibit 2

Exhibit 2

Exhibit A

Exhibit B- Capesaro's Product

Exhibit 2

(Exhibit 2)

Exhibit B- Pls Email

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

Exhibit 3

Exhibit C- Notice of Depo 1

CIVIL Cover Sheet

(Exhibit 4)

Exhibit D- Notice of Depo 2

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

(Exhibit E- 11697 Order)

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

NEW PARTIES: A2TPJYCNKBCVT3, Adorely Store, Blyxon, Cobok, Everything wins, fengyingqinshopss, FriendShip, Frontier co-creation Hong Kong Limited, fuqingyaba, HAIKOUSHICHENGHUAYUNSHANGMAOYOUXIANGONGSI, HAPPY FIESTA PARTY, HSJNJKFU, huahongstore, Jallysia, Jienyun, JonesLi-USA, JYFLZQ, Kloa Hloa, KOLMALK, Leopmase Market, liangjianhua121, Liqing trading Co., LTD, lixushengdedian, MinyuaN, NaduoT96, NawaiTrede, nguyen thi anh thu t shop, Nobledecor Balloons Store, OTUYBGRSEC, qiyizhijia-shop, Recommended Pro, suzilongmaoyi, Taoyicom, TBGFVCDEESDX, Thalia store, Tomatobrother, Tree Cave People, wenxianqiao, xihanmudianzishangwu, xjdbaihuolingshoushangdian, Yanaf Direct, yangdeyio, YHYDZ US DIRECT, YIYOUU, YNWRJ, YunjinHQ, YYVVWTYSVS, ZHANGDEFEI, zhumadianshijiejingyuancanjuqingxiyouxiangongsi, antouyijie, corepair, defender2021, dongyanh40, eby18, Fashion Protective Case, luuu, oh-midnight, princesscostume, taianshunyi66, taianshunyi-818, usiwangdi-0, xiaoj_wen, yangjidong334, anytimeLZ, Chen Dongxu, FengTai, KINWOER, LHOTSE JEWELRY, Storm Force, SwagTeeDude and JSLY Network added to case caption. (Text entry; no document attached.)

MAILED Original fifty thousand and 00/100 dollars ($50,000) bond posted by MATTEL, Inc. to Amy Crout Ziegler Greer, Burns & Crain Ltd. 200 W Madison St., Ste 2100, Chicago, IL 60606 certified via mail # 9589 0710 5270 0579 7830 66 (Text entry; no document attached.)

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Michael Moore regarding memorandum in support of motion[12]

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 3 - Parts 1-2 regarding declaration[14]

MOTION by Plaintiff Mattel, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[16], motion for temporary restraining order[11], motion for leave to file[3] before Honorable Manish S. Shah on 5/27/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3][11][16] are granted and no appearance on the motions is necessary. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 5/21/2025. Notices Mailed.

Registry Deposit Information Form by Mattel, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mattel, Inc.

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

SURETY BOND in the amount of $ 50,000.00 posted by Mattel, Inc. (Document not imaged)

ATTORNEY Appearance for Defendant Balun Admhai by Ruixin Lu

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time[27]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[28]

NOTICE of Motion by Rachel S Miller for presentment of extension of time[27] before Honorable Manish S. Shah on 6/4/2025 at 09:45 AM.

ATTORNEY Appearance for Defendants Capesaro, ZOOYOO inc by Jianyin Liu

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 27 is granted, and no appearance is necessary. The TRO is extended to 6/18/25. Notices Mailed.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction[34]

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction[34] before Honorable Manish S. Shah on 6/18/2025 at 09:45 AM.

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/13/2025, answer due 7/4/2025.

ANSWER to Complaint with Jury Demand by Capesaro, ZOOYOO inc

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Manish S. Shah: For the reasons stated in open court, plaintiff's motion for preliminary injunction [34] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Plaintiff shall file a status report as to the answering defendants by 7/2/25. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 6/18/2025. Notices Mailed.

MOTION by Defendants Capesaro, ZOOYOO incto Dissolve Preliminary Injunction [DE 41]

NOTICE of Motion by Jianyin Liu for presentment of motion for miscellaneous relief[42] before Honorable Manish S. Shah on 6/24/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 6/24/25 is necessary. Plaintiff shall respond to the motion to dissolve injunction by 7/3/25 and defendant may reply by 7/17/25. The court will rule by cm/ecf. All discovery as to defendant ZOOYOO and Capesaro (including expedited discovery previously authorized) is stayed. Notices Mailed.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

STATUS Report Pursuant to 40 by Mattel, Inc.

MINUTE entry before the Honorable Manish S. Shah: The stay on discovery between plaintiff and defendants Capesaro, and ZOOYOO Inc (Defendants 5 and 57) is lifted. Defendants have answered the complaint and the parties should proceed with discovery in the ordinary course. The parties must exchange initial disclosures by 7/31/25 and all fact discovery must be completed by 10/30/25. The court will set the remainder of the schedule when the parties get closer to completing fact discovery. The parties shall file a joint status report on discovery progress by 9/30/25. The briefing schedule on the motion to dissolve the preliminary injunction remains as set. Notices Mailed.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

RESPONSE by Mattel, Inc.in Opposition to MOTION by Defendants Capesaro, ZOOYOO incto Dissolve Preliminary Injunction [DE 41] 42

DECLARATION of Hannah A. Abes regarding response in opposition to motion 50

ATTORNEY Appearance for Defendant YIYOUU by Haipeng Xiao

ANSWER to Complaint with Jury Demand by YIYOUU

MINUTE entry before the Honorable Manish S. Shah:The fact discovery schedule set on 7/3/25, see 48, applies to defendant YIYOUU. The parties shall exchange initial disclosures by 7/31/25, complete fact discovery by 10/30/25, and file a joint status report by 9/30/25. Mailed notice

REPLY by Capesaro, ZOOYOO inc to response in opposition to motion 50

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to a Certain Defendant

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants with the exception of certain Defendants

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment 58

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 59

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment 58 before Honorable Manish S. Shah on 7/17/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: For the reasons stated in open court, the motion for entry of default judgment 58 is granted. Enter Default Judgment Order. The discovery schedule as to the remaining parties remains as set 54. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 7/17/2025. Notices Mailed.

MOTION by Defendants ZOOYOO inc, Capesaro for summary judgment

MEMORANDUM by ZOOYOO inc in support of motion for summary judgment[64]

RULE 56 (C) Statement by Capesaro, ZOOYOO inc regarding motion for summary judgment[64]

FULL SATISFACTION of Judgment regarding order 63 in the amount of $50,000 as to certain defendant

RETURN of Green card certified returned receipt number article no. 9589 0710 5270 0579 7830 66 (Received by mail in the Clerk's Office on 7/30/25.)

NOTICE of Motion by Jianyin Liu for presentment of motion for summary judgment 64 before Honorable Manish S. Shah on 8/12/2025 at 09:45 AM.

NOTICE of Motion by Jianyin Liu for presentment of motion for miscellaneous relief 42 before Honorable Manish S. Shah on 8/12/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. Counsel for defendants Capesaro and ZOOYOO, Inc. does not appear. The motion to dissolve preliminary injunction 42 remains under advisement. Plaintiff's response to the motion for summary judgment 64 is due 9/26/25. Defendants' reply is due 10/17/25. The court will issue a ruling via cm/ecf. Plaintiff's counsel shall file a notice on the court's docket if the parties settle. Notices Mailed.

TRANSCRIPT OF PROCEEDINGS held on 08/12/2025 before the Honorable Manish S. Shah. Motion Hearing. Order Number: 52755. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 9/3/2025. Redacted Transcript Deadline set for 9/15/2025. Release of Transcript Restriction set for 11/11/2025.

Stipulation of Dismissal by Mattel, Inc. as to a Certain Defendant

MOTION by Defendants Capesaro, ZOOYOO inc for protective order

MOTION by Plaintiff Mattel, Inc. to stay All Deadlines and Notice of Settlement (Joint)

MINUTE entry before the Honorable Manish S. Shah: The motion to stay deadlines pending settlement 75 is granted. The remaining parties must file a joint status report by 10/10/25. Notices Mailed.

STIPULATION of Dismissal as to Certain Defendants

MINUTE entry before the Honorable Manish S. Shah: All of plaintiff's claims having been resolved, this case is dismissed. Notices Mailed.