2025-cv-05438

COMPLAINT filed by Mob Entertainment, Inc.; Filing fee $ 405, receipt number AILNDC-23493046.

Exhibit 1

Exhibit 2

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

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

CIVIL Cover Sheet

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

Notice of Claims Involving Trademarks by Mob Entertainment, Inc.

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Mob Entertainment, Inc. by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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: Bai Shanlin, spin-fortune, AUGFK, SDR CARD, David Decoration, The poster looks great, Global Better Products, eeloveee, CanvasMuse, CJ baixi, Doll Decoration Painting, Duo Pai Art Gallery, CanvasVoyage Gallery, FlowerF ART, Custom Wall Artistry, ZL Art Decor, Tacheng Decorative Painting, SangYun Trading, FanVu Trade, KIDSHOME-Delivery 5 days, Zadoren-01, YYSHOPHHZ, zhuangsheng, lvtifdiash and WUO-Wom added to case caption.

NEW PARTIES: A30ORCTCU2608N, chenyanfei-us, FLYHOBBY, Pinnacle of Glory Store, wuqixianghiqixiangsh, xianyufeishangmaodiangerenduziqiye (gerenduziqiye), ZhenShiXingTouSu, zhoukoutangsushangmaoyouxiangongsi, brickfunny, changy_9345, cltnin, cyiter, danmi-2o, esunnytoy, fanticeer, feigou_40, fuwe-19, gaoyuansm, gewindeer, HavenHoppers, hcungy, hcuntr, huahan6069, jeient, jeilfke, laptoptech-2014, leallt, lilishangmao, liujing-48145, mchuny, nihaiyoo, P's Toy World, proful, qius_746, sterwitch, wangshangcong_6, wanneg, XM Toy Store, xs985183888, yazhi_86, yuanjie11, zenalee, zuxten, BILINQIYE, Canvas painting manufacturers, Cocoyo Art Poster, Fist Blanket, Hfenghome blanket, LEI K, OGAJGUA, Oiziz, OOOLOVE, SunFays, TeeVault, ChunManYuan, deyou001, DHEQJZE, dimaimaoyi, ErXiu Shop, frank wu, Gentrung, HomeCuisine Hub, huangrense, JINRUIm, JULIC, laicailaicai, Leiteng, lelepai, MioFery, Parallax Edit, prevefalli, shaobo, ShiCaiMaoYi, wang tian fu, wen'lin, xiaohui02, xiaomei02, xichuanxianyaokunjianzhu, YIEEE, YU FAN ART SHOP and zhenfug added to case caption.

MAILED original eighty-thousand-dollar ($80,000) surety bond to posted by Mob Entertainment, Inc. through their Attorneys Amy Crout Ziegler or Justin R. Gaudio 200 West Madison St. Suite 2100 Chicago IL. 60606 via certified mail # 7022 3330 0001 8848 7624. (jn,)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MAILED copyright report to Registrar, Washington DC.

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

MEMORANDUM by Mob Entertainment, Inc. in support of motion for temporary restraining order 14

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 15

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

DECLARATION of Shelly Gayner regarding memorandum in support of motion 15

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Mob Entertainment, Inc. Exhibit 3 - Parts 1-2 regarding declaration 18

Exhibit 3-1

(Exhibit 3-2)

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

MEMORANDUM by Mob Entertainment, Inc. in support of motion for miscellaneous relief 20

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

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal 3 is granted. Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 20 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 5/19/2025. Mailed notice.

Registry Deposit Information Form by Mob Entertainment, Inc.

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

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

SURETY BOND in the amount of $ 80,000.00 posted by Mob Entertainment, Inc. (Document not imaged)

MOTION by Plaintiff Mob Entertainment, Inc. to withdraw party added

MOTION by Plaintiff Mob Entertainment, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Mob Entertainment, Inc. in support of motion for preliminary injunction[30]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[31]

MINUTE entry before the Honorable Thomas M. Durkin: Motion to withdraw the addition of new parties [29] is granted. The New Parties added to the case caption on 5/27/2025 are stricken from the record as added in error. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [30] is set for 6/2/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

SUMMONS Returned Executed by Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/28/2025, answer due 6/18/2025.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 6/2/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [30] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibits to the Declaration of Shelly Gayner [19], and the TRO [24]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 7/3/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 6/2/2025. Mailed notice.

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

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

NOTICE of Voluntary Dismissal by Mob Entertainment, Inc. as to certain defendant

MOTION by Plaintiff Mob Entertainment, Inc. for entry of default, MOTION by Plaintiff Mob Entertainment, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Mob Entertainment, Inc. in support of motion for entry of default, motion for default judgment[41]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 7/3/2025 at 9:00 a.m. is converted to a telephone hearing on the motion for entry of default and default judgment [41]. Mailed notice.

MOTION by Defendant MioFery for extension of time. (Received via Box.com 6/24/25)

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

MOTION by Plaintiff Mob Entertainment, Inc. to strike MOTION by Defendant MioFery for extension of time [45] or, in the alternative, to compel Defendant to obtain U.S. counsel

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

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 7/3/2025. No one appeared on behalf of defendants. Fr the reasons stated on the record, the motion for entry of default and default judgment [41] is granted. Enter order. The motion to strike [47] is denied as moot. The eighty thousand dollar ($80,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 7/3/2025. Mailed notice.

MAILED trademark report with certified copy of minute order dated 7/3/2025 to Patent Trademark Office, Alexandria VA. (jn,)

MAILED copyright report with certified copy of minute order dated 7/3/2025 to Registrar, Washington DC. (jn,)

RETURN of U.S. Post Office Receipt, article no. 7022 3330 0001 8848 7624.