2025-cv-05624

COMPLAINT filed by Sony Interactive Entertainment LLC; Filing fee $ 405, receipt number AILNDC-23512866.

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Schedule A regarding complaint 1

MOTION by Plaintiff Sony Interactive Entertainment LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sony Interactive Entertainment LLC

Notice of Claims Involving Trademarks by Sony Interactive Entertainment LLC

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Lucas Allen Peterson

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

CASE ASSIGNED to the Honorable Jorge L. Alonso. 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: Liyunnn-store, LLRline, luzhoutech, MAGIFUN, MEGA TAY-LOR, Mengyatege, Niaodidili, Olclss Direct, Party Super, Perfect Decor Store, PHANHKERTP, PINGSHI Boutique Shop, Pixframy, Poster Line, putian shi shaocheng dianzi shangwu youxian gongsi, PYBUG, qiannanzhoumaofengguanggaogongzuoshi, Qytown, Sayailian, ScothenStore, Selling things for yuan, shanameng, Shanghai Pingji Cultural Communication Co., Ltd., ShaoYongDengJu, shengzhoushiyuhailongdianzishangwuyouxiangongsi, Shenlu Culture Cool Shop, shenqiuxianshupingshangmaoyouxiangongsi, Shenzhen Oulemi Technology Co. LTD, SKTFFR, STAYTOP, suhanlong, SUILCEUT-, suojianwei, TAIZHENGOUWU, tang wei1, tianlongpocheng, tiaopijin, TingxuanUS, TKDKSFD, UNYUASGNW, USONEPT, UUYDFH, UZXTFQU, VA StoReDn, vanhieustore86, VIJIAO, W6Design, Wall Art Decoration Shop, WangJun--us, wangxiu shop, WEBEEDY US, Weiyangpeng, Wenohonne Store, xiamenshirunganbaihuoyouxiangongsi, Xiangchengshishiyushangmaoyouxiangongsi, XiAnPingJingShangMaoYouXianGongSi, XiAnYanRanShangMaoYouXianGongSi, XiAnYingMingShangMaoYouXianGongSi, XINYUEWANG, xixianxinqukonggangxinchenghanglifushangmaoshanghang, XuPuXianKanLaiYiShangMaoYouXianGongSi, yangnew, YangWei-us, yazheshangwu, YiMaShiXinWenWangLuo, Yolo 365, yunyangshanmao, ZAUYA, ZhangShuaiShangMao, zhijiangshiruotingshangmaoyouxianzerengongsi, zhoutianshuaishangmao, KJXABCMM, UPZH, Voyage cup, Both with me, CHITONG Co.Ltd, Comfort Retreat, Dan Ri Mao Yi, FENPENG, foshanshiyuhaozhuanshangmaoyouxiangongsi, huyihuimaiyi, Ldeal Shop, LFHDSGVB, Linqinwanju SHOP, LONGHAICHUANGTUO, LUNUAOE, maoyilili and Niuyuewen added to case caption.

MOTION by Plaintiff Sony Interactive Entertainment LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for temporary restraining order 14

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

DECLARATION of Jack Schecter regarding memorandum in support of motion 15

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Sony Interactive Entertainment LLC Exhibit 3 Parts 1-2 regarding declaration 17

Exhibit 3-1

(Exhibit 3-2)

MOTION by Plaintiff Sony Interactive Entertainment LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for miscellaneous relief 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 19, motion for temporary restraining order 14, motion for leave to file 3 before Honorable Jorge L. Alonso on 5/29/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 3 14 19 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants 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 is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $88,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 5/29/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 5/28/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Sony Interactive Entertainment LLC

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

ATTORNEY Appearance for Defendant W6Design by Jianyin Liu

SURETY BOND in the amount of $ 88,000 posted by Sony Interactive Entertainment LLC (document not imaged)

MOTION by Plaintiff Sony Interactive Entertainment LLC for preliminary injunction

Exhibit A

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for preliminary injunction[31]

Declaration of Rachel S. Miller

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction[31] before Honorable Jorge L. Alonso on 6/11/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Sony Interactive Entertainment LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/6/2025, answer due 6/27/2025.

Declaration of Lucas A. Peterson

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 6/11/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Motion hearing held. Defendant W6Design's response to Plaintiff's Motion for entry of a preliminary injunction [31] shall be filed by 6/20/25; Defendant's reply shall be filed by 6/27/25. Plaintiff's Motion for entry of a preliminary injunction [31] is granted as to all other Defendants. Enter preliminary injunction order. Telephonic status hearing set for 6/26/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 6/11/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants W6Design, W6Design, MOTION by Defendants W6Design, W6Design to sever for Misjoinder

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to a certain Defendant

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing previously set for 6/26/25 is stricken and reset to 7/9/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Defendant CHITONG Co.Ltd by He Cheng

ANSWER to Complaint by CHITONG Co.Ltd

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Jennifer Van Nacht

MOTION by Plaintiff Sony Interactive Entertainment LLC for entry of default, MOTION by Plaintiff Sony Interactive Entertainment LLC for default judgment as to all Defendants with the exception of certain Defendants

Exhibit A

MEMORANDUM by Sony Interactive Entertainment LLC in support of motion for entry of default, motion for default judgment, [47]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment, [47] before Honorable Jorge L. Alonso on 7/9/2025 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Defendant LUNUAOE by Timothy Tiewei Wang

MOTION by Defendant LUNUAOE for extension of time to file answer regarding complaint[1] Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer[52] before Honorable Jorge L. Alonso on 7/8/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Defendant LUNUAOE's Unopposed Motion to extend deadline to answer or otherwise respond 52 is granted to 7/18/25. Motion hearing date of 7/8/25 is stricken. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Sony Interactive Entertainment LLC by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 7/22/25 at 9:30 a.m. The parties are directed to file a joint status report updating the Court on what remains in the case by 7/17/25. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants, with the exception of Defendant Nos. 76 and 86 [47] is granted. Enter Default Judgment Order. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 7/9/2025. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order 57 in the amount of $150,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 57 in the amount of $150,000 as to certain defendants

STATUS Report per 56 (Joint) by Sony Interactive Entertainment LLC

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 10/15/25 at 9:30 a.m. The parties' rule 26(a)(1) disclosures shall be served by 8/1/25. All fact discovery shall be noticed in time to be completed by 9/30/25. The parties are directed to file a joint status report by 10/10/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Sony Interactive Entertainment LLC as to certain defendant

FULL SATISFACTION of Judgment regarding order 57 in the amount of $150,000 as to certain defendant

NOTICE by CHITONG Co.Ltd Rule 26(a)(1) Initial Disclosures

MINUTE entry before the Honorable Jorge L. Alonso: Defendant W6Design's motion to dismiss 39 is denied as moot in light of the notice 40 that it has been voluntarily dismissed from the case. Notice mailed by Judge's staff

STIPULATION of Dismissal as to Defendant CHITONG Co.Ltd

MINUTE entry before the Honorable Jorge L. Alonso: A stipulation to dismiss has been filed. Defendant CHITONG Co. Ltd (Def. No. 76) is dismissed with prejudice. Status hearing previously set for 10/15/25 is stricken. Civil case terminated.

MAILED trademark report with order dated 9/2/2025 to Patent Trademark Office, Alexandria VA

MAILED copyright report with order dated 9/2/2025 to Registrar, Washington DC