2025-cv-06122

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23563634.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Complaint for Copyright Infringement regarding complaint, [1]

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal

Declaration of Katherine M. Kuhn in Support of Motion for Leave to File Under Se

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal [4]

(Exhibit 2 to the Declaration of K. Kuhn)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Gokalp Bayramoglu

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 3).

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.

MAILED Copyright Request letter to Plaintiff's counsel of record.

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for leave to file under seal [4] is granted. Mailed notice

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and Electronic Service

Exhibit Memorandum in Support of Motion for Electronic Service

Declaration of Katherine M. Kuhn in Support of Motion for Electronic Service

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages for Temporary Restraining Order

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

Exhibit Memorandum in Support of Motion for Temporary Restraining Order

Declaration of Katherine M. Kuhn in Support of Motion for Temporary Restraining

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Temporary Restraining Order

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for leave to file excess pages[14], motion for service by publication, [13], motion for temporary restraining order, [15] before Honorable Virginia M. Kendall on 6/12/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion due to a Jury Trial proceeding, Motion hearing set for 6/12/2025 is reset for 9:00 AM (PLEASE NOTE TIME CHANGE ONLY).Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 6/12/2025 is reset for 12:30 PM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 6/12/2025. Plaintiff's Motion for Temporary Restraining Order [15] is granted. Order to follow. Temporary Restraining Order shall remain in effect up to and including 6/26/2025. Status hearing set for 6/26/2025 at 9:30 AM. Plaintiff's Motion for leave to file excess pages [14] and Motion for electronic service of process [13] are granted. Mailed notice

TEMPORARY Restraining Order signed by the Honorable Virginia M. Kendall on 6/12/2025. Mailed notice

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time to Extend the Temporary Restraining Order

Exhibit Memorandum in Support of First Motion to Extend Temporary Restraining Or

Declaration of Joseph W. Droter in Support of First Motion to Extend Temporary R

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of extension of time, [21] before Honorable Virginia M. Kendall on 6/26/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion to extend Temporary Restraining Order [21] is granted. Temporary Restraining Order shall remain in effect up to and including 7/10/2025. Status hearing set for 7/10/2025 at 9:30 AM. Motion and Status hearing set for 6/26/2025 are stricken. Mailed notice

SURETY BOND in the amount of $ 5,000.00 posted by Hong Kong Leyuzhen Technology Co. Limited

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Status hearing set for 7/10/2025 is reset for 7/9/2025 at 9:30 AM. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time SECOND Extension of the Temporary Restraining Order

Exhibit Memorandum in Support of Second Motion to Extend the Temporary Restraini

Declaration of Katherine M. Kuhn. in Support of Second Motion to Extend the Temp

Exhibit 1 to the Declaration of K. Kuhn

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of extension of time, [26] before Honorable Virginia M. Kendall on 7/9/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Status and Motion hearing held on 7/9/2025. Plaintiff's Motion for extension of Temporary Restraining Order [26] is granted. Order to follow. Status hearing set for 7/23/2025 at 9:00 AM (Please note time change). Mailed notice

EXTENDED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 7/9/2025. Mailed notice

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to compel third-party platform TikTok

Exhibit A to the Motion to Compel

Exhibit B to the Motion to Compel

Exhibit C to the Motion to Compel

Declaration of Joseph W. Droter in Support of Motion to Compel

Declaration of Heather M. Ikerd in Support of Motion to Compel

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion to compel, [30] before Honorable Virginia M. Kendall on 7/30/2025 at 09:30 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time for Temporary Restraining Order Third Request

Exhibit Memorandum in Support of Third Motion to Extend Temporary Restraining Or

Declaration of Joseph W. Droter in Support of Third Motion to Extend Temporary R

Exhibit 1 to the Declaration of J. Droter

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of extension of time, [32] before Honorable Virginia M. Kendall on 7/30/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearings set for 7/30/2025 are reset for 10:00 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 7/30/2025. Plaintiff's Counsel advised that Tik Tok has failed to respond to Motion to Compel [30]. Rule to Show Cause hearing is set for 8/20/2025 at 9:30 AM. Third Party Platform Tik Tok is Ordered to appear for Rule to Show Cause hearing set for 8/20/2025 at 9:30 AM as to why they should not be held in contempt for failing to comply with Subpoena. If you need to appear virtually, send the attached form to Judge Kendall's courtroom deputy. The courtroom deputy will inform you as to whether your request has been approved. Motion to Compel [30] is entered and continued. Plaintiff's Motion to extend the Temporary Restraining Order [32] is granted. Order to follow. Mailed notice

ORDER Extending Temporary Restraining Order Converting to Preliminary Injunction signed by the Honorable Virginia M. Kendall on 7/30/2025. Mailed notice

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nazly Aileen Bayramoglu

TRANSCRIPT OF PROCEEDINGS held on 07/30/2025 before the Honorable Virginia M. Kendall. Motion Hearing. Order Number: 52707. Court Reporter Contact Information: Gayle A. McGuigan, CSR, RMR, CRR, Gayle_McGuigan@ilnd.uscourts.gov. 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 9/2/2025. Redacted Transcript Deadline set for 9/12/2025. Release of Transcript Restriction set for 11/10/2025.

ATTORNEY Appearance for Respondent TikTok Inc. by Douglas Lawrence Sawyer

RESPONSE by Respondent TikTok Inc. to order on motion to compel, order on motion for extension of time, motion hearing, terminate deadlines and hearings, set/reset hearings, [35] and Opposition to Plaintiff's Motion to Compel (Dkt. 30)

Declaration of Jaime M. Crowe

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

NOTICE by Hong Kong Leyuzhen Technology Co. Limited re order on motion to compel, order on motion for extension of time, motion hearing, terminate deadlines and hearings, set/reset hearings, [35], Response, [40] of Withdraw Motion to Compel TikTok Inc.

MINUTE entry before the Honorable Virginia M. Kendall. Pursuant to Notice of Withdrawal of Plaintiff's Motion to Compel [41], Rule to Show Cause hearing set for 8/20/2025 is stricken due to Tik Tok's compliance. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A on 8/20/2025, answer due 9/10/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for preliminary injunction

Exhibit Memorandum in Support of Motion for Preliminary Injunction

Declaration of Joseph W. Droter in Support of Motion for Preliminary Injunction

Exhibit 1 to the Declaration of J. Droter

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [46] before Honorable Virginia M. Kendall on 8/26/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 8/26/2025 is reset for 9/3/2025 at 10:00 AM and will proceed via Webex. Prior to the hearing, you are directed to cut and paste this hyper link into a browser: https://us-courts.webex.com/join/virginia_kendallilnd.uscourts.gov You can use the dial in option ONLY if you do not have access to a device with video capability: (650)-479-3207, the access code is: 180 698 4009. Mailed notice

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited ONLY as to Defendants 10 and 26 without prejudice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 9/3/2025. Plaintiff's Motion for Preliminary Injunction [46] is granted. Order to follow. Status hearing set for 9/23/2025 at 9:30 AM which will proceed in person unless requested otherwise. Mailed notice

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 9/3/2025. Mailed notice

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 26 Defaulted Defendants

Exhibit Memorandum in Support of Motion for Default and DefaultJudgment

Declaration of Katherine M. Kuhn in Support of Motion for Default and Default Ju

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Motion for Default and Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [52] before Honorable Virginia M. Kendall on 9/23/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 9/23/2025. Plaintiff's Motion for entry of Default and Default Judgment [52] is granted. Enter Order of Default as to Defendants as identified in Schedule A. Default Judgment Order to enter. Mailed notice

DEFAULT Judgment Order signed by the Honorable Virginia M. Kendall on 9/23/2025. Civil case terminated. Mailed notice