2025-cv-07240

COMPLAINT filed by FRIDA KAHLO CORPORATION; Filing fee $ 405, receipt number AILNDC-23684109.

Ex. 1 - TM Registrations

(Request for Reassignment)

Exhibit Ex. 1 - TM Registrations

Declaration of Matthew A. Werber

(Summons - Served July 25, 2025)

Exhibit A - Defaulting Defendant

(Supplemental Ex.- Temu)

CIVIL Cover Sheet

Ex. 2 - CBP

Exhibit Ex. 2 - CBP

Exhibit A - Amazon

Declaration of Matthew A. Werber

SEALED EXHIBIT by Plaintiff FRIDA KAHLO CORPORATION -- Schedule A to the Complaint -- regarding complaint 1

Ex. 3 - IP Rights

Exhibit Ex. 3 - IP Rights

Exhibit B - Hague

Exhibit A to the Declaration of Matthew A. Werber

MOTION by Plaintiff FRIDA KAHLO CORPORATION to seal document exhibit 3

(Ex. 4 - DHS)

Exhibit Ex. 4 - DHS

Exhibit C - Temu

Exhibit B to the Declaration of Matthew A. Werber

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FRIDA KAHLO CORPORATION

(Exhibit Ex. 5 - Amended Schedule A)

(Unpublished)

Unpublished

ATTORNEY Appearance for Plaintiff FRIDA KAHLO CORPORATION by Matthew A. Werber

(Other Unpublished)

CASE ASSIGNED to the Honorable Robert W. Gettleman. 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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Executive Committee: Case reassigned to the Honorable April M. Perry for all further proceedings pursuant to 28 USC 294(b). Mailed notice

MINUTE entry before the Honorable April M. Perry: Plaintiff's Motion to Seal 4 is granted. It appearing that the case filed is a "Schedule A" case, Plaintiff is directed to the Court's standing order on its website directing the filing of the Court's Schedule A Template within 14 days. Upon review of the complaint, the Court sua sponte raises the propriety under Federal Rule of Civil Procedure 20(a)(2) of joining 84 defendants to this action. See, e.g, Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). Plaintiff should reference this Court's opinion in Zaful v. Schedule A Defs., 24-cv-11111, Doc. 12 (N.D. Ill. Jan. 10, 2025), where the Court expressed its views on joinder in such cases. By 7/17/2025, Plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the above cases. In the alternative, Plaintiff has leave to file an amended complaint by 7/17/2025 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Mailed notice. (jcc,)

ATTORNEY Appearance for Plaintiff Frida Kahlo Corporation by Peter Krusiewicz

AMENDED complaint by Frida Kahlo Corporation against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

MOTION by Plaintiff Frida Kahlo Corporation for Expedited Discovery and Electronic Service

NOTICE of Motion by Matthew A. Werber for presentment of motion for miscellaneous relief, 13 before Honorable April M. Perry on 7/24/2025 at 10:00 AM.

MINUTE entry before the Honorable April M. Perry: Plaintiff's Motion for Expedited Discovery and Electronic Service 13 is granted. Expedited discovery is warranted to identify Defendant. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with an online marketplace defendant. The Court strikes the motion hearing set for 7/24/2025. Enter order. Mailed notice. (jcc,)

ORDER for Leave to Conduct Expedited Discovery and Service of Process by E-Mail and/or Electronic Publication. Signed by the Honorable April M. Perry on 7/16/2025. Mailed notice. (jcc,)

ENTERED IN ERROR. Modified on 7/24/2025.

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

NOTICE of Correction regarding summons issued (court participant) 18

SUMMONS Returned Executed by Frida Kahlo Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 7/25/2025, answer due 8/15/2025.

MINUTE entry before the Honorable April M. Perry: There has been no activity on this docket since 7/25/2025, when the summons in this matter was returned executed 21. The parties are asked to file a joint initial status report, consistent with the template on Judge Perry's website, by 9/16/2025. If Plaintiff has had no communication from Defendant, Plaintiff shall either file a motion for entry of default or the initial status report on its own. Mailed notice. (jcc,)

MOTION by Plaintiff Frida Kahlo Corporation for default judgment as to - Defaulting Defendant -, MOTION by Plaintiff Frida Kahlo Corporation for entry of default

MEMORANDUM by Frida Kahlo Corporation in support of motion for default judgment, motion for entry of default 23

MINUTE entry before the Honorable April M. Perry: Plaintiff's motion for default judgment 23 is taken under advisement. Based on its review of the motion, the Court requests supplemental materials from Plaintiff prior to the hearing. Specifically, the Court requests as an exhibit screenshots of defendant's Temu listing. Plaintiff's motion for default judgment will be heard on 10/15/2025, at 10:00 a.m. in person in Courtroom 1725. Plaintiff must serve a copy of this minute order upon Defendant within two business days of its entry on the docket and promptly file proof of that service. Mailed notice. (jcc,)

CERTIFICATE of Service by Peter Krusiewicz on behalf of Frida Kahlo Corporation regarding order on motion for default judgment, order on motion for entry of default, set motion and R&R deadlines/hearings, 25

SUPPLEMENT to motion for default judgment, motion for entry of default 23