2025-cv-07396

COMPLAINT filed by Anderson Design Group, Inc. ; Filing fee $ 405, receipt number AILNDC-23700440.

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Anderson Design Group, Inc. Schedule A to the Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Yi Bu

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Anderson Design Group, Inc. by Christopher Romero

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Anderson Design Group, Inc.

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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 report to Registrar, Washington DC.

SEALED DOCUMENT by Plaintiff Anderson Design Group, Inc. Amended Schedule A to Complaint 1 and Schedule A 2

MOTION by Plaintiff Anderson Design Group, Inc. for leave to file under seal

MOTION by Plaintiff Anderson Design Group, Inc. for leave to file excess pages

MEMORANDUM in support of 16 Exparte motion

Exhibit 1

Declaration of Keith A. Vogt

Exhibit 1-2, of Keith A. Vogt's declaration

Declaration 1-2, of Joel Anderson's declaration

(Exhibit 1-2, of Joel Anderson's declaration)

SEALED EXHIBIT by Plaintiff Anderson Design Group, Inc. Sealed Exhibit 2, Declaration of Joel Anderson regarding memorandum in support of motion, 17

(Exhibit 2)

Presentment for Exparte motion 16 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 14, motion for leave to file excess pages 15 before Honorable Edmond E. Chang on 7/17/2025 at 08:30 AM.

MEMORANDUM Establishing that Joinder is Proper

(Exhibit 1)

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of the joinder filings, R. 18, 20, joinder of the two remaining Defendants in Amended Schedule A is proper. In addition to offering the same produces with the same infringed works, most importantly the Defendants use the same unique string of advertising text of 31 words in the exact same sequence. (2.) In this copyright-infringement case, the Plaintiff's motion [16] for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. � 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. �504(b). To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendants, who likely would seek to transfer the money elsewhere. The Plaintiff's motion [14] for leave to file under seal is granted in light of the asset-restraint goal. A redacted version of the TRO (which has already been emailed to the Proposed Order account) will be posted separately. The Plaintiff's motion [15] for extra pages is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 08/01/2025 at 8:30 a.m. The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 07/25/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 07/15/2025. Emailed notice

MOTION by Plaintiff Anderson Design Group, Inc. for preliminary injunction

MOTION by Plaintiff Anderson Design Group, Inc. for default judgment as to The Defendants Identified In Amended Schedule A

MEMORANDUM by Anderson Design Group, Inc. in support of motion for default judgment 33

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 33 before Honorable Edmond E. Chang on 8/20/2025 at 08:30 AM.

ORDER: Given the absence of a timely response to the amended complaint, the motion for default judgment is granted. Statutory damages are awarded in the amount of fifteen-thousand dollars ($15,000) from each Defendant. Given the willfulness established by the default, a permanent injunction is entered. A separate AO-450 judgment shall be entered. The status hearing of 08/26/2025 is vacated. Civil case terminated. (AO-450 judgment attached). Signed by the Honorable Edmond E. Chang on 8/15/2025. Mailed notice. (jn,)