2025-cv-08426

COMPLAINT filed by TV Tokyo Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-23783946.

Exhibit 1

(Exhibit 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by John Wilson

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Elizabeth Aubree Miller

MOTION by Plaintiff TV Tokyo Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation

Notice of Claims Involving Trademarks by TV Tokyo Corporation

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.

NOTICE of Motion by Michael A. Hierl for presentment of motion to seal document 8 before Honorable LaShonda A. Hunt on 7/29/2025 at 10:00 AM.

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.

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. Plaintiff names 92 Defendants in this single case 9. However, after reviewing the complaint 1 and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all Defendants. See Fed. R. Civ. P. 20(a)(2); Viking Arm AS v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). In addition, because Plaintiff filed a form complaint with generic allegations about "Defendant Internet Stores" allegedly violating federal trademark laws without any details whatsoever about the defendants identified in Schedule A, the Court doubts that the complaint satisfies the requirements of with Federal Rules of Civil Procedure 8 and 10. Accordingly, by 8/8/25, Plaintiff must either (a) file an amended complaint and an amended Schedule A, which may be provisionally filed under seal if warranted, with a subset of Defendants, and the amended complaint must set forth with specific allegations about each defendant identified in Plaintiff's amended Schedule A, including allegations that explain how each defendant is properly joined with each other and labeled exhibits that contain screenshots or other information specific to Defendants listed on amended Schedule A only; or (b) file a supplemental memorandum that refers to specific facts alleged in its filings and provides citations to specific screenshots associated with each Schedule A Defendant to demonstrate that joinder is proper and the allegations are sufficient under Rules 8 and 10. Otherwise, this case will be dismissed. Counsel is admonished to review and comply with all court procedures and applicable rules. Plaintiff's motion to seal 8 is taken under advisement until joinder is resolved. The motion hearing set for 7/29/25 12 is stricken. Mailed notice (gel,)

AMENDED complaint by TV Tokyo Corporation against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

(Exhibit 2)

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Amended Schedule A

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to file under seal 8 is granted. Schedule A 9 and Amended Schedule A 18 shall remain sealed until further court order. By 8/18/25, Plaintiff is ordered to file a status report proposing next steps in this case, if no other appropriate relief has not been sought by that date. Mailed notice (gel,)

STATUS Report by TV Tokyo Corporation

MINUTE entry before the Honorable LaShonda A. Hunt: The Court has reviewed Plaintiff's status report 20. This case was filed on 7/23/25 with several documents temporarily sealed. But at this point, Plaintiff has not presented exigent circumstances that would justify continued sealing of the defendant or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 25 C 2937, 2025 WL 2299593 at *7 (N.D. Ill. Aug. 8, 2025)(Kness, J.). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000). For those reasons, the Clerk of Court is directed to unseal the documents filed at 9 18 and to update the docket and caption to reflect that Defendant's name is "zhangweijuan." If no other relief has been sought, Plaintiff is ordered to file an updated status report by 9/3/25 setting forth proposed next steps in this case. Mailed notice (gel,)

MOTION by Plaintiff TV Tokyo Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff TV Tokyo Corporation for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by TV Tokyo Corporation in support of motion for temporary restraining order, 23

Declaration Saiki Declaration

Exhibit 1

Exhibit 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 to Saiki Declaration regarding memorandum in support of motion, 24

NOTICE of Motion by Michael A. Hierl for presentment of motion for leave to file excess pages 22, motion for temporary restraining order, 23 before Honorable LaShonda A. Hunt on 8/26/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's ex parte motion for a TRO and other relief 23 is denied without prejudice. Plaintiff has not come close to meeting the exacting standards of Fed. R. Civ. P. 65(b) to warrant ex parte relief. At a minimum, the Court finds the generic copy-and-paste affidavits fall well short of providing "specific facts" to "clearly show that immediate and irreparable injury, loss or damage will result," let alone demonstrating the required certification from counsel. That is ample reason to deny this extraordinary request. See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A., No. 25 C 2937, 2025 WL 2299593 at *4-7 (N.D. Ill. Aug. 8, 2025) (Kness, J.) ("Given that any irreparable harm wrought by infringement can, as with more traditional forms of IP litigation, be addressed through preliminary injunctive relief following an adversarial proceeding, the use of Rule 65(b) to ensure an unimpeded path to a prejudgment asset restraint is unsound."). Plaintiff may be allowed to seek discovery to assist with identifying defendant, but any such request must be presented in a separate motion. Consequently, Plaintiff's motion for leave to file excess pages 22 is denied as moot. Finally, and notwithstanding the Court's prior order expressly finding no grounds for sealing document in this case 21, Plaintiff filed another sealed document 25 a few hours after entry of that order without seeking leave as required under Local Rule 26.2. The Clerk of Court is therefore directed, forthwith, to unseal the documents filed at 9 18, as previously ordered, and the motion at 25, and to update the docket and caption, as previously ordered, to reflect that the lone defendant in this case is "zhangweijuan." Counsel is admonished that further disregard for court orders and the applicable rules will result in a rule to show cause why sanctions, including dismissal of this case, should not be imposed. The 9/3/25 status report deadline stands. Mailed notice. Modified on 8/22/2025.