2025-cv-08485

COMPLAINT filed by BlushCrunch Studio LLC; Filing fee $ 405, receipt number AILNDC-23788074.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Andrew D. Burnham

Exhibit A

Declaration of Madeline B. Halgren

SEALED EXHIBIT by Plaintiff BlushCrunch Studio LLC Schedule A regarding complaint[1]

Exhibit A

MOTION by Plaintiff BlushCrunch Studio LLC for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BlushCrunch Studio LLC

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Andrew Daniel Burnham

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Madeline Halgren

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 3). (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.)

BOND in the amount of $96,000.00 check, Receipt No. 100023416, posted by BlushCrunch Studio LLC (Text entry; no document attached.)

MOTION by Plaintiff BlushCrunch Studio LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by BlushCrunch Studio LLC in support of motion for temporary restraining order[10]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[11]

DECLARATION of Mariana Ruiz regarding memorandum in support of motion[11]

SEALED EXHIBIT by Plaintiff BlushCrunch Studio LLC Exhibit 2 - Parts 1-2 regarding declaration[13]

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

MEMORANDUM by BlushCrunch Studio LLC in support of motion for miscellaneous relief[15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[10], motion for miscellaneous relief[15], motion for leave to file[3] before Honorable Jorge L. Alonso on 8/12/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Motion hearing previously set for 8/12/25 is stricken and reset to 8/14/25 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: Plaintiff's ex parte motions 3 10 15 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 $96,000--$1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 8/14/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 8/13/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by BlushCrunch Studio LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff BlushCrunch Studio LLC

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

MOTION by Plaintiff BlushCrunch Studio LLC for extension of time of Temporary Restraining Order

MEMORANDUM by BlushCrunch Studio LLC in support of extension of time[25]

DECLARATION of Andrew D. Burnham regarding memorandum in support of motion[26]

NOTICE of Motion by Andrew Daniel Burnham for presentment of extension of time[25] before Honorable Jorge L. Alonso on 8/27/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order [25] is granted. The temporary restraining order is extended for 14 days to 9/10/25. Motion hearing date of 8/27/25 is stricken. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by BlushCrunch Studio LLC as to certain defendants

MOTION by Plaintiff BlushCrunch Studio LLC for preliminary injunction

MEMORANDUM by BlushCrunch Studio LLC in support of motion for preliminary injunction[31]

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for preliminary injunction[31] before Honorable Jorge L. Alonso on 9/10/2025 at 09:30 AM.

SUMMONS Returned Executed by BlushCrunch Studio LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/5/2025, answer due 9/26/2025.