2025-cv-08509

COMPLAINT filed by Zodiak Kids Studio France; Jury Demand. Filing fee $ 405, receipt number AILNDC-23790609.

Exhibit 1

(Exhibit 2)

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Zodiak Kids Studio France by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Zodiak Kids Studio France by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Zodiak Kids Studio France by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Zodiak Kids Studio France by John Wilson

ATTORNEY Appearance for Plaintiff Zodiak Kids Studio France by Elizabeth Aubree Miller

MOTION by Plaintiff Zodiak Kids Studio France to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Zodiak Kids Studio France Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Zodiak Kids Studio France

Notice of Claims Involving Trademarks by Zodiak Kids Studio France

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.

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. Plaintiff names 231 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 copyright and 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 under seal 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. The motion for leave to file under seal 8 is taken under advisement pending resolution of the joinder issue. The motion hearing set for 7/29/25 12 is stricken. Mailed notice (gel,)

AMENDED complaint by Zodiak Kids Studio France 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 Zodiak Kids Studio France Amended Schedule A

MINUTE entry before the Honorable LaShonda A. Hunt: This case was filed on 7/24/25 with a temporarily sealed Schedule A. But at this point, Plaintiff has not presented exigent circumstances that would justify continued sealing of the defendant's identity. "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 motion for leave to file under seal 8 is denied, and the Clerk of Court is directed to unseal the documents filed at 9 15 and to update the docket and caption to reflect that Defendant's name is "Miku Poster 1 Store." If no other relief has been sought, Plaintiff is ordered to file an updated status report by 9/5/25 setting forth proposed next steps in this case. Mailed notice (gel,)