2025-cv-09113

COMPLAINT filed by Collectanea J. Limited, a Hong Kong Limited Corporation; JURY DEMAND. Filing fee $ 405, receipt number AILNDC-23828443.

Exhibit One: Registration with Samples

Exhibit One: Trademark Registration

(Exhibit Five: Evidence)

Exhibit One (Evidence)

CIVIL Cover Sheet

Exhibit Two: CBP Report

Exhibit Two: Copyright Registration with Sample

Declaration of L. Pittaway

ATTORNEY Appearance for Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation by Lydia Pittaway

Exhibit Three: Law Review Article

(Exhibit Three: Copyright Registration with Samples)

(Exhibit One to Decl. of L. Pittaway)

SEALED DOCUMENT by Plaintiff Collectanea J. Limited, a Hong Kong Limited Corporation SCHEDULE A

(Exhibit Four: HSI Report)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collectanea J. Limited, a Hong Kong Limited Corporation

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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 $2,000 check, Receipt No. 100023235, posted by Collectanea J. Limited (Text entry; no document attached.)

MAILED Copyright report to Registrar, Washington DC

DECLARATION of YU CHUNG TING

SEALED DOCUMENT by Plaintiff Collectanea J. Limited Exhibits Four and Five to the Declaration of Yu Chung Ting: Exhibit Four: Schedule A;

MOTION by Plaintiff Collectanea J. Limited to seal

MOTION by Plaintiff Collectanea J. Limited PLAINTIFFS MOTION FOR LEAVE TO CONDUCT EXPEDITED THIRD-PARTY DISCOVERY AND MEMORANDUM OF LAW

MOTION by Plaintiff Collectanea J. Limited FOR ELECTRONIC SERVICE OF PROCESS PURSUANT TO FED. R. CIV. P. 4(f)(3)

MOTION by Plaintiff Collectanea J. Limited for temporary restraining order

SEALED DOCUMENT by Plaintiff Collectanea J. Limited MEMORANDUM ON THE ISSUE OF JOINDER

NOTICE of Motion by Lydia Pittaway for presentment of motion for miscellaneous relief 11, motion for temporary restraining order 12, motion to seal 9, motion for miscellaneous relief 10 before Honorable Edmond E. Chang on 8/14/2025 at 08:30 AM.

SEALED Temporary Restraining Order. Signed by the Honorable Edmond E. Chang on 8/13/2025. Mailed notice. (jn,)

MINUTE entry before the Honorable Edmond E. Chang: On review of the memorandum on joinder, R. 13, the Court finds that the two Defendants are properly joined. The two online sellers use exactly the same advertising text that is relatively unique, that is, a 17-word sentence in a somewhat unusual sequence (including using the same word twice for no particular reason). More importantly, in the product description, the sellers use the same three sentences with the same unique grammatical errors. (2.) In this copyright-infringement case, the Plaintiff's motion 12 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 9 for leave to file under seal is granted in light of the asset-restraint goal. By 08/20/2025, the Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the names of Defendants and omitting Schedule A). The Plaintiff's motion 11 for electronic service of process and motion 10 for early discovery are granted to obtain information in order to provide reasonable notice. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 08/29/2025 at 8:30 a.m. The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 08/22/2025. Mailed notice. (jn,)

TEMPORARY Restraining Order Signed by the Honorable Edmond E. Chang on 8/13/2025. Mailed notice

REGISTRY Deposit Information Form by Collectanea J. Limited. (Received at the Intake Counter on 08/14/2025)

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

MOTION by Plaintiff Collectanea J. Limited TO EXTEND THE TEMPORARY RESTRAINING ORDER ENTERED AUGUST 13, 2025 [D.E. 17]

NOTICE of Motion by Lydia Pittaway for presentment of motion for miscellaneous relief 21 before Honorable Edmond E. Chang on 8/26/2025 at 08:30 AM.

MINUTE entry before the Honorable Edmond E. Chang: In light of the same circumstances that justified entry of the TRO, the extension motion 21 is granted through 09/10/2025. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The tracking status hearing of 08/29/2025 is reset to 09/12/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 09/05/2025, or else the Plaintiff shall file the report if the Defendant has not appeared. Emailed notice

MOTION by Plaintiff Collectanea J. Limited for preliminary injunction

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction [25] is granted. Given the answer deadline of 09/26/2025, R. 27, the tracking status hearing of 09/12/2025 is reset to 10/10/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 10/03/2025. If the Defendants do not answer by 09/26/2025, then they shall be deemed in default, and the Plaintiff shall instead file a motion for default judgment in a sum certain by 10/03/2025. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 09/08/2025. Emailed notice