2025-cv-09374

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-23853109.

Exhibit 1

Exhibit 1

(Exhibit A)

(Declaration of Rachel S. Miller)

(Exhibit A)

Declaration of Hannah A. Abes

(Exhibit A- Infringing Evidence Provided by Plaintiff)

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint[1]

Exhibit 2

Exhibit 2

(Exhibit A)

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

Notice of Claims Involving Trademarks by Mattel, Inc.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Albert Berry, III. Case assignment: Random assignment. (Civil Category 2). (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.)

NEW PARTIES: A2UX5ODT6MU7KJ, AMZ_Deqi, AMZ-jingrandianzi, Bettina Toys, desigin fast kolo melo, DEZHOUHUABINWANGLUOXIAOSHOUYOUXIANGONGSI, DiniHinFu, fuqingshishunjindianshangyouxianzerengongsi, hujianxion, ICOCONG, JCIIEWF, jilinshengjixingqingchenjiajuyouxiangongsi, JunMaFZ, Karlsli, kimngocphuonghuyen, LimufanCA, Natural Companion Shop, Oathast Direct, SunZhuoQiangSHOP, XIAOXIAOSU, XuWenXue2025, ZhaoChunYan2025, ZHOU ZHUDEDIAN, best-fix, claemp, CosplayFashionHub, Gametek1, junjijunji, lanlanhh, mototalk, Phone Accessories official, qiaofengqiaofengqiaofeng, rrj-5299, rubo-34, sasagi66644, Toms Jewelry Direct, toylover-888, uudress, wuhanshihuiyupaidianz-0, ying21, FS Zephyr, hmgjhhh, HugCulture, Ink Bloom Apparel, Jzihazz, Kiss my baby Kiss, OceanDealss, Ronin stone, SDHFSN, Sheng xx, Tee Lite, The Soft Wear, Time Warm Blanket, toasaroa, chifumaoyiyouxiangongsi, JIAXINHEHE, pairuimu dianzikejiyouxiangongsi, Remocguys, ToyTrek, Welltop, Yunyao, ZEESUEM and ZLZJIA added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Michael Moore regarding memorandum in support of motion[12]

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 3 - Parts 1-2 regarding declaration[14]

MOTION by Plaintiff Mattel, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for miscellaneous relief[16], motion for temporary restraining order[11] before Honorable Jorge L. Alonso on 8/19/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [11] [16] 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 $68,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 8/19/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 8/18/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Mattel, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mattel, Inc.

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

SURETY BOND in the amount of $ 68,000.00 posted by Mattel, Inc.

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time[26]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[27]

NOTICE of Motion by Rachel S Miller for presentment of extension of time[26] before Honorable Jorge L. Alonso on 9/2/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order 26 is granted. The temporary restraining order is extended for 14 days to 9/15/25. Telephonic status hearing set for 9/15/25 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

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant ALINK OFFICIAL by Jianyin Liu

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction 33

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction 33 before Honorable Jorge L. Alonso on 9/15/2025 at 09:30 AM.

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/10/2025, answer due 10/1/2025.

RESPONSE by ALINK OFFICIALin Opposition to MOTION by Plaintiff Mattel, Inc. for preliminary injunction 33

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

ATTORNEY Appearance for Defendant KARLURE by Zheng Gong

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 10/15/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's reply in support of its motion for preliminary injunction 33 shall be filed by 9/29/25. Defendant KARLURE's response to Plaintiff's Motion for preliminary injunction shall be filed by 10/15/25. Plaintiff's Motion for entry of a preliminary injunction 33 is granted as to the remaining Defendants. The Clerk's office is directed to unseal all previously sealed documents. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. The temporary restraining order is extended as to Defendants ALINK OFFICIAL and KARLURE pending ruling on the motion for preliminary injunction. 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

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 9/15/2025. Notice mailed by Judge's staff