2025-cv-09595

COMPLAINT filed by Angela Jarman; Jury Demand. Filing fee $ 405, receipt number AILNDC-23874815.

Exhibit A to Complaint

MOTION by Plaintiff Angela Jarman to seal

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's motion to seal [6] is denied, and ex parte motion [8] is denied in part, granted in part. No appearance on 8/28/25 is necessary. The court authorizes early expedited discovery to identify defendants and alternative service of process, but otherwise denies the motion. The court authorizes early, expedited discovery pursuant to Rules 26(d)(1) and 45 to third parties to provide discovery in aid of identifying defendants and serving process. Upon Plaintiff's request, any third party with actual notice of this Order who is providing services for any of the Defendants, or in connection with any of Defendants' Online Marketplaces shall, within seven (7) calendar days after receipt of such notice, provide to Plaintiff expedited discovery, limited to copies of documents and records in such person's or entity's possession or control sufficient to determine the identities and locations of Defendants, their officers, agents, servants, employees, attorneys, and any persons acting in active concert or participation with them, including all known contact information and all associated e-mail addresses. Plaintiff may provide notice of the proceedings in this case to Defendants, including service of process pursuant to Fed. R. Civ. P. 4(f)(3), and any future motions, by electronically publishing a link to the Complaint, this Order, and other relevant documents on a website and by sending an e-mail with a link to said website to the e-mail addresses known to Plaintiff and any e-mail addresses provided for Defendants by third parties. The Clerk of the Court is directed to issue a single original summons in the name of "The Individuals and all other Defendants identified in the Complaint" that shall apply to all Defendants. The combination of providing notice via electronic publication and e-mail, along with any notice that Defendants receive from payment processors, shall constitute notice reasonably calculated under all circumstances to apprise Defendants of the pendency of the action and afford them the opportunity to present their objections. All other ex parte relief is denied. Any evaluation of the merits or likelihood of success in this case against over two dozen defendants should not proceed without adversarial presentation. Based on the court's review of plaintiff's ex parte evidence, the court doubts whether some of the accused listings infringe the copyrighted work. The risk that defendants will move assets is not a good reason to proceed ex parte when extraordinary equitable relief like asset restraints are not to be used in aid of collection of damages, and the court doubts plaintiff has any intention to pursue an accounting as opposed to statutory damages. The clerk shall unseal all filings. Notices mailed.

Exhibit B to Complaint

Exhibit C to Complaint

Exhibit D to Complaint

Schedule A to Complaint