2025-cv-13421

COMPLAINT filed by ShinStar LLC; Filing fee $ 405, receipt number AILNDC-24290989.

Exhibit 1

Exhibit 2

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

SEALED EXHIBIT by Plaintiff ShinStar LLC Exhibit 3 - Parts 1-2 regarding complaint[1]

MOTION by Plaintiff ShinStar LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ShinStar LLC

Notice of Claims Involving Trademarks by ShinStar LLC

ATTORNEY Appearance for Plaintiff ShinStar LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff ShinStar LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff ShinStar LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff ShinStar 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 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.

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

MEMORANDUM by ShinStar LLC in support of motion for temporary restraining order[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

DECLARATION of Zhen Liang regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff ShinStar LLC Exhibit 3 - Parts 1-2 regarding declaration[15]

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

MEMORANDUM by ShinStar LLC in support of motion for miscellaneous relief[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[17], motion for temporary restraining order[12], motion for leave to file[4] before Honorable Jorge L. Alonso on 11/12/2025 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [4] [12] [17] 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 $92,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 11/12/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 11/10/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by ShinStar LLC

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

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

MOTION by Plaintiff ShinStar LLC for extension of time of Temporary Restraining Order

MEMORANDUM by ShinStar LLC in support of extension of time[29]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[30]

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time[29] before Honorable Jorge L. Alonso on 11/20/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order [29] is granted. The temporary restraining order is extended for 14 days to 12/8/25. Motion hearing date of 11/20/25 is stricken. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by ShinStar LLC as to certain Defendants

MOTION by Plaintiff ShinStar LLC for preliminary injunction

Exhibit A

MEMORANDUM by ShinStar LLC in support of motion for preliminary injunction[35]

Declaration of Trevor C. Talhami

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[35] before Honorable Jorge L. Alonso on 12/4/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by ShinStar LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/1/2025, answer due 12/22/2025.

Declaration of Madeline B. Halgren

Exhibit A

ATTORNEY Appearance for Plaintiff ShinStar LLC by Lucas Allen Peterson

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [35] is granted. Enter Preliminary injunction order. 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. Telephonic status hearing set for 1/15/26 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 12/4/2025. Notice mailed by Judge's staff

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