2025-cv-14833

COMPLAINT filed by SM ENTERTAINMENT CO., Ltd.; Filing fee $ 405, receipt number AILNDC-24442330.

Exhibit 1

SEALED EXHIBIT by Plaintiff SM ENTERTAINMENT CO., Ltd. Exhibit 2 - Parts 1-2 regarding complaint[1]

SEALED EXHIBIT by Plaintiff SM ENTERTAINMENT CO., Ltd. Schedule A regarding complaint[1]

MOTION by Plaintiff SM ENTERTAINMENT CO., Ltd. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by SM ENTERTAINMENT CO., Ltd.

Notice of Claims Involving Trademarks by SM ENTERTAINMENT CO., Ltd.

ATTORNEY Appearance for Plaintiff SM ENTERTAINMENT CO., Ltd. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff SM ENTERTAINMENT CO., Ltd. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff SM ENTERTAINMENT CO., Ltd. by Luana Faria De Souza (Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff SM ENTERTAINMENT CO., Ltd. by Rachel Meira Ackerman

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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 SM ENTERTAINMENT CO., Ltd. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by SM ENTERTAINMENT CO., Ltd. in support of motion for temporary restraining order[12]

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

DECLARATION of Jeong Gon Kim regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff SM ENTERTAINMENT CO., Ltd. Exhibit 2 - Parts 1-2 regarding declaration[15]

MOTION by Plaintiff SM ENTERTAINMENT CO., Ltd. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by SM ENTERTAINMENT CO., Ltd. in support of motion for miscellaneous relief[17]

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

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file under seal [4] and motion for electronic service of process [17] are granted. Plaintiff's motion for entry of an ex parte temporary restraining order (etc.) [12] is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 12/29/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 12/23/2025. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 12/15/2025.

Registry Deposit Information Form by SM Entertainment CO., Ltd. (Faria De Souza, Luana)

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff SM Entertainment CO., Ltd. (Faria De Souza, Luana)

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

MOTION by Plaintiff SM Entertainment CO., Ltd. for extension of time of Temporary Restraining Order (Faria De Souza, Luana)

MEMORANDUM by SM Entertainment CO., Ltd. in support of extension of time[27] (Faria De Souza, Luana)

DECLARATION of Luana Faria de Souza regarding memorandum in support of motion[28] (Faria De Souza, Luana)

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of the temporary restraining order [27] is granted; the ex parte TRO entered by the Court on 12/15/2025 is extended through 1/12/2026. The telephonic preliminary injunction hearing set for 12/29/2025 is vacated and reset to 1/12/2026 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction is to be filed by 1/7/2026. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

SURETY BOND in the amount of $ 10,000.00 posted by SM Entertainment CO., Ltd. (Document not scanned).

ATTORNEY Appearance for Defendant EVERRISE by Jianyin Liu

ATTORNEY Appearance for Defendant EVERRISEE by Jianyin Liu

MOTION by Plaintiff SM Entertainment CO., Ltd. for preliminary injunction

Exhibit A

MEMORANDUM by SM Entertainment CO., Ltd. in support of motion for preliminary injunction[34]

Declaration of Luana Faria de Souza

SUMMONS Returned Executed by SM Entertainment CO., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/30/2025, answer due 1/20/2026.

Declaration of Rachel M. Ackerman

Exhibit A

ANSWER to Complaint with Jury Demand by EVERRISEE

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/31/2025: Mailed notice.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/31/2025: Mailed notice.

RESPONSE by EVERRISEEin Opposition to MOTION by Plaintiff SM Entertainment CO., Ltd. for preliminary injunction [34]

MOTION by Attorney Jianyin Liu to withdraw as attorney for EVERRISEE. New address information: Yanping Chen, Room 407, Unit 3, Building A, Xuezi Liyuan, Guanlong Village, Xili Town, Nanshan District, Shenzhen City, Guangdong Province, China 518055

Exhibit Contact Form

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by attorney for defendant EVERRISEE to withdraw [40] is denied, without prejudice to renewal via a motion that must describe the type of entity EVIRRISEE is (e.g., corporation, partnership, sole proprietorship, etc.).

MOTION by Attorney Jianyin Liu to withdraw as attorney for EVERRISEE. New address information: Yanping Chen, No. 407 Unit 3, A Bldg, Xueziliyuan, Guanling Village, Xili Town, Nanshan District, Shenzhen City, Guangdong Province, China

Exhibit Contact Form

MOTION by Plaintiff SM Entertainment CO., Ltd. to compel or, In the Alternative, To Strike Defendant's Filings [37] And [39]

Exhibit A

DECLARATION of Luana Faria de Souza regarding motion to compel[44]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Matthew F. Kennelly: Motion to withdraw appearance of attorney Jianyin Liu as attorney for defendant EVERRISEE is granted [43]. The Clerk is directed to add defendant EVERRISEE's name and address to the docket. EVERRISEE is advised that because it is a limited liability company it may not represent itself in court but rather must be represented by an attorney. Defendant EVERRISEE will be held in default unless an attorney files an appearance by 2/6/2026. Mailed notice.

NOTICE of Voluntary Dismissal by SM Entertainment CO., Ltd. as to a Certain Defendant

MINUTE entry before the Honorable Matthew F. Kennelly: Only one defendant in this case has appeared or responded to the complaint or the motion for preliminary injunction. That defendant appears to be "Musite" (defendant 2). As to that defendant (whose status is in flux at this point given the order of 1/7/2026 (dkt. 46) the ex parte temporary restraining order is extended through 2/9/2026. Plaintiff should file a separate motion for preliminary injunction and/or default judgment if that defendant (referred to in the Court's order as EVERRISEE) does not file an appearance of counsel by 2/6/2026. The telephonic preliminary injunction hearing set for 1/12/2026 is vacated. Plaintiff's motion for entry of a preliminary injunction is granted as to all other defendants [32]. Enter Preliminary Injunction Order As To Certain Defendants. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 3/13/2026 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 3/6/2026. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 1/8/2026. Mailed notice.

NEW PARTIES: KPop Merchandise, Musite, ZHENGGE, A Custom made clothing, ABCHGJJB, An orange sticker, BCGJK, BDGJK, BK Shuangxia Skateboarding, Bob decoration, CLXLPH, DIY PPP, FASGUTNRQ, FashionSparkle, Fortunate funny sticker, fortunate stickers, FZP Home Decor, Gina Hat Selection, GLKLFXJLSS, Good Boy sticker, GXGC, HeadStyleHaven, HHH CASE SHOP, Hi rumiya, HLKTTA, Home Super Helper, HPTLPH, HugInABlankets, Hz Household Goods Series, I will try, inspirational sticker shop, Jam Funny sticker, KANG HOME DIYS, kangkangLetsgo, LuckyGear Textiles, Lybxy, lzpa, MaiChaoWa, Majianshe, MSKDGOLJ, Mw Bong, NestLinen Home Decor, Nice car sticker, NINE POWER MAN, Order surge BBA, PadPulse Mouse Pads, Periwinkle Pipit, PFITNQNG, Phwwcase, PlushCloud Home Textile Blanket, QIMU HOME DIY, QXZMROOM, Shu Home, ShuaiQing shop, SN Wilson, Stephen Car Stickers, Stylish western cowboy, SxfMug, Timestroke Canvas, Top Hatters Cap, TUAFQP Case, WALL ART HYREE, WAN funny sticker, WN funny sticker, wsy C shop, WUFD Funny sticker, XRFB Art, XXX NNN, XXZSHXX, Yiqianxin Sticker, Youth sticker, Ysw XFTextiles, ZQYNKH, zzh seven, zzh shiqi Shop and Colour new world added to case caption.

MINUTE entry before the Honorable Matthew F. Kennelly: Motion to strike 44 is denied without prejudice in light of the Court's orders entered on 1/7/2026 and 1/8/2026.

NOTICE of Voluntary Dismissal by SM Entertainment CO., Ltd. as to Certain Defendants