2026-cv-03730

COMPLAINT filed by Netflix, Inc., Netflix Worldwide Entertainment, LLC, Netflix US, LLC, Netflix Studios, LLC; Filing fee $ 405, receipt number AILNDC-24936030.

Exhibit 1

SEALED EXHIBIT by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. Schedule A regarding complaint[1]

SEALED EXHIBIT by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. Exhibit 2 - Parts 1-2 regarding complaint[1]

MOTION by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc.

Notice of Claims Involving Trademarks by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc.

ATTORNEY Appearance for Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. by Madeline Halgren

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Albert Berry, III. 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.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [4] is granted. Mailed notice.

MOTION by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. in support of motion for temporary restraining order, [13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Jen Dirks regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. Exhibit 2 - Parts 1-2 regarding declaration[16]

MOTION by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Additionally, to the extent Plaintiff also makes a motion for expedited discovery or for an order permitting electronic service of process, Plaintiff should submit a proposed order for that relief that is separate from the proposed order for the TRO and asset restraint. The proposed order for the TRO and asset restraint should name the relevant defendants directly in the order, without reference to Schedule A. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 4/7/2026. Mailed notice.

SEALED Order Authorizing Expedited Discovery and Electronic Service of Process. Signed by the Honorable Thomas M. Durkin on 4/7/2026. Mailed notice.

Registry Deposit Information Form by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc.

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

SURETY BOND in the amount of $ 95,000 posted by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. (document not imaged)

MOTION by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. in support of motion for preliminary injunction 29

(Declaration of Kahlia R. Halpern)

NOTICE of Voluntary Dismissal by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. as to a certain Defendant

SUMMONS Returned Executed by Netflix, Inc., Netflix Worldwide Entertainment, LLC, Netflix US, LLC, Netflix Studios, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/16/2026, answer due 5/7/2026.

Declaration of Madeline B. Halgren

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: At elephone hearingas to the motion for preliminary injunction 29 is set for 4/21/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice. Mailed notice.

ATTORNEY Appearance for Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. by Hannah Alexa Abes

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 4/21/2026. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction is granted [29]. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibit 2 to the Complaint [3], Exhibits to the Declaration of Jen Dirks [17], the Order Authorizing Expedited Discovery and Electronic Service of Process [24], and the TRO [23]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 6/4/2026 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Thomas M. Durkin on 4/21/2026. Mailed notice.

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NOTICE of Voluntary Dismissal by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. as to certain Defendants

ATTORNEY Appearance for Defendant RAW CULTURE by Chengchen Xu

MOTION by Defendant RAW CULTURE for extension of time to file answer

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time to answer 39 is granted. Defendant Raw Culture is to answer or otherwise respond to Plaintiffs' Complaint by 5/28/2026. Mailed notice.

NOTICE of Voluntary Dismissal by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. as to certain Defendants

MOTION by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. for entry of default, MOTION by Plaintiffs Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. for default judgment as to all Defendants with the exception of a certain Defendant

Exhibit A

MEMORANDUM by Netflix Studios, LLC, Netflix US, LLC, Netflix Worldwide Entertainment, LLC, Netflix, Inc. in support of motion for entry of default, motion for default judgment, [44]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion, [45]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [44] before Honorable Thomas M. Durkin on 5/26/2026 at 09:00 AM.

Exhibit A