CAPCOM CO., LTD. v. The Partnerships and Unincorporated Associations Identified on Schedule A

COMPLAINT filed by CAPCOM CO., LTD.; Filing fee $ 405, receipt number AILNDC-25279331.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff CAPCOM CO., LTD. Schedule A regarding complaint[1]

MOTION by Plaintiff CAPCOM CO., LTD. for Leave to File CertainDocuments Under Seal

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff CAPCOM CO., LTD. by Martin Francis Trainor

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by CAPCOM CO., LTD.

ATTORNEY Appearance for Plaintiff CAPCOM CO., LTD. by Victor Benjamin Chahin, Jr

ATTORNEY Appearance for Plaintiff CAPCOM CO., LTD. by Alexander Whang

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.

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 2).

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file certain documents under seal [3] is granted. Mailed notice.

MOTION by Plaintiff CAPCOM CO., LTD. for Entry of a Temporary Restraining Order, Including a Temporary Injunction and a Temporary Asset Restraint as to Certain Defendants

MEMORANDUM by CAPCOM CO., LTD. in support of motion for miscellaneous relief[10]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Robert Johns regarding memorandum in support of motion[11]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff CAPCOM CO., LTD. Exhibit 3, Parts 1-17 regarding declaration[12]

MOTION by Plaintiff CAPCOM CO., LTD. for Authorization to Provide Electronic Notice of Any Forthcoming Motion for Entry of a Preliminary Injunction

MOTION by Plaintiff CAPCOM CO., LTD. for Expedited Discovery

Exhibit 1

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 and a temporary asset restraint as to certain defendants [10] is granted. Ex parte motion for authorization to provide electronic notice of any forthcoming motion for entry of a preliminary injunction [14] is granted. Motion for expedited discovery [15] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 7/6/2026. Mailed notice.

SEALED Order Authorizing Expedited Discovery. Signed by the Honorable Thomas M. Durkin on 7/6/2026. Mailed notice.

CIVIL BOND in the amount of $ 34,000 posted by CAPCOM CO., LTD.

MOTION by Plaintiff CAPCOM CO., LTD. to Extend the Temporary Restraining Order

MEMORANDUM by CAPCOM CO., LTD. in support of motion for miscellaneous relief[21]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [21] is granted. The Temporary Restraining Order entered on 7/6/2026 [18] is extended by a period of fourteen (14) days until 8/3/2026. Mailed notice.

MOTION by Plaintiff CAPCOM CO., LTD. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by CAPCOM CO., LTD. in support of motion for preliminary injunction[24]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [24] is set for 8/3/2026 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.