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-25467831.

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 Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Capcom Co., Ltd.

Notice of Claims Involving Trademarks by Capcom Co., Ltd.

ATTORNEY Appearance for Plaintiff Capcom Co., Ltd. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Capcom Co., Ltd. by Alexander Whang

ATTORNEY Appearance for Plaintiff Capcom Co., Ltd. by Victor Benjamin Chahin, Jr

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Capcom Co., Ltd. against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Capcom Co., Ltd. Schedule A regarding amended complaint, 12

MOTION by Plaintiff Capcom Co., Ltd. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Capcom Co., Ltd. in support of motion for miscellaneous relief 14

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Robert Johns regarding memorandum in support of motion 15

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Capcom Co., Ltd. Exhibit 3, Parts 1-12 regarding declaration 16

Exhibit 3, Part 1

Exhibit 3, Part 2

Exhibit 3, Part 3

Exhibit 3, Part 4

Exhibit 3, Part 5

Exhibit 3, Part 6

Exhibit 3, Part 7

Exhibit 3, Part 8

Exhibit 3, Part 9

Exhibit 3, Part 10

Exhibit 3, Part 11

(Exhibit 3, Part 12)

MOTION by Plaintiff Capcom Co., Ltd. for Authorization to Provide Electronic Notice of Any Forthcoming Motion for Entry of a Preliminary Injunction

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. Plaintiff's motion for leave to file under seal 3, motion to provide electronic notification of any forthcoming motion for entry of preliminary injunction 18, and motion for a temporary restraining order, including a temporary injunction and a temporary asset restraint, and expedited discovery 14 are granted. At the outset, the Court notes that plaintiff has presented evidence of completed purchases of the allegedly infringing products to customers in Illinois, (Dckt. #17). See Liu v. Monthly, 170 F.4th 1090 (7th Cir. 2026). Moreover, plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order that will be being entered with this order will also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. Expedited discovery is warranted to identify defendants and to implement the asset freeze. If plaintiff intends to file a motion for leave for electronic service, it must comply with the dicates of Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793, 799 (7th Cir. 2026). In Kangol, the Seventh Circuit held that the Hague Service Convention "prohibits service by email in China." Id. at 795. The Court acknowledged, however, that the Convention does not apply if the defendant's address is unknown. Id. at 799. "[C]ourts handling Schedule A cases typically require plaintiffs to make "'reasonably diligent efforts to ascertain and verify [the] defendant's mailing address' before deeming the defendant's address unknown." Id., quoting NBA Props., Inc. v. P'ships and Unincorporated Ass'ns Identified in Schedule "A", 549 F. Supp. 3d 790, 796 (N.D.Ill. 2021). "[B]are assertions regarding the reliability of Defendant[s]' publicly available address[es] are not a substitute for actual diligence." NBA Props., 549 F.Supp.3d at 796. Enter Sealed TRO. Tracking status hearing set for 11/16/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Jeffrey I Cummings on 10/14/2026 Mailed notice

NOTICE of Voluntary Dismissal by Capcom Co., Ltd. as to a certain defendant

SURETY BOND in the amount of $ 10,000.00 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[22]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to extend the TRO [22] is granted. The TRO entered on 10/14/26 is extended to 11/11/26. Mailed notice