ZAG America, LLC et al v. The Partnerships and Unincorporated Associations Identified on Schedule A

COMPLAINT filed by ZAG America, LLC, Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp.; Filing fee $ 405, receipt number AILNDC-25469010.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC Schedule A regarding complaint, [1]

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC

Notice of Claims Involving Trademarks by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC by Alexander Whang

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC by Victor Benjamin Chahin, Jr

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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 certain documents under seal [3] is granted. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction and a Temporary Asset Restraint, as to Certain Defendants

MEMORANDUM by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC in support of motion for miscellaneous relief, [12]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Robert Johns regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC Exhibit 3, Parts 1-4 regarding declaration[14]

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC for Authorization to Provide Electronic Notice of Any Forthcoming Motion for Entry of a Preliminary Injunction

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC 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 [12] is granted. Ex parte motion for authorization to provide electronic notice of any forthcoming motion for entry of a preliminary injunction [16] is granted. Motion for expedited discovery [17] is granted. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Thomas M. Durkin on 8/14/2026. Mailed notice.

SEALED ORDER Authorizing Expedited Discovery. Signed by the Honorable Thomas M. Durkin on 8/14/2026. Mailed notice.

SURETY BOND in the amount of $ 8,000 posted by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC to Extend the Temporary Restraining Order

MEMORANDUM by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC in support of motion for miscellaneous relief[22]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [22] is granted. The Temporary Restraining Order entered on 8/14/2026 is extended by a period of fourteen (14) days until 9/11/2026. Mailed notice.

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC in support of motion for preliminary injunction[26]

Declaration of Martin F. Trainor

Exhibit 1