Beijing Pop Mart Cultural & Creative Co., Ltd. et al v. The Partnerships and Unincorporated Associations Identified on Schedule A

COMPLAINT filed by Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd.; Filing fee $ 405, receipt number AILNDC-25677650.

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SEALED EXHIBIT by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. Exhibit 6, Parts 1 to 13 regarding complaint, [1]

SEALED EXHIBIT by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. Exhibit 6, Parts 14 to 29 regarding complaint, [1]

Exhibit 6, Part 14

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(Exhibit 6, Part 29)

SEALED EXHIBIT by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. Schedule A regarding complaint, [1]

MOTION by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd.

Notice of Claims Involving Trademarks by Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd.

ATTORNEY Appearance for Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. by Alexander Whang

ATTORNEY Appearance for Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. by Victor Benjamin Chahin, Jr

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 Albert Berry, III. Case assignment: Random assignment. (Civil Category 2).

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. for Leave to File Certain Documents Under Seal

AMENDED complaint by Pop Mart (Singapore) Holding Pte. Ltd., Beijing Pop Mart Cultural & Creative Co., Ltd. against The Partnerships and Unincorporated Associations Identified on Schedule A

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SEALED EXHIBIT by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. Exhibit 6, Parts 1-29 regarding amended complaint, [15]

Exhibit 6, Part 1

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Exhibit 6, Part 28

(Exhibit 6, Part 29)

SEALED EXHIBIT by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. Amended Schedule A regarding amended complaint, [15]

MOTION by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. for Entry of a Temporary Restraining Order, Including a Temporary Injunction and a Temporary Asset Restraint as to certain Defendants

MEMORANDUM by Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. in support of motion for miscellaneous relief, [18]

Declaration of Martin F. Trainor

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DECLARATION of Robert Johns regarding memorandum in support of motion, [19]

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Exhibit 2

SEALED EXHIBIT by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. Exhibit 3, Parts 1-29 regarding declaration[20]

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Exhibit 3, Part 28

(Exhibit 3, Part 29)

MOTION by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. for Leave to File Certain Documents Under Seal

MOTION by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. for Authorization to Provide Electronic Notice of Any Forthcoming Motion for Entry of a Preliminary Injunction

MOTION by Plaintiffs Beijing Pop Mart Cultural & Creative Co., Ltd., Pop Mart (Singapore) Holding Pte. Ltd. for Expedited Discovery

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.