2026-cv-01871

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. (Filing Fee $ 405.00, Receipt Number BNYSDC-32508275)Document filed by Toho Co., Ltd.

Exhibit 1 - Trademark Registrations

Exhibit 2-1 Copyright Registrations

Exhibit 2-2 Copyright Registrations

Exhibit 2-3 Copyright Registrations

CIVIL COVER SHEET filed.

AO 120 FORM TRADEMARK - NOTICE OF SUBMISSION BY ATTORNEY. AO 120 Form Patent/Trademark for case opening submitted to court for review.

AO 121 FORM COPYRIGHT - NOTICE OF SUBMISSION BY ATTORNEY. AO 121 Form Copyright for case opening submitted to court for review.

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Hankyu Hanshin Holdings, Inc., Other Affiliate H2O Retailing Corporation for Toho Co., Ltd. Document filed by Toho Co., Ltd.

MOTION to Seal certain documents. Document filed by Toho Co., Ltd.

***SEALED***REDACTION to [1] Complaint, Shedule A Defendant list by Toho Co., Ltd.Motion or Order to File Under Seal: [6].

***SEALED***REDACTION to [1] Complaint, Exhibit 3 - infringing evidence by Toho Co., Ltd.Motion or Order to File Under Seal: [6].

EX PARTE MOTION for Temporary Restraining Order. Document filed by Toho Co., Ltd. (Refer to ECF Rule 13.19(b) and (c) for directions regarding promptly alerting the court to this filing.)

MEMORANDUM OF LAW in Support re: [9] EX PARTE MOTION for Temporary Restraining Order. Document filed by Toho Co., Ltd.

DECLARATION of Shengmao Mu in Support re: [9] EX PARTE MOTION for Temporary Restraining Order. Document filed by Toho Co., Ltd.

DECLARATION of JAY HARVEY PARAGOSO in Support re: [9] EX PARTE MOTION for Temporary Restraining Order. Document filed by Toho Co., Ltd.

***SEALED***REDACTION to [9] EX PARTE MOTION for Temporary Restraining Order., [11] Declaration in Support of Motion, [10] Memorandum of Law in Support of Motion Exhibit 4 - Plaintiff's effort to locate Defendants's addresses by Toho Co., Ltd.Motion or Order to File Under Seal: [6].

PROPOSED ORDER. Document filed by Toho Co., Ltd. Related Document Number: [9]. Proposed Order to be reviewed by Clerk's Office staff.

***SEALED***REDACTION to [1] Complaint, Unredacted Complaint by Toho Co., Ltd.Motion or Order to File Under Seal: [6].

***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED ORDER. Notice to attorney Shengmao Mu to RE-FILE Document No. [14] Proposed Order. The filing is deficient for the following reason(s): the wrong event type was used to file the proposed order. Re-file the document using the event type Proposed Order to Show Cause With Emergency Relief found under the event list Proposed Orders - select the correct filer/filers - attach the correct signed (scanned signature image) and dated PDF. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Shengmao Mu to RE-FILE Document No. [1] Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. If the deficiency/deficiencies are not corrected within five (5) days per Amended Standing Order 15-mc-00131 this case will be administratively closed. Initial Pleading due by 3/16/2026. (Text entry; no document attached.)

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Unassigned. (Text entry; no document attached.)

Case Designated ECF. (Text entry; no document attached.)

***NOTICE TO ATTORNEY TO ELECTRONICALLY FILE RELATED CASE STATEMENT. Notice to Attorney Shengmao Mu, for non compliance with Local Rule 13 of the Division of Business Among Judges. Attorney must electronically file the Related Case Statement. Use the event type Statement of Relatedness found under the event list Other Documents. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Shengmao Mu. The following case opening statistical information was erroneously selected/entered: Cause of Action code 15:44; County code Albany;. The following correction(s) have been made to your case entry: the Cause of Action code has been modified to 15:1114; the County code has been modified to XX Out of U.S.;. Corrections were updated as per the Civil Cover Sheet. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED ORDER. Notice to attorney Shengmao Mu to RE-FILE Document No. [14] Proposed Order. The filing is deficient for the following reason(s): the wrong event type was used to file the proposed order. Re-file the document using the event type Proposed Order to Show Cause With Emergency Relief found under the event list Proposed Orders - select the correct filer/filers - attach the correct signed (scanned signature image) and dated PDF. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Shengmao Mu to RE-FILE Document No. [1] Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. If the deficiency/deficiencies are not corrected within five (5) days per Amended Standing Order 15-mc-00131 this case will be administratively closed. Initial Pleading due by 3/16/2026. (Text entry; no document attached.)

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Unassigned. (Text entry; no document attached.)

***NOTICE TO ATTORNEY TO ELECTRONICALLY FILE RELATED CASE STATEMENT. Notice to Attorney Shengmao Mu, for non compliance with Local Rule 13 of the Division of Business Among Judges. Attorney must electronically file the Related Case Statement. Use the event type Statement of Relatedness found under the event list Other Documents. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Shengmao Mu. The following case opening statistical information was erroneously selected/entered: Cause of Action code 15:44; County code Albany;. The following correction(s) have been made to your case entry: the Cause of Action code has been modified to 15:1114; the County code has been modified to XX Out of U.S.;. Corrections were updated as per the Civil Cover Sheet. (Text entry; no document attached.)

AO 120 FORM TRADEMARK - CASE OPENING - SUBMITTED. In compliance with the provisions of 15 U.S.C. 1116, the Director of the U.S. Patent and Trademark Office is hereby advised that a court action has been filed on the following trademark(s) in the U.S. District Court Southern District of New York. Director of the U.S. Patent and Trademark Office electronically notified via Notice of Electronic Filing (NEF).

AO 121 FORM COPYRIGHT - CASE OPENING - SUBMITTED. In compliance with the provisions of 17 U.S.C. 508, the Register of Copyrights is hereby advised that a court action has been filed on the following copyright(s) in the U.S. District Court Southern District of New York. Form e-mailed to Register of Copyrights.

ORDER TO SHOW CAUSE FOR PRELIMINARY INJUNCTION AND TEMPORARY RESTRAINING ORDER: Based on the foregoing findings of fact and conclusions of law, Plaintiff's Application is hereby GRANTED and it is ORDERED as follows: 1.As sufficient causes have been shown, Defendants are temporarily enjoined and restrained from engaging in any of the following conduct pending the return date of the Application as referenced below:a.Cease and refrain from manufacturing, advertising, offering for sale,selling, distributing, destroying, selling off, transferring, or otherwise disposing of any Infringing Products;b.Cease and refrain from manufacturing, advertising, offering to sell, selling,reproducing, or distributing any goods utilizing the GODZILLA IP, or any confusingly similar goods, other than genuine products manufactured or distributed by Plaintiff or its authorized manufacturers and distributors;c.Cease and refrain from destroying, selling off, transferring, or otherwisedisposing of any documents, electronically stored information, or financial records or assets of any kind relating to the manufacture, importation, sale, offer for sale, distribution, or transfer of any Infringing Products; d.Cease and refrain from using the GODZILLA IP on or in connection with any Seller Alias that any Defendant may own, operate, or control on any Marketplace;e.Cease and refrain from any and all use of the GODZILLA IP as metatags,on any webpage (including the title of any web page), in any advertising links to other websites, from search engines databases or cache memory,or any other form of use of such terms that are visible to a computer user or serves to direct computer searches to Seller Aliases registered, owned or operated by any Defendant on any Marketplace; and;f.Cease and refrain from altering, disabling, closing, or transferring ownership of any seller alias on any Marketplace during the pendency of this action, or until further Order of the Court. The Clerk of Court is directed to issue a single original summons in the name of "The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A To The Complaint" that shall apply to all Defendants. Plaintiff shall deposit with the Court One Thousand Five Hundred Dollars ($1,500.00), either cash, cashier's check or surety bond, as security, which amount was determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Plaintiff shall file unsealed versions of Plaintiff's Schedule A attached to the Complaint, Plaintiff's unredacted version of the Complaint, Exhibit 3 showing the Defendant Internet Stores' infringement, and Exhibit 4 showing Plaintiff's efforts to verify Defendants' addresses using the CM/ECF system prior to the expiration of this Order when Financial Institutions have confirmed that Defendants' funds are frozen and that Plaintiff properly serves Defendants with the Summon and the Complaint, whichever comes later. This Temporary Restraining Order without notice is entered on March 6, 2026, and shall remain in effect for fourteen (14) days. (And as further set forth herein.) (Show Cause Hearing set for 3/20/2026 at 02:00 PM before Judge Katherine Polk Failla., Show Cause Response due by 3/13/2026.), Motions terminated: 6 MOTION to Seal certain documents. filed by Toho Co., Ltd., 9 EX PARTE MOTION for Temporary Restraining Order. filed by Toho Co., Ltd. (Signed by Part One Judge Katherine Polk Failla on 3/6/2026) (jca) Transmission to Finance Unit (Cashiers) for processing.

Transmission to the Civil Case Openings Clerk. Transmitted re: 18 Order to Show Cause, to the Civil Case Openings Clerk for case processing. (Text entry; no document attached.)

STATEMENT OF RELATEDNESS re: that this action be filed as related to 26-cv-1514. Document filed by Toho Co., Ltd.

***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED ORDER. Notice to attorney Shengmao Mu to RE-FILE Document No. 14 Proposed Order. The filing is deficient for the following reason(s): the wrong event type was used to file the proposed order. Re-file the document using the event type Proposed Order to Show Cause With Emergency Relief found under the event list Proposed Orders - select the correct filer/filers - attach the correct signed (scanned signature image) and dated PDF. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Shengmao Mu to RE-FILE Document No. 1 Complaint. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. If the deficiency/deficiencies are not corrected within five (5) days per Amended Standing Order 15-mc-00131 this case will be administratively closed. Initial Pleading due by 3/16/2026. (Text entry; no document attached.)

Case Designated ECF. (Text entry; no document attached.)

CASE REFERRED to Judge Victor Marrero as possibly related to 26-cv-1514. (Text entry; no document attached.)

PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Toho Co., Ltd. Related Document Number: 9. Proposed Order to Show Cause to be reviewed by Clerk's Office staff.

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Unassigned. (Text entry; no document attached.)

***NOTICE TO ATTORNEY TO ELECTRONICALLY FILE RELATED CASE STATEMENT. Notice to Attorney Shengmao Mu, for non compliance with Local Rule 13 of the Division of Business Among Judges. Attorney must electronically file the Related Case Statement. Use the event type Statement of Relatedness found under the event list Other Documents. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Shengmao Mu. The following case opening statistical information was erroneously selected/entered: Cause of Action code 15:44; County code Albany;. The following correction(s) have been made to your case entry: the Cause of Action code has been modified to 15:1114; the County code has been modified to XX Out of U.S.;. Corrections were updated as per the Civil Cover Sheet. (Text entry; no document attached.)