2025-cv-01845

COMPLAINT against SCHEDULE A DEFENDANTS (Filing fee, including Administrative fee, $405, receipt number APAWDC-9220455), filed by ELIZABETH KARLSON.

Magistrate Judge Kezia O.L. Taylor added. (Text entry; no document attached.)

CLERK'S REQUEST FOR CORRECTIVE ACTION re 1 COMPLAINT. ERROR: Filer must submit AO 121 Report on the Filing or Determination of an Action or appeal Regarding a Copyright. CORRECTION: Filer advised to file the Notice within 7 days. The link to the report can be found under Other Forms at: http://www.uscourts.gov/FormsAndFees/Forms/CourtFormsByCategory.aspx (Text entry; no document attached.)

CLERK'S REQUEST FOR CORRECTIVE ACTION re 1 COMPLAINT. ERROR: Filer must submit AO 121 Report on the Filing or Determination of an Action or appeal Regarding a Copyright. CORRECTION: Filer advised to file the Notice within 7 days. The link to the report can be found under Other Forms at: http://www.uscourts.gov/FormsAndFees/Forms/CourtFormsByCategory.aspx (Text entry; no document attached.)

Exhibit 1

Exhibit 2

Exhibit 3

(Civil Cover Sheet)

ORDER that the parties must meet and confer at least 5 business days prior to the filing of such a motion to determine whether it can be avoided. The duty to meet and confer extends to parties appearing pro se. Consistent with the foregoing, motions to dismiss must be accompanied by a certificate of the movant, stating that the moving party has made good faith efforts to confer with the nonmovant(s) to determine whether the identified pleading deficiencies properly may be cured by amendment. The certificate should include when and how the meet and confer took place. The Court will strike any motion to dismiss that does not contain the required certification. IT IS FURTHER ORDERED that: (1) as soon as is practicable, Plaintiff(s) promptly shall serve a copy of this Order upon Defendant(s); (2) all counsel and unrepresented parties must read, know and understand the Local Rules of this Court (see web page at: https://www.pawd.uscourts.gov/sites/pawd/files/lrmanual20181101.pdf); and (3) all counsel and unrepresented parties must familiarize themselves with the undersigned's Practices and Procedures (see https://www.pawd.uscourts.gov/sites/pawd/files/Taylor_Practices_Procedures.pdf) and they will be held responsible for complying with the same. Signed by Magistrate Judge Kezia O. L. Taylor on 12/04/2025.

AO 121 NOTICE by ELIZABETH KARLSON (Attachments: # 1 Additional Register copyrights) Modified text on 12/8/2025; removed from view and refiled at 6.

Disclosure Statement identifying NONE as corporate parent or other affiliate by ELIZABETH KARLSON. Modified text on 12/9/2025; document removed from view and refiled as an Errata at 6.

Errata re 4 Disclosure Statement by ELIZABETH KARLSON. Reason for Correction: wrong document filed.

Errata re 3 AO 121 Notice by ELIZABETH KARLSON. Reason for Correction: wrong document filed.

(Additional Register copyrights)

COPYRIGHT DOCUMENTS ISSUED. Emailed copy of Transmittal Letter, AO 121 Form, Complaint, Exhibits and Docket Sheet to the Register of Copyrights.

Complaint

Docket Sheet

Exhibit 1

Exhibit 2

Exhibit 3

AO 121 Notice

(Additional Registries) (tla)

MOTION for Leave to File Documents Under Seal by ELIZABETH KARLSON.

(Proposed Order)

ORDER GRANTING the 8 MOTION for Leave to File Documents Under Seal. DO NOT electronically file the sealed version of the document until you electronically file the redacted version of the document, using the Redacted Document event, unless otherwise ordered by the Court. You are required to serve the sealed document on counsel using traditional service methods. Decision to Unseal Document deferred. Signed by Magistrate Judge Kezia O. L. Taylor on 12/10/2025.

MOTION for Temporary Restraining Order by ELIZABETH KARLSON.

CLERK'S NOTICE OF REASSIGNMENT. In light of the filing of the 10 Motion for Temporary Restraining Order, this case is no longer assigned to Magistrate Judge Kezia O.L. Taylor and is reassigned to Judge W. Scott Hardy. (Text entry; no document attached.)

NOTICE TO ALL PARTIES: This Court has implemented new Practices and Procedures for Judge W. Scott Hardy effective 1/1/26. These Practices and Procedures can be found on the Court's website at https://www.pawd.uscourts.gov/content/w-scott-hardy-district-judge. Text-only entry. No PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by ELIZABETH KARLSON.

Proposed Order TRO

Declaration Karlson

Declaration Ference

Exhibit 1 - Intellectual Property Rights Seizure Statistics

Exhibit 2 - Northwestern Journal of International Law & Business

Exhibit 3 - Combatting Trafficking in Counterfeit and Pirated Goods

Declaration Odell

1 Composite

2 Composite

3 Composite

4 Composite

5 Composite

6 Composite

7 Composite

8 Composite

(9 Composite)

SEALED DOCUMENT by ELIZABETH KARLSON. This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal.

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by ELIZABETH KARLSON.

(Proposed Order Exceed Page Limit)

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by ELIZABETH KARLSON.

Proposed Order Alternative Service

Exhibit

Declaration Ference

(Exhibit 1 - Hauge Conference on Private International Law)

SEALED DOCUMENT by ELIZABETH KARLSON. This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal.

Summons

(Schedule A)

Summons Issued as to SCHEDULE A DEFENDANTS

SEALED ORDER re 14 Motion to Exceed Page Limit. Signed by Judge W. Scott Hardy on 1/21/2026.

SEALED ORDER re 15 Motion for an Order Authorizing Alternative Service. Signed by Judge W. Scott Hardy on 1/21/2026.

SEALED ORDER re 12 Motion for Temporary Restraining Order. Opposing papers, if any, shall be filed electronically with the Court and served on Plaintiff's Counsel at least one business day before the Show Cause Hearing. A Show Cause Hearing on Preliminary Injunction is set for 2/2/2026 at 1:00 PM in Courtroom 3B before Judge W. Scott Hardy. Signed by Judge W. Scott Hardy on 1/21/2026.

Set/Reset Hearings: Show Cause Hearing set for 2/2/2026 at 1:00 PM in Courtroom 3B before Judge W. Scott Hardy. (Text entry; no document attached.)

SEALED ORDER indicating that, upon consideration of Plaintiff's Ex Parte Motion for TRO/Preliminary Injunction, Plaintiff shall supplement its Motion for TRO/PI, Memoranda of Law, and supporting declarations and exhibits by close of business on 1/29/2026 as further set forth in the Court's Order. Signed by Judge W. Scott Hardy on 1/21/2026.

Surety Bond BOND in the amount of $50,000 Receipt Number S-996609, posted by ELIZABETH KARLSON NGM Insurance Company as Surety.

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by ELIZABETH KARLSON.

Proposed Order Extension Time

(Declaration)

SEALED ORDER granting Motion to Extend TRO. Signed by Judge W. Scott Hardy on 1/30/26.

Set/Reset Hearings: Show Cause Hearing is set for 2/16/2026 at 01:00 PM in Courtroom 3B before Judge W. Scott Hardy. (Text entry; no document attached.)

SEALED ORDER indicating that the Show Cause hearing previously scheduled for 2/16/2026 is rescheduled for 2/17/2026 at 9:30 AM in Courtroom 3B before Judge. W. Scott Hardy. Signed by Judge W. Scott Hardy on 1/30/26.

Set/Reset Hearings: The Show Cause Hearing previously set for 2/16/2026 is now set for 2/17/2026 at 9:30 AM in Courtroom 3B before Judge W. Scott Hardy. (Text entry; no document attached.)

CERTIFICATE OF SERVICE TRO Show Cause Hearing by ELIZABETH KARLSON

MOTION to Unseal Case by ELIZABETH KARLSON.

(Proposed Order)

MOTION for attorney Jianyin Liu to Appear Pro Hac Vice, (Filing fee $70, Receipt # APAWDC-9345215) by Dofeng.

CLERK'S REQUEST FOR CORRECTIVE ACTION re 28 MOTION for attorney Jianyin Liu to Appear Pro Hac Vice, (Filing fee $70, Receipt # APAWDC-9345215). ERROR: Party did not file disclosure statement as required by either LR 7.1.A or FRCvP 7.1(a)(2). CORRECTION: Filer advised to docket statement within 7 days by using the Disclosure Statement event. This event is located by going to Civil > Other Filings > Other Documents > Disclosure Statement. (Text entry; no document attached.)

Affidavit Liu

Proposed Order

Exhibit A- FL Good Standing

(Exhibit B- WA Good Standing) Duplicative text removed. Modified text on 2/6/2026. (tla)

ORDER granting 28 Motion for Jianyin Liu to Appear Pro Hac Vice. Signed by Judge W. Scott Hardy on 2/6/2026.

Disclosure Statement identifying None as corporate parent or other affiliate, declaring citizenship by Dofeng.

MOTION for Hearing re 25 Sealed Order with Remote Appearance by Dofeng.

(Proposed Order)

Order on Motion to Unseal Case

Order on Motion for Hearing (Text entry; no document attached.)

Second MOTION for Hearing re 33 Order on Motion for Hearing, with Remote Appearance by Dofeng.

(Proposed Order)

SEALED DOCUMENT by ELIZABETH KARLSON. This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal.

(Proposed Order Preliminary Injunction)

MOTION for attorney Shaoyi Che to Appear Pro Hac Vice, on behalf of shenzhenshi fanliduofushi youxiangongsi d/b/a IN'VOLAND (Filing fee $70, Receipt # APAWDC-9365852) by shenzhenshi fanliduofushi youxiangongsi.

Affidavit of Shaoyi Che

Proposed Order

Exhibit A