2025-cv-01854

COMPLAINT against SCHEDULE A DEFENDANTS (Filing fee, including Administrative fee, $405, receipt number APAWDC-9223577), filed by FAENKOVA ELENA VALENTINOVNA.

Magistrate Judge Christopher B. Brown added. (Text entry; no document attached.)

CLERK'S REQUEST FOR CORRECTIVE ACTION re 1 COMPLAINT. ERRORS: Civil Cover Sheet missing the county for the plaintiff. Filer must submit AO 121 Report on the Filing or Determination of an Action or appeal Regarding a Copyright. CORRECTIONS: Filer to submit a corrected civil cover sheet by using the Errata event, linking it to the initial pleading. Filer also 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 - Copyright Registrations

Exhibit 2 - Combating Trafficking in Counterfeit and Pirated Goods

Exhibit 3 - Intellectual Property Rights Seizure Statistics

(Civil Cover Sheet)

STANDING ORDER ON RULE 12(b) MOTIONS. Signed by Magistrate Judge Christopher B. Brown on 12/3/2025.

AO 121 NOTICE by FAENKOVA ELENA VALENTINOVNA

(Additional Register copyrights)

Disclosure Statement identifying NONE as corporate parent or other affiliate by FAENKOVA ELENA VALENTINOVNA.

MOTION for Leave to File Documents Under Seal by FAENKOVA ELENA VALENTINOVNA.

(Proposed Order)

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

Complaint

Exhibit 1

Exhibit 2

Exhibit 3

Docket Sheet

AO 121 Notice

(Additional Register copyrights) (kss)

ORDER granting 5 MOTION for Leave to File Documents Under Seal as set forth in more detail in the attached. Signed by Magistrate Judge Christopher B. Brown on 12/10/2025.

MOTION for Temporary Restraining Order, MOTION for Order Restraining Assets and Merchant Storefronts, MOTION for Order to Show Cause Why A Preliminary Injunction Should Not Issue, MOTION for Order Authorizing Expedited Discovery on by FAENKOVA ELENA VALENTINOVNA. Added MOTION for Order Restraining Assets and Merchant Storefronts, MOTION for Order to Show Cause Why A Preliminary Injunction Should Not Issue, MOTION for Order Authorizing Expedited Discovery on 1/7/2026

CLERK'S REQUEST FOR CORRECTIVE ACTION re 8 MOTION for Temporary Restraining Order, MOTION for Order Restraining Assets and Merchant Storefronts, MOTION for Order to Show Cause Why A Preliminary Injunction Should Not Issue, MOTION for Order Authorizing Expedited Discovery. ERROR: Filer did not attach a Proposed Order as required by LCvR 7. CORRECTION: Filer to submit a proposed order using the Proposed Order event. Filer is to link the Proposed Order to the relevant motion in the event. (Text entry; no document attached.)

CLERK'S NOTICE OF CORRECTION re 8 MOTION for Temporary Restraining Order, MOTION for Order Restraining Assets and Merchant Storefronts, MOTION for Order to Show Cause Why A Preliminary Injunction Should Not Issue, MOTION for Order Authorizing Expedited Discovery. ERROR: Multiple relief motion filed requesting only a relief. CORRECTION FOR FUTURE FILINGS: Filer to select all relief types sought when filing the Motion event. THIS MESSAGE IS FOR INFORMATIONAL PURPOSES ONLY AND NO FURTHER ACTION IS REQUIRED ON THE FILING AT ISSUE. (Text entry; no document attached.)

CLERK'S NOTICE OF REASSIGNMENT. In light of the filing of the 8 Motion for Temporary Restraining Order, this case is no longer assigned to Magistrate Judge Christopher B. Brown and is reassigned to Judge Mark R. Hornak. (Text entry; no document attached.)

SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, by FAENKOVA ELENA VALENTINOVNA.

Proposed Order TRO

Declaration Valentinovna

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

(10 Composite)

SEALED DOCUMENT by FAENKOVA ELENA VALENTINOVNA. This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal.

SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, by FAENKOVA ELENA VALENTINOVNA.

(Proposed Order Exceed Page Limit)

SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, by FAENKOVA ELENA VALENTINOVNA.

Proposed Order Alternative Service

Exhibit

Declaration Ference

(Exhibit 1 - Hauge Conference on Private International Law)

SEALED DOCUMENT by FAENKOVA ELENA VALENTINOVNA. This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal.

Summons

(Schedule A)

SEALED ORDER re 9 SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, filed by FAENKOVA ELENA VALENTINOVNA. Signed by Judge Mark R. Hornak on 2/10/26.

(Schedule A) (bdb)

ORDER GRANTING 11 Sealed Motion. Signed by Judge Mark R. Hornak on 2/10/26.

ORDER GRANTING AS MODIFIED BY THE COURT 12 Sealed Motion. Signed by Judge Mark R. Hornak on 2/10/26.

ORDER DIRECTING THE FILING OF A SUPPLEMENTAL REPORT BY THE PLAINTIFF. In consideration of the matters currently before the Court in this proceeding, including the Plaintiff's request for provisional injunctive and declaratory relief and other related submissions, it is ORDERED that not later than 48 hours prior to the commencement of any show cause or other hearing in this case relative to preliminary injunctive relief, Plaintiff shall supplement its filings via a single report filed on the docket and, in furtherance of the relief sought, such submission shall address the following: (1) Whether Plaintiff has previously brought any action, claim or proceeding in any court or tribunal against any named Defendant wherein Plaintiff sought to enforce the involved copyrights/trademarks/patents, identifying the tribunal, type of claim, and case number of any such action and advising the Court as to its current status; (2) For any such action identified in (1), state the number of Defendants currently enjoined by any form of equitable relief for alleged infringement or violation of the interest at issue in this action; and (3) To the extent the Plaintiff seeks or will seek authorization for alternative service of process or other papers, the Plaintiff shall file a statement of position as to the applicability of the reasoning in Smart Study, Co., No. 24-313, 2025 WL 3672740 (2d Cir. Dec. 18, 2025) to such request, and advise the Court how any future Order should proceed so as to conform to applicable law. In the alternative, to the extent that the Plaintiff is not seeking alternative service the Plaintiff shall explicitly so state. Further, in such report, the Plaintiff shall supply the Court with information pertaining to: (a) the aggregate amount of assets frozen pursuant to any Order of this Court; (b) the average dollar amount frozen per defendant; (c) the smallest and largest amounts so frozen, along with the identities of those corresponding defendants; and (d) the identities of any Defendant with cumulative assets frozen of $10,000 or greater, and the corresponding amount. Signed by Judge Mark R. Hornak on 2/10/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Summons Issued as to SCHEDULE A DEFENDANTS

Surety Bond BOND in the amount of $25,000 Receipt Number S-960259, posted by FAENKOVA ELENA VALENTINOVNA NGM Insurance Company as Surety.

MOTION to Extend Time to to the Temporary Restraining Order, MOTION to Continue the Show Cause Hearing, MOTION to Modify the Briefing Schedule by FAENKOVA ELENA VALENTINOVNA.

CLERK'S NOTICE OF CORRECTION re 20 MOTION to Extend Time to the Temporary Restraining Order, MOTION to Continue the Show Cause Hearing, MOTION to Modify the Briefing Schedule. ERROR: Multiple relief motion filed requesting only a relief. CORRECTION FOR FUTURE FILINGS: Filer to select all relief types sought when filing the Motion event. THIS MESSAGE IS FOR INFORMATIONAL PURPOSES ONLY AND NO FURTHER ACTION IS REQUIRED ON THE FILING AT ISSUE. (Text entry; no document attached.)

Proposed Order

(Declaration) Added MOTION to Continue the Show Cause Hearing, MOTION to Modify the Briefing Schedule on 2/23/2026 (kss)

ORDER GRANTING 20 MOTION to Extend Time to to the Temporary Restraining Order, MOTION to Continue the Show Cause Hearing, MOTION to Modify the Briefing Schedule. The Show Cause Hearing set for 2/24/26 at 4:00 PM is hereby CONTINUED to 3/9/26 at 3:30 PM via video conference before Judge Mark R. Hornak. It is further ORDERED as set forth herein. Signed by Judge Mark R. Hornak on 2/23/26.

ORDER DIRECTING THE FILING OF A SUPPLEMENTAL REPORT BY THE PLAINTIFF AND THE PROVISION TO THE COURT VIA ELECTRONIC MAIL OF ADDITIONAL DOCUMENTATION. In consideration of the matters currently before the Court in this proceeding, including the Plaintiff's request for provisional injunctive and declaratory relief and other related submissions, it is ORDERED that not later than 48 hours prior to the commencement of any show cause or other hearing in this case relative to preliminary injunctive relief, Plaintiff shall supplement its filings via a single report filed on the docket and, in furtherance of the relief sought, such submission shall address the following: (1) Whether Plaintiff has previously brought any action, claim or proceeding in any court or tribunal against any named Defendant wherein Plaintiff sought to enforce the involved copyrights/trademarks/patents, identifying the tribunal, type of claim, and case number of any such action and advising the Court as to its current status; (2) For any such action identified in (1), state the number of Defendants currently enjoined by any form of equitable relief for alleged infringement or violation of the interest at issue in this action; and (3) To the extent the Plaintiff has sought, seeks or will seek authorization for alternative service of process or other papers, the Plaintiff shall file a statement of position as to the applicability of the reasoning in Smart Study, Co., No. 24-313, 2025 WL 3672740 (2d Cir. Dec. 18, 2025) to such request, and advise the Court how any Orders in this action should proceed so as to conform to applicable law. In the alternative, to the extent that the Plaintiff is not seeking alternative service the Plaintiff shall explicitly so state. Further, in such report, the Plaintiff shall supply the Court with information pertaining to: (a) the aggregate amount of assets frozen in this action pursuant to any Order of this Court; (b) the average dollar amount frozen per defendant in this action; (c) the smallest and largest amounts so frozen, along with the identities of those corresponding defendants; and (d) the identities of any defendant with cumulative assets frozen of $10,000 or greater, and the corresponding amount. Additionally, it is ORDERED that also no later than 48 hours prior to the commencement of any show cause or other hearing in this case relative to preliminary injunctive relief, Plaintiff shall file a final proposed order for injunctive relief on the docket. Plaintiff shall also send a copy of said order in a Word document via electronic mail to Hornak_Chambers@pawd.uscourts.gov. This Order supplements and supersedes any prior Order in this action directed to these matters. Signed by Judge Mark R. Hornak on 2/26/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

ORDER CONTINUING HEARING. Based on the request with Chambers by counsel for the Plaintiff, the Show Cause Hearing set for 3/9/26 at 3:30 PM is hereby CONTINUED to 3/11/26 at 3:30 PM via Video Conference before Judge Mark R. Hornak. The link required to participate will be circulated via e-mail. Signed by Judge Mark R. Hornak on 2/27/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

NOTICE as to SHOW CAUSE HEARING. The SHOW CAUSE HEARING set for Wednesday, March 11, 2026 at 3:30 PM will be conducted via Zoom video conference. The Plaintiff shall give notice and provide service of this Order to all remaining Defendants in conformity with this Court's previous Orders authorizing service. The Plaintiff shall file Certificates of Service upon completion of such service. Any person who wishes to participate in the hearing by Zoom must be a party to these actions. In order to participate, any non-individual party must be represented by an attorney who is admitted or capable of being admitted to practice before this Court, and any such attorney must enter an appearance on the appropriate docket. Alternatively, any party to these actions who is an individual natural person and who files, via the Court's CM/ECF system, formal notice on the appropriate docket, including an email at which they can be contacted, that they intend to represent themselves may participate in the Zoom hearing on their own behalf. Any entity or organization may be represented by legal counsel only, and a non-lawyer may represent themselves only. The Zoom information required to participate will be disseminated by email to parties who comply with these procedures for their use only. Public access to observe proceedings will be provided by other means. Participants are expected to join the Zoom conference at least fifteen (15) minutes early to provide time for admitting approved participants. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

MOTION TO REDUCE ASSET RESTRAINT AS TO DEFENDANTS EROSEBRIDAL (Def. No. 63), ZANLN (Def. No. 92), and ShoPen (Def. No. 258) by FAENKOVA ELENA VALENTINOVNA.

Proposed Order

SUPPLEMENT by FAENKOVA ELENA VALENTINOVNA to 22 Order.

ORDER GRANTING 25 Motion To Reduce Asset Restraint as to Defendants EROSEBRIDAL (Def. No. 63), ZANLN (Def. No. 92), and ShoPen (Def. No. 258). It is hereby ordered that Amazon shall maintain a total restraint of One Hundred Fifty Thousand ($150,000.00) of funds in the account of each of the following Defendants: EROSEBRIDAL (Def. No. 63) ZANLIN (Def. No. 92) and ShoPen (Def. No. 258). All other funds in the accounts of Defendant EROSEBRIDAL (Def. No. 63) Defendant ZANLIN (Def. No. 92) and ShoPen (Def. No. 258) shall be released. The restraint on the accounts of Defendant EROSEBRIDAL (Def. No. 63) Defendant ZANLIN (Def. No. 92) and ShoPen (Def. No. 258) (the One Hundred Fifty Thousand Dollars ($150,000.00) per account) shall remain in place until further Order of Court. Signed by Judge Mark R. Hornak on 3/10/26.

CERTIFICATE OF SERVICE by FAENKOVA ELENA VALENTINOVNA

SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, by FAENKOVA ELENA VALENTINOVNA.

(Proposed Order)

CORRECTIVE ENTRY re 27 ORDER GRANTING 25 Motion To Reduce Asset Restraint as to Defendants EROSEBRIDAL (Def. No. 63), ZANLN (Def. No. 92), and ShoPen (Def. No. 258). It is hereby ordered that Amazon shall maintain a total restraint of One Hundred Fifty Thousand ($1 50,000.00) of funds in the account of each of the following Defendants: EROSEBRIDAL (Def. No. 63) ZANLIN (Def. No. 92) and ShoPen (Def. No. 258). All other funds in the accounts of Defendant EROSEBRIDAL (Def. No. 63) Defendant ZANLIN (Def. No. 92) and ShoPen (Def. No. 258) shall be released. The restraint on the accounts of Defendant EROSEBRIDAL (Def. No. 63) Defendant ZANLIN (Def. No. 92) and ShoPen (Def. No. 258) (the One Hundred Fifty Thousand Dollars ($150,000.00) per account) shall remain in place until further Order of Court. Reason for Correction: wrong date on document.

ANSWER to 1 Complaint by Iurii Tulin. Modified text on 3/11/2026 to add document linkage.

ORDER. Based on the Show Cause Hearing set for this date at 3:30 PM, it is hereby ORDERED that the following documents are hereby UNSEALED on the Court's docket: 9 ; 10 ; 11 ; 12 ; 13 ; 14 ; 15 ; 16 ; 21 ; and, 29. Signed by Judge Mark R. Hornak on 3/11/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

CLERK'S NOTICE OF CORRECTION re 28 Certificate of Service. ERROR: Document not linked. CORRECTION FOR FUTURE FILINGS: Filer advised to link filing to related document(s) in future filings. Clerk added link to appropriate document(s). THIS MESSAGE IS FOR INFORMATIONAL PURPOSES ONLY AND NO FURTHER ACTION IS REQUIRED ON THE FILING AT ISSUE. (Text entry; no document attached.)

Minute Entry for proceedings held before Judge Mark R. Hornak: Show Cause Hearing held via videoconference on 3/11/26. (Court Reporter: Amanda Williamson)

PRELIMINARY INJUNCTION ORDER. Signed by Judge Mark R. Hornak on 3/11/26.

(Schedule A) (bdb)

ORDER DIRECTING PLAINTIFF TO FILE STATUS REPORT. Plaintiff's counsel shall file a Status Report on the matters relevant to this case within thirty (30) days of the date of this order, or sooner if there is a material development. In said status report, Plaintiff is directed to provide a factual basis as to whether and what amount of any of the monies frozen in Defendant's account(s) pursuant to any of this Court's Orders are specifically related to the alleged infringing conduct in the action at bar, and, if so, shall show cause why such amounts beyond those amounts should remain frozen by Order of this Court. Signed by Judge Mark R. Hornak on 3/11/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Order to Vacate Document (Text entry; no document attached.)

ORDER to Vacate Document. It is hereby ORDERED that the Order Directing Plaintiff to File Status Report (ECF No. 35) is hereby VACATED. Signed by Judge Mark R. Hornak on 3/12/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

CLERK'S REQUEST FOR CORRECTIVE ACTION re 31 Answer to Complaint. ERROR: Party (7DOTS ART) did not file disclosure statement as required by LR 7.1.A. 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.)