2024-cv-61700

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00. Pay.gov Agency Tracking ID FLSDC-17834729, payment transferred from : 24-cv-61700 Tangle Inc. v. The Individuals, et al., filed by Tangle Inc.

Exhibit 1

Exhibit 2

Civil Cover Sheet

Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Tangle Inc.

Plaintiff's MOTION to Seal Schedule A to Complaint per Local Rule 5.4 by Tangle Inc.

(Text of Proposed Order)

ORDER GRANTING MOTION TO SEAL granting [5] Motion to File Under Seal. Signed by Judge Rodney Smith on 9/18/2024. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's MOTION for Leave to File Excess Pages by Tangle Inc.

Text of Proposed Order

NOTICE of Voluntary Dismissal of Certain Defendant Only by Tangle Inc.

Order (Text entry; no document attached.)

PAPERLESS ORDER granting 9 Motion to Exceed Page Limitation. Signed by Judge Rodney Smith on 9/20/2024. (cl01)

NOTICE of Voluntary Dismissal of Certain Defendant Only by Tangle Inc.

SYSTEM ENTRY - Docket Entry 14 [motion] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 15 [motion] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

ORDER of Dismissal re [10] Notice of Voluntary Dismissal filed by Tangle Inc. Dismissing Defendants No. 45, (renasretrotreasures) Listed on Schedule A to the Complaint and Defendant No. 14, (COCONUM) Listed on Schedule A to the Complaint. Signed by Judge Rodney Smith on 9/25/2024. See attached document for full details.

Order (Text entry; no document attached.)

NOTICE of Attorney Appearance by Leigh Benjamin Salomon on behalf of Tangle Inc. Attorney Leigh Benjamin Salomon added to party Tangle Inc.(pty:pla).

NOTICE of Filing Proposed Summons(es) in Compliance with the Court's Sealed Order Granting Ex Parte Application for Entry of Temporary Restraining Order [DE 18] by Tangle Inc.

Summon(s)

Notice of Posting Bond in the amount of $10000.00 receipt # 292497 posted by Tangle Inc. Approved by Judge Rodney Smith

Summons Issued as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A.

First MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines by Tangle Inc. Responses due by 10/15/2024.

Affidavit

Text of Proposed Order

ORDER granting 23 Motion for Extension of Time. Prelinjhrg Hearing set for 10/23/2024 08:45 AM before Judge Rodney Smith. Responses due by 10/16/2024. Replies due by 10/21/2024. Signed by Judge Rodney Smith on 10/1/2024. See attached document for full details.

Second MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines re [24] Order on Motion for Extension of Time, by Tangle Inc. Responses due by 10/28/2024.

Affidavit Declaration of Nicole Fundora ISO Second Motion to Extend TRO and Resc

Text of Proposed Order

ORDER granting 25 Motion for Extension of Time. The Temporary Restraining Order, dated September 25, 2024 [DE 18], is hereby extended and will remain in effect until November 6, 2024. Any response or opposition to Plaintiff's Motion for Preliminary Injunction must be filed with the Court and served on Plaintiff's counsel by October 28, 2024. Plaintiff shall file any Reply Memorandum on or before November 1, 2024. Responses due by 10/28/2024. Preliminary Injunction Hearing set for 11/6/2024 08:45 AM before Judge Rodney Smith. Signed by Judge Rodney Smith on 10/15/2024. See attached document for full details.

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of YUEARN. Attorney Andrew Jonathan Palmer added to party YUEARN(pty:dft).

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Tangle Inc. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 11/5/2024, response/answer due 11/26/2024; YUEARN served on 11/5/2024, response/answer due 11/26/2024.

Statement of: Declaration of He Cheng regarding the procedural issues by YUEARN re 26 Order on Motion for Extension of Time

Exhibit Exhibit 1 - Email Communication - 10/10

Exhibit Exhibit 2 - Screenshots of Defendant's Amazon storefront

Exhibit Exhibit 3 - Screenshot of service by publication

(Exhibit Exhibit 4 - Email - service of process)

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Preliminary Injunction Hearing held on 11/6/2024, 8:45-9:00am. After hearing from plaintiff's counsel and counsel for defendant Yuearn, the Court entered preliminary injunction as to defendants, with the exception of defendant Yuearn. Attorney Appearance(s): Leigh Benjamin Salomon, Andrew Jonathan Palmer, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

Plaintiff's NOTICE of Filing Proposed Order on Plaintiff's Motion for Preliminary Injunction (as to all but DOE 26 YUEARN) by Tangle Inc. re 31 Miscellaneous Hearing

(Text of Proposed Order)

MOTION to Unseal Case by Tangle Inc. Responses due by 11/20/2024.

Text of Proposed Order

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Changsha Wodemore Technology Co., Ltd., Dongguan Ouyi Industrial Co., Ltd., Henan Yokids Group, Joe&joy(guangzhou) Mother&baby Products Ltd., Shantou Beilisi Toys Co., Ltd., Shenzhen Xinhui Chuangda Technology Co., Ltd., Yongkang Xiaotongban Toys Gifts Co., Ltd., AVIS Official Store, LuckyLife Store, muddy Puddles Official Store, Novedosos Decompression Toys Store, Shop168830442 Store, Super Funny Toys Store, Dongmuguojimaoyiyouxiangongsi, iSuTun, Khs Store, LENDOD Party, Meixinz, MFUERSTIC, Mwcsmao, SONGSONGAM, srd-gengyangmaoyi, YOUMIYA, Yuhao Shoes, abfl, beauty10 Store, cr6a, d3kr, deng08 Store, gduc, ob7p, p6kf, pelsagirl, rja2, roq0, s98z, tengdaele2022, uvkc, xemx, xrxl, nickspartysupplies, Asdettu, BestSell, Gababy, GUI YANYAN, JHNaYi, JOYTOY (WINWING), Langlun Toy, mai chi, Rui De, Ruoshui, SFRFHNYJHMM, SIJUN, SZBEIDUOXIN, talented, TANSAR, xiang tian, XINGSHOU, Yingwin, ZhengDaHuanYuan, ZS toy, BADE.Co.Ltd, beetoy, DDY-US, JIELA Co.Ltd, Lanliyun Outlet, Qtulex, Sheiny, shenzhenshipuyukeiji and Costpress.

ORDER granting 33 Motion to Unseal Case. Signed by Judge Rodney Smith on 11/7/2024. See attached document for full details.

NOTICE of Compliance re 35 Order on Motion to Unseal Case. (All docket entries unsealed)

Order Granting Plaintiff's Motion for Preliminary Injunction Signed by Judge Rodney Smith on 11/7/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party Asdettu re 38 Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 11/13/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party ZhengDaHuanYuan re [40] Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 11/14/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party mai chi re 42 Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 11/18/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party Joe&joy(guangzhou) Mother&baby Products Ltd. (Defendant Number 4) re 44 Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 11/21/2024. See attached document for full details.

MOTION for Clerk's Entry of Default as to AVIS Official Store, BADE.Co.Ltd, BestSell, Changsha Wodemore Technology Co., Ltd., Costpress, DDY-US, Dongguan Ouyi Industrial Co., Ltd., Dongmuguojimaoyiyouxiangongsi, GUI YANYAN, Gababy, Henan Yokids Group, JHNaYi, JIELA Co.Ltd, JOYTOY (WINWING), Khs Store, LENDOD Party, Langlun Toy, Lanliyun Outlet, LuckyLife Store, MFUERSTIC, Meixinz, Mwcsmao, Novedosos Decompression Toys Store, Qtulex, Rui De, Ruoshui, SFRFHNYJHMM, SIJUN, SONGSONGAM, SZBEIDUOXIN, Shantou Beilisi Toys Co., Ltd., Sheiny, Shenzhen Xinhui Chuangda Technology Co., Ltd., Shop168830442 Store, Super Funny Toys Store, TANSAR, XINGSHOU, YOUMIYA, Yingwin, Yongkang Xiaotongban Toys Gifts Co., Ltd., Yuhao Shoes, ZS toy, abfl, beauty10 Store, beetoy, cr6a, d3kr, deng08 Store, gduc, iSuTun, muddy Puddles Official Store, nickspartysupplies, ob7p, p6kf, pelsagirl, rja2, roq0, s98z, shenzhenshipuyukeiji, srd-gengyangmaoyi, talented, tengdaele2022, uvkc, xemx, xiang tian, xrxl by Tangle Inc.

Affidavit Declaration of Nicole Fundora ISO Plaintiff's Request for Clerk&#

Clerk's Entry of Default as to AVIS Official Store, BADE.Co.Ltd, BestSell, Changsha Wodemore Technology Co., Ltd., Costpress, DDY-US, Dongguan Ouyi Industrial Co., Ltd., Dongmuguojimaoyiyouxiangongsi, GUI YANYAN, Gababy, Henan Yokids Group, JHNaYi, JIELA Co.Ltd, JOYTOY (WINWING), Khs Store, LENDOD Party, Langlun Toy, Lanliyun Outlet, LuckyLife Store, MFUERSTIC, Meixinz, Mwcsmao, Novedosos Decompression Toys Store, Qtulex, Rui De, Ruoshui, SFRFHNYJHMM, SIJUN, SONGSONGAM, SZBEIDUOXIN, Shantou Beilisi Toys Co., Ltd., Sheiny, Shenzhen Xinhui Chuangda Technology Co., Ltd., Shop168830442 Store, Super Funny Toys Store, TANSAR, XINGSHOU, YOUMIYA, Yingwin, Yongkang Xiaotongban Toys Gifts Co., Ltd., Yuhao Shoes, ZS toy, abfl, beauty10 Store, beetoy, cr6a, d3kr, deng08 Store, gduc, iSuTun, muddy Puddles Official Store, nickspartysupplies, ob7p, p6kf, pelsagirl, rja2, roq0, s98z, shenzhenshipuyukeiji, srd-gengyangmaoyi, talented, tengdaele2022, uvkc, xemx, xiang tian, xrxl - Motions Terminated: [46] Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 12/5/2024.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Tangle Inc.

Order Dismissing Parties Ruoshui (Defendant Number 55) and YUEARN (Defendant Number 26) are DISMISSED without prejudice, re 48 Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 12/6/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party GUI YANYAN (Defendant Number 49) re [50] Notice of Voluntary Dismissal. Signed by Judge Rodney Smith on 12/10/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Tangle Inc.

Order Dismissing Parties XINGSHOU (Defendant Number 62) and ZS toy (Defendant Number 65) without prejudice re 52 Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 12/11/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party beetoy (Defendant No. 67) re 54 Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 12/12/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

Order Dismissing Party talented re [56] Notice of Voluntary Dismissal Signed by Judge Rodney Smith on 12/16/2024. See attached document for full details.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE Signed by Judge Rodney Smith on 12/16/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

ORDER. Defendant SZBEIDUOXIN (Defendant Number 58) is DISMISSED without prejudice. Signed by Judge Rodney Smith on 12/18/2024. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Tangle Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Tangle Inc.

ORDER. Plaintiff's claims against the following Defendants are DISMISSED without prejudice: LENDOD Party, YOUMIYA, Yingwin, Gababy and JOYTOY (WINWING). Signed by Judge Rodney Smith on 12/31/2024. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Tangle Inc.

Exhibit Schedule A - list of Defaulting Defendants

Affidavit Declaration of Nicole Fundora ISO Motion for Default

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 1 of 2)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 2 of 2)

Text of Proposed Order

(Text of Proposed Order)

ORDER ON MOTION FOR ENTRY OF FINAL DEFAULT JUDGMENT granting [64] Motion for Default Judgment. Signed by Judge Rodney Smith on 4/21/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION Judgment in favor of Tangle Inc. against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Signed by Judge Rodney Smith on 4/21/2025. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

MOTION for Disbursement of Funds by Tangle Inc.

Text of Proposed Order

ORDER granting 68 Motion for Disbursement of Funds to Boies Schiller Flexner LLP in the amount of $10,000.00. Signed by Judge Rodney Smith on 4/24/2025. See attached document for full details.

Civil Case Terminated. Closing Case. (Text entry; no document attached.)