2025-cv-22171

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18439540, filed by Spike Cable Networks Inc.

Civil Cover Sheet

(Exhibit 1 to Complaint - Certificates of Registration for the Yellowstone Trademarks)

Clerks Notice of Judge Assignment to Judge Rodolfo A. Ruiz, II. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis 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

(Complaint) (blc)

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by Spike Cable Networks Inc. identifying Corporate Parent Paramount Global, Other Affiliate National Amusements, Inc. for Spike Cable Networks Inc.

OMNIBUS ORDER REGARDING SCHEDULE "A" CAUSES OF ACTION. Signed by Judge Rodolfo A. Ruiz, II on 5/12/2025. See attached document for full details.

Plaintiff's RESPONSE to 5 Administrative Order by Spike Cable Networks Inc.

Plaintiff's MOTION to Seal per Local Rule 5.4 by Spike Cable Networks Inc.

(Text of Proposed Order Granting Motion to File Under Seal)

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof by Spike Cable Networks Inc. (Attachments: # 1 Declaration of Mallory Levitt in Support Thereof, # 2 Exhibit 1 to the Declaration of Mallory Levitt, # 3 Declaration of Stephen M. Gaffigan in Support Thereof, # 4 Declaration of Kathleen Burns in Support Thereof, # 5 Exhibit 1, Part 1 to the Declaration of Kathleen Burns, # 6 Exhibit 1, Part 2 to the Declaration of Kathleen Burns, # 7 Exhibit 1, Part 3 to the Declaration of Kathleen Burns, # 8 Text of Proposed Order Granting Ex Parte Application for Temporary Restraining Order) Modified to Unseal per DE 19 on 7/3/2025

Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof by Spike Cable Networks Inc. (Attachments: # 1 Declaration of Stephen M. Gaffigan in Support Thereof, # 2 Exhibit 1 to the Declaration of Stephen M. Gaffigan, # 3 Exhibit 2 to the Declaration of Stephen M. Gaffigan, # 4 Declaration of Huang Yu Ting in Support Thereof, # 5 Exhibit 1 to the Declaration of Huang Yu Ting, # 6 Declaration of Kathleen Burns in Support Thereof, # 7 Exhibit 1 to the Declaration of Kathleen Burns, # 8 Text of Proposed Order Granting Motion for Order Authorizing Alternate Service of Process) Modified to Unseal per DE 19 on 7/3/2025

ORDER granting 7 Motion to File Under Seal. Signed by Judge Rodolfo A. Ruiz II on 6/24/2025. See attached document for full details.

ORDER granting 8 Ex Parte Application for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets. Signed by Judge Rodolfo A. Ruiz II on 6/24/2025. See attached document for full details. (gp) Modified to Unseal per DE 19 on 7/3/2025

ORDER granting 9 Ex Parte Motion for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3). Signed by Judge Rodolfo A. Ruiz II on 6/24/2025. See attached document for full details. (gp) Modified to Unseal per DE 19 on 7/3/2025

Sealed Document re DE# 10 Order on Motion to Seal by Spike Cable Networks Inc. (Attachments: # 1 Schedule "A" to Plaintiff's Complaint for Damages and Injunctive Relief) Modified to Unseal per DE 19 on 7/3/2025

Sealed Document Notice of Filing Proposed Summonses Under Seal re DE# 10 Order on Motion to Seal by Spike Cable Networks Inc. (Attachments: # 1 Summon(s)) Modified to Unseal per DE 19 on 7/3/2025

Summons Issued as to rasotee.com, and all other Defendants identified in Schedule "A" hereto. (amb) Text Modified on 6/26/2025 (amb). Modified to Unseal per DE 19 on 7/3/2025

PLAINTIFF'S NOTICE OF FILING BOND

NOTICE of Compliance by Spike Cable Networks Inc.

Plaintiff's MOTION to Unseal Document Entries 8-9 and 11-15 by Spike Cable Networks Inc. Responses due by 7/16/2025.

(Text of Proposed Order Granting Motion to Unseal)

ORDER granting 18 Motion to Unseal Document. Signed by Judge Rodolfo A. Ruiz, II on 7/2/2025. See attached document for full details.

NOTICE of Compliance re 19 Order on Motion to Unseal Document. (All docket entries unsealed and returned to the public records)

Plaintiff's NOTICE upon Defendants via Electronic Mail by Spike Cable Networks Inc. re 8 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, 1 Complaint, 11 Order on Ex Parte Motion, 18 Plaintiff's MOTION to Unseal Document Entries 8-9 and 11-15

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Spike Cable Networks Inc. re 13 Sealed Document, 10 Order on Motion to Seal, 6 Response/Reply (Other), 12 Order on Ex Parte Motion, 5 Administrative Order, 7 Plaintiff's MOTION to Seal per Local Rule 5.4, 8 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, 1 Complaint, 3 Form AO 120/121, 2 Clerks Notice of Judge Assignment, 17 Notice of Compliance, 11 Order on Ex Parte Motion, 18 Plaintiff's MOTION to Unseal Document Entries 8-9 and 11-15, 9 Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof, 4 Certificate of Other Affiliates/Corporate Disclosure Statement, 16 Notice of Conventional Filing, 14 Sealed Document upon Defendants via website posting

Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof by Spike Cable Networks Inc.

(Text of Proposed Order Setting Hearing on Motion for Entry of Preliminary Injunction)

Plaintiff's MOTION to Extend Temporary Restraining Order re 11 Order on Ex Parte Motion, by Spike Cable Networks Inc.

(Text of Proposed Order)

ORDER SETTING HEARING ON MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Rodolfo A. Ruiz, II on 7/3/2025. See attached document for full details.

ORDER GRANTING MOTION TO EXTEND TEMPORARY RESTRAINING ORDER. Signed by Judge Rodolfo A. Ruiz, II on 7/3/2025. See attached document for full details.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Spike Cable Networks Inc.

(Exhibit 1 to Amended Complaint - Certificates of Registration for the Yellowstone Trademarks)

Plaintiff's NOTICE upon Defendants via Electronic Mail by Spike Cable Networks Inc. re 25 Order Setting Hearing on Motion

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Spike Cable Networks Inc. re 25 Order Setting Hearing on Motion for Entry of Preliminary Injunction upon Defendants via website posting Modified text and link on 7/8/2025

SUMMONS (Affidavit) Returned Executed on 27 Amended Complaint/Amended Notice of Removal, 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Spike Cable Networks Inc. 2020trendingtees.com served on 7/8/2025, response/answer due 7/29/2025; 247teeshirt.com served on 7/8/2025, response/answer due 7/29/2025; aeety.com served on 7/8/2025, response/answer due 7/29/2025; aixpi-ring-light.com served on 7/8/2025, response/answer due 7/29/2025; anurvogel.com served on 7/8/2025, response/answer due 7/29/2025; baetees.com served on 7/8/2025, response/answer due 7/29/2025; bestoftees.com served on 7/8/2025, response/answer due 7/29/2025; bipubunny.com served on 7/8/2025, response/answer due 7/29/2025; bucktee.com served on 7/8/2025, response/answer due 7/29/2025; cotosen.com served on 7/8/2025, response/answer due 7/29/2025; fashionstoreaz.com served on 7/8/2025, response/answer due 7/29/2025; ghelter.com served on 7/8/2025, response/answer due 7/29/2025; glieseshirt.com served on 7/8/2025, response/answer due 7/29/2025; hhshirt.com served on 7/8/2025, response/answer due 7/29/2025; inkinaction.com served on 7/8/2025, response/answer due 7/29/2025; inotee.com served on 7/8/2025, response/answer due 7/29/2025; maxxtees.com served on 7/8/2025, response/answer due 7/29/2025; merchill.com served on 7/8/2025, response/answer due 7/29/2025; nemopremium.com served on 7/8/2025, response/answer due 7/29/2025; nemoshirt.com served on 7/8/2025, response/answer due 7/29/2025; neptuneshirt.com served on 7/8/2025, response/answer due 7/29/2025; novitaregali.com served on 7/8/2025, response/answer due 7/29/2025; nowateeca.com served on 7/8/2025, response/answer due 7/29/2025; onnmerch.com served on 7/8/2025, response/answer due 7/29/2025; ornamentmerch.com served on 7/8/2025, response/answer due 7/29/2025; outfitgod.com served on 7/8/2025, response/answer due 7/29/2025; perfectfittshirts.com served on 7/8/2025, response/answer due 7/29/2025; rasotee.com served on 7/8/2025, response/answer due 7/29/2025; shirtelephant.com served on 7/8/2025, response/answer due 7/29/2025; t-shirtbear.com served on 7/8/2025, response/answer due 7/29/2025; teecify.net served on 7/8/2025, response/answer due 7/29/2025; teeforsports.com served on 7/8/2025, response/answer due 7/29/2025; teenavi.com served on 7/8/2025, response/answer due 7/29/2025; teepanda.net served on 7/8/2025, response/answer due 7/29/2025; theaffordableshirt.com served on 7/8/2025, response/answer due 7/29/2025; thorshirts.com served on 7/8/2025, response/answer due 7/29/2025; topiy.com served on 7/8/2025, response/answer due 7/29/2025; tshirtatlowprice.com served on 7/8/2025, response/answer due 7/29/2025; vsgclothing.com served on 7/8/2025, response/answer due 7/29/2025; yellow-stone.store served on 7/8/2025, response/answer due 7/29/2025.

Affidavit of Service

(Affidavit of Service)

Plaintiff's NOTICE of E-mail Correspondence Received from Certain Defendants in Connection with Notice by Spike Cable Networks Inc.

(Exhibit 1 to the Notice of E-mail Correspondence)

PAPERLESS Minute Entry for proceedings held before Judge Rodolfo A. Ruiz II: Telephonic Motion Hearing held on 7/9/2025 re 23 Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof filed by Spike Cable Networks Inc. Order to follow. Attorney Appearance(s): Virgilio Gigante, Mallory Ruth Denzl, Court Reporter: Lance Steinbeisser, 305-523-5633 / Lance_Steinbeisser@flsd.uscourts.gov.

ORDER GRANTING MOTION FOR PRELIMINARY INJUNCTION. Signed by Judge Rodolfo A. Ruiz, II on 7/9/2025. See attached document for full details.

Plaintiff's NOTICE of Identification of Additional Financial Accounts Used by Certain Defendants by Spike Cable Networks Inc.

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Declaration of Kathleen Burns)

Plaintiff's MOTION to Approve Consent Judgment as to Defendant Number 31 by Spike Cable Networks Inc. Responses due by 7/31/2025.

Exhibit 1 - Statement of Consent

(Text of Proposed Order Consent Final Judgment and Permanent Injunction as to Defendant Number 31)

ORDER granting 35 Motion to Approve Consent Judgment. Signed by Judge Rodolfo A. Ruiz, II on 7/17/2025. See attached document for full details.

Plaintiff's MOTION to Approve Consent Judgment as to Defendant Number 34 by Spike Cable Networks Inc. Responses due by 8/7/2025.

Exhibit 1 - Statement of Consent

(Text of Proposed Order Consent Final Judgment and Permanent Injunction as to Defendant Number 34)

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 34. Signed by Judge Rodolfo A. Ruiz, II on 7/24/2025. See attached document for full details.

NOTICE of Attorney Appearance by Jianyin Liu on behalf of anurvogel.com, cotosen.com. Attorney Jianyin Liu added to party anurvogel.com(pty:dft), Attorney Jianyin Liu added to party cotosen.com(pty:dft).

ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by anurvogel.com, cotosen.com.

Plaintiff's NOTICE of Identification of Additional Aliases and Additional Financial Accounts Used by Defendant Numbers 4 and 5 by Spike Cable Networks Inc.

Declaration of Mallory Levitt in Support Thereof

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

(Exhibit 2 to the Declaration of Kathleen Burns)

Plaintiff's MOTION for Clerk's Entry of Default as to 2020trendingtees.com, 247teeshirt.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, aeety.com, aixpi-ring-light.com, baetees.com, bestoftees.com, bipubunny.com, bucktee.com, fashionstoreaz.com, glieseshirt.com, hhshirt.com, inkinaction.com, inotee.com, maxxtees.com, merchill.com, nemopremium.com, nemoshirt.com, neptuneshirt.com, nowateeca.com, onnmerch.com, ornamentmerch.com, outfitgod.com, perfectfittshirts.com, rasotee.com, shirtelephant.com, t-shirtbear.com, teecify.net, teeforsports.com, teenavi.com, teepanda.net, theaffordableshirt.com, thorshirts.com, topiy.com, tshirtatlowprice.com, vsgclothing.com, yellow-stone.store by Spike Cable Networks Inc.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk's Entry of Default

(Text of Proposed Order)

Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A - Motions Terminated: 42 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK FTL on 7/31/2025.

NOTICE of Attorney Appearance by Ni Xue on behalf of aeety.com, topiy.com. Attorney Ni Xue added to party aeety.com(pty:dft), Attorney Ni Xue added to party topiy.com(pty:dft).

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

Declaration of Mallory Levitt in Support Thereof

Exhibit 1 to the Declaration of Mallory Levitt

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order Granting Plaintiff's Motion for Default Final Judgment

(Text of Proposed Order Default Final Judgment and Permanent Injunction)

Second NOTICE of Identification of Additional Aliases and Additional Financial Accounts Used by Defendant Number 4 by Spike Cable Networks Inc.

Declaration of Mallory Levitt in Support Thereof

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Declaration of Kathleen Burns)

NOTICE of Settlement with Defendant Numbers 2 and 12 by Spike Cable Networks Inc.

Joint MOTION to Approve Consent Judgment as to Defendant Numbers 2 and 12 by Spike Cable Networks Inc. Responses due by 9/4/2025.

(Exhibit 1 - Proposed Consent Final Judgment and Permanent Injunction as to Defendant Numbers 2 and 12)

ORDER GRANTING PLAINTIFF'S MOTION FOR DEFAULT FINAL JUDGMENT. Signed by Judge Rodolfo A. Ruiz, II on 8/25/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION. Signed by Judge Rodolfo A. Ruiz, II on 8/25/2025. See attached document for full details.

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBERS 2 AND 12. Signed by Judge Rodolfo A. Ruiz, II on 8/25/2025. See attached document for full details.

Joint SCHEDULING REPORT - Rule 26(f) by Spike Cable Networks Inc.

(Text of Proposed Order)

PAPERLESS ORDER Requiring Informal Settlement Conference. On or before September 29, 2025, the parties shall conduct an informal settlement conference for a minimum of two (2) hours. A representative with settlement authority must attend the informal settlement conference or be available telephonically. The parties shall file a Joint Notice of Compliance and Status Report certifying compliance with this Order and providing a report on the status of discussions on or before October 3, 2025. Should the parties reach a resolution of this case through meeting and conferring prior to conducting the informal settlement conference, the parties shall promptly notify the Court that the informal settlement conference will no longer be necessary. If the parties are unable to reach a resolution after conducting the informal settlement conference, this matter will be referred to the magistrate judge for a formal settlement conference. Additionally, the Court will not issue a Scheduling Order until all efforts to resolve this case as to the two remaining Defendants have been fully exhausted. Signed by Judge Rodolfo A. Ruiz, II on 8/29/2025.

NOTICE of Compliance and Status Report by Spike Cable Networks Inc. re [53] Order

ORDER OF REFERRAL TO SETTLEMENT CONFERENCE. Signed by Judge Rodolfo A. Ruiz, II on 10/1/2025. See attached document for full details.