2025-cv-22807

COMPLAINT against The Partnerships and Unincorporated Associations Identified On Schedule "A". Filing fees $ 405.00 receipt number AFLSDC-18552971, filed by SEGA CORPORATION, SEGA OF AMERICA, INC.

Exhibit 1

Complaint

Text of Proposed Order

Text of Proposed Order re Renewed Motion to Seal

Exhibit Declaration of George C. Sciarrino in Support of Motion to Extend TRO

Summon(s)

Text of Proposed Order

Affidavit of George C. Sciarrino

Exhibit A

Exhibit A

Exhibit A

Exhibit A

Text of Proposed Order

Clerks Notice of Judge Assignment to Judge Beth Bloom. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Marty Fulgueira Elfenbein 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.

Exhibit 2

(Exhibit Proposed Order)

Exhibit A

Text of Proposed Order

Text of Proposed Order

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

Exhibit 3

Corporate Disclosure Statement by SEGA CORPORATION, SEGA OF AMERICA, INC. identifying Corporate Parent Sega Sammy Holdings, Inc. for SEGA CORPORATION, SEGA OF AMERICA, INC.

Exhibit 4

MOTION to Seal per Local Rule 5.4 by SEGA CORPORATION, SEGA OF AMERICA, INC.

Exhibit 5

Order Requiring Scheduling Report and Certificates of Interested Parties. Signed by Judge Beth Bloom on 6/23/2025. See attached document for full details.

Civil Cover Sheet

OMNIBUS ORDER Regarding Schedule "A" Causes of Action. Signed by Judge Beth Bloom on 6/23/2025. See attached document for full details.

PAPERLESS ORDER denying 5 Motion to Seal. See the Court's Order at ECF No. 7. Signed by Judge Beth Bloom

Plaintiff's RESPONSE to [7] Order regarding Schedule "A" Causes of Action by Sega Corporation, Sega of America, Inc.

Renewed MOTION to Seal Certain Documents and Incorporated Memorandum of Law per Local Rule 5.4 by Sega Corporation, Sega of America, Inc.

PAPERLESS ORDER granting Motion to Seal. ECF No. 10. Signed by Judge Beth Bloom

SYSTEM ENTRY - Docket Entry 12 [misc] restricted/sealed until further notice. (2029729) (Text entry; no document attached.)

Order (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 13 [motion] restricted/sealed until further notice. (2029729) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 14 [motion] restricted/sealed until further notice. (2029729) (Text entry; no document attached.)

Order (Text entry; no document attached.)

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

Order (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 16 [order] restricted/sealed until further notice. (Text entry; no document attached.)

Order (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 18 [misc] restricted/sealed until further notice. (Text entry; no document attached.)

First MOTION for Extension of Time to extend ex parte temporary restraining order by Sega Corporation, Sega of America, Inc. Responses due by 8/4/2025.

ORDER granting [17] Motion for Extension of Ex Parte Temporary Restraining Order. Signed by Judge Beth Bloom on 7/22/2025. See attached document for full details.

NOTICE of Filing Proposed Summons(es) by Sega Corporation, Sega of America, Inc.

Summons Issued as to The Partnerships and Unincorporated Associations Identified On Schedule "A".

MOTION to Unseal Case by Sega Corporation, Sega of America, Inc. Responses due by 8/20/2025.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Sega Corporation, Sega of America, Inc. The Partnerships and Unincorporated Associations Identified On Schedule "A" served on 8/7/2025, response/answer due 8/28/2025.

MOTION for Preliminary Injunction by Sega Corporation, Sega of America, Inc.

MOTION to Extend the Temporary Restraining Order Dated July 14, 2025 by Sega Corporation, Sega of America, Inc.

Clerk's Notice to Filer re 25 MOTION to Extend the Temporary Restraining Order Dated July 14, 2025. Filer Selected the Wrong Motion Relief(s); ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs.

PAPERLESS ORDER granting Plaintiffs' Motion to Unseal Case. ECF No. 22. The Clerk is directed to unseal all docket entries in this case. Signed by Judge Beth Bloom

PAPERLESS ORDER REFERRING MOTION for Preliminary Injunction, ECF No. 24, to Judge Marty Fulgueira Elfenbein for Report and Recommendation. Signed by Judge Beth Bloom

ORDER Setting Hearing on Motion for Preliminary Injunction, ECF No. [24]: Motion Hearing set for 8/11/2025 at 09:30 a.m. in Miami Division before Magistrate Judge Marty Fulgueira Elfenbein. Signed by Magistrate Judge Marty Fulgueira Elfenbein on 8/7/2025. See attached document for full details.

ORDER denying [25] Motion for Extension of Ex Parte Temporary Restraining Order. Signed by Judge Beth Bloom on 8/7/2025. See attached document for full details.

CERTIFICATE OF SERVICE by Sega Corporation, Sega of America, Inc.

NOTICE of Proposed Preliminary Injunction Order by Sega Corporation, Sega of America, Inc. re [24] MOTION for Preliminary Injunction, [29] Order Setting Hearing on Motion

PAPERLESS Minute Order for proceedings held before Magistrate Judge Marty Fulgueira Elfenbein: Hearing on Plaintiff's Motion for Preliminary Injunction held on 8/11/2025 via Zoom re ECF No. 24. The Court heard from Plaintiff; reasons stated on the record. Five Defendants appeared for the hearing. The Court noted that none of the Defendants filed a response to the Motion for Preliminary Injunction as required by the Court's Order. The Defendants who were present on the Zoom were non-lawyers appearing on behalf of a corporate entity. The Court inquired whether they intended to hire counsel for the corporate entity named as a Defendant and whether they needed additional time to retain counsel. All Defendants indicated that they did not intend to hire counsel and they did not need additional time to retain counsel prior to proceeding with the hearing on the Motion for Preliminary Injunction. The Court will take the matter under advisement. Report and Recommendation to follow.Total time in court: 1 hour(s) : 00 minutes. Attorney Appearance(s): George Christian Sciarrino (counsel for the Plaintiff)Other Appearance(s): Natalie Tighe, Tatiana Haag, Rita Cherry, Sofiia Zhukovska, and Mamma Gayum. (ogn1)

REPORT AND RECOMMENDATIONS Recommending the Plaintiffs' Motion for Preliminary Injunction, ECF No. [24], be GRANTED. Objections to R&R due by 8/25/2025 Signed by Magistrate Judge Marty Fulgueira Elfenbein on 8/11/2025. See attached document for full details.

Clerk's Notice to Filer re 32 Notice (Other). Proposed Order Docketed as Main Document; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - Filer must File a Notice of Striking, then resubmit the proposed order as instructed in the CM/ECF Administrative Procedures.

CERTIFICATE OF SERVICE by Sega Corporation, Sega of America, Inc.

Clerk's Notice to Filer re 36 Certificate of Service. Docket Text Does Not Match Document; ERROR - The Filer failed to enter a title in the docket text that matches the title of the document. It is not necessary to refile the document.

NOTICE of Voluntary Dismissal as to a certain defendant by Sega Corporation, Sega of America, Inc.

NOTICE of Striking [32] Notice (Other) filed by Sega Corporation, Sega of America, Inc. by Sega Corporation, Sega of America, Inc.

NOTICE of Filing Proposed Order by Sega Corporation, Sega of America, Inc. re [34] REPORT AND RECOMMENDATIONS re [24] MOTION for Preliminary Injunction filed by Sega Corporation, Sega of America, Inc. Recommending Motion, ECF No. [24], be GRANTED., [24] MOTION for Preliminary Injunction

ORDER of Dismissal as to Certain Defendant Approving [38] Notice of Voluntary Dismissal; Dismissing Case with prejudice as to the Defendant listed in the Notice. Signed by Judge Beth Bloom on 8/15/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to certain Defendants by Sega Corporation, Sega of America, Inc.

ORDER OF DISMISSAL AS TO CERTAIN DEFENDANTS WITH PREJUDICE: re [42] Notice of Voluntary Dismissal. The above-styled case is DISMISSED WITH PREJUDICE as to the Defendants listed in the Notice: Bimuna Clothing and YueGuo Trading. Signed by Judge Beth Bloom on 8/22/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to certain Defendants by Sega Corporation, Sega of America, Inc.

ORDER of Dismissal as to Certain Defendants (With Prejudice). Signed by Judge Beth Bloom on 8/29/2025. See attached document for full details.

ORDER ADOPTING REPORT AND RECOMMENDATIONS Adopting [34] Report and Recommendations; granting [24] Motion for Preliminary Injunction. Signed by Judge Beth Bloom on 8/28/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to certain Defendants by Sega Corporation, Sega of America, Inc.

ORDER OF DISMISSAL AS TO CERTAIN DEFENDANTS WITH PREJUDICE. Signed by Judge Beth Bloom on 9/5/2025. See attached document for full details.