2022-cv-06691

COMPLAINT filed by FoxMind Canada Enterprises, Ltd.; Filing fee $ 402, receipt number AILNDC-20090778.

EXHIBIT by Plaintiff FoxMind Canada Enterprises, Ltd. Ex.1. Match Madness Registrations regarding complaint 1

(Exhibit Ex. 2 - FoxMind Schedule A Slipsheet)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff FoxMind Canada Enterprises, Ltd. by David Edward Hutchinson

SEALED DOCUMENT by Plaintiff FoxMind Canada Enterprises, Ltd. Schedule A to Complaint

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FoxMind Canada Enterprises, Ltd.

CLAIM by FoxMind Canada Enterprises, Ltd. regarding Trademarks.

CLAIM by FoxMind Canada Enterprises, Ltd. regarding Copyright.

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. for leave to file excess pages

Supplement Memorandum in support of TRO

Declaration David E. Hutchinson Declaration

Exhibit Ex. 1 to Attorney Declaration - Jan 2011 Mark Monitor

Exhibit Ex. 2 to Attorney Declaration - 2020 IP Rights Seizures Stat Report

Exhibit Ex. 3 to Attorney Declaration - BASCAP Report

Exhibit Ex. 4 to Attorney Declaration - ICANN Registrar Accreditation Agreement

Exhibit Ex. 5 to Attorney Declaration - Hague Convention on Service Abroad

Exhibit Ex. 6 to Attorney Declaration - Translation of Civil Procedure Law of the People of China

Declaration Declaration of David Capon

(Exhibit Ex. 1 Match Madness Registrations)

SEALED DOCUMENT by Plaintiff FoxMind Canada Enterprises, Ltd. Ex. 2 (Parts 1 of 11) to David Capon Declaration.

Exhibit Ex. 2 (Part 2 of 11) to David Capon Declaration

Exhibit Ex. 2 (Part 3 of 11) to David Capon Declaration

Exhibit Ex. 2 (Part 4 of 11) to David Capon Declaration

Exhibit Ex. 2 (Part 5 of 11) to David Capon Declaration

Exhibit Ex. 2 (Part 6 of 11) to David Capon Declaration

Exhibit Ex. 2 (Part 7 of 11) of David Capon Declaration

Exhibit Ex. 2 (Part 8 of 11) of David Capon Declaration

Exhibit Ex. 2 (Part 9 of 11) of David Capon Declaration

Exhibit Ex. 2 (Part 10 of 11) of David Capon Declaration

(Exhibit Ex. 2 (Part 11 of 11) of David Capon)

ATTORNEY Appearance for Plaintiff FoxMind Canada Enterprises, Ltd. by Nathan Daniel Monroe-yavneh

ATTORNEY Appearance for Plaintiff FoxMind Canada Enterprises, Ltd. by Christopher Tom

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment.

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MAILED copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 9 and motion for leave to file excess pages 11 are granted. Plaintiff's motion for entry of a sealed ex parte temporary restraining order is also granted 10. Enter Sealed Ex Parte Temporary Restraining Order. Preliminary injunction hearing is set for 12/22/2022 at 8:50 AM. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. Any motion to extend the temporary restraining order or motion for preliminary injunction must be filed by 12/19/2022. Any motion for preliminary injunction filed hereafter in this case must be accompanied by a certificate of service stating upon whom and how the motion has been served. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 12/8/2022.

ORDER ON PLAINTIFF'S EX PARTE MOTION TO EXTEND TEMPORARY RESTRAINING ORDER signed by the Honorable Matthew F. Kennelly on 12/20/2022: Plaintiff's motion to extend the ex parte temporary restraining order is granted, through 1/5/2023. Telephonic preliminary injunction hearing set for 12/22/2022 is vacated and reset to 1/5/2023 at 8:50 AM, using call-in number 888-684-8852, access code 746-1053. Motion for preliminary injunction must be filed by no later than 1/2/2023 and must be accompanied by a certificate of service describing upon whom and how the motion has been served.

BOND in the amount of $ 5000.00 via check, Receipt No. 4624280461, posted by FoxMind Canada Enterprises, Ltd.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice.

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. for preliminary injunction

Supplement Memo in support of Preliminary Injunction

Declaration David E. Hutchinson Declaration in support of Motion for Preliminary

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for preliminary injunction [23] is granted. Enter Preliminary Injunction Order. The hearing date of 1/5/2023 is vacated. The Clerk is directed to unseal the file in this case and is also directed to amend the caption and title of the case to read: FoxMind Canada Enterprises Ltd. vs. Arrydrry Official Store et al. Law Firm Thoits Law is ordered to add all defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 3/7/2023 at 8:50 AM. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. Plaintiff is directed to file a status report on 2/28/2023 regarding service of the preliminary injunction and any settlement discussions. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 1/3/2023. Mailed notice.

SUMMONS Returned Executed by FoxMind Canada Enterprises, Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A of the Complaint on 1/4/2023, answer due 1/25/2023.

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. for preliminary injunction Plaintiff's Second Motion for Entry of a Preliminary Injunction.

Supplement Memo in support of Second Motion for Preliminary Injunction

(Declaration David E. Hutchinson Declaration in support of Second Motion for Preliminary Injunction)

NEW PARTIES: Arrydrry Offcial Store (1), ASWJ Official Store (2), Baby Growthing Store (3), congtou Store (4), Conqueror's store (5), daguo toy Store (6), Fafafa Store (7), faina's Store (8), FlyAC Store (9), Fun Together No. 14 Store (10), Fun Toy Box Store (11), HizoeChu Toy Store (12), Hoery Mother, Baby & Toy Store (13), iBaseToy Zone Store (14), iPlay iLearn Official Store (15), KOLEHOME Store (16), LOLlive Store (17), lvse life Store (18), ModernBaby Store (19), Mon Mere&Baby Store (20), Mother & Baby Toy Store (21), QWZ First Toy Store (22), Shop3625110 Store (23), Small fire Store (24), Someone 's 15 Store (25), TopGou Store (26), TT Toy Store (27), Viego Store (28), WJBJOY RC TOY Store (29), XXRT TOY Store (30), ZHWisdom FUN Store (31), AJIE-US (32), Deals Direct US (33), DOWNWINDU.S (34), DYXUS (35), Eggfine (36), JXYSX-US (37), LSYDCARM Store (38), Misike (39), PinkClouds-US (40), Yousheng Toy (41), www.comespirit.com (42), Daliylife.wshopon (43), amaljariya (44), dudigalabrgel (45), hubeihsi (46), iconicretailstore (47), jeanb1981 (48), modernlife100 (49), peisen (50), rerost-9 (51), sh_shop (52), trminh_58 (53), utoejkjd (54), hionvictsker (55), Knock on Wood Toys (56), lauraslift (57), Lautapelit.fi (58), llccjjl (59), presentsofmind (60), thegamesshop (61), thetherapystore (62), Anggrek Store (63), AOZWIN (64), Besida International Group Ltd (65), BRRNOO (66), Chengdu Jingzhi Trading Co., Ltd. (67), Chengdu Yimei Technology Co. (68), CPYK STORE (69), EOTVIA store (70), FEIXING STORE (71), FEIXINXIN STORE (72), FONWOON (73), guangzhoushijupingshangmaoyouxiangongsi (74), Gupbes Store (75), HILITAND (76), JAYBALLY INC (77), Ji feng long rui ke ji (Cheng du) you xin gong si (78), JIUTAIRONG STORE (79), JXYH STORE (80), LAFGUR Store (81), LHCER STORE (82), Lowerprice Store (83), LUCKISTARS.LLC (84), LYUMO STORE (85), Mgaxyff STORE (86), OAVQHLG3B (87), Octpeak Store (88), QIILU SHOP (89), Richangjing (90), shanghaiquejuewangluokejiyouxiangongsi (91), Shen zhen shi de xing yang ke ji you xian gong si (92), Shen zhen shi gui feng da ke ji you xian gong si (93), Shen zhen shi jia na ke ke ji you xian gong si (94), Shen zhen shi jing yao fei ke ji you xian gong si (95), Shen zhen shi mei xi zi ke ji you xian gong si (96), Shen zhen shi zhong li rui ke ji you xian gong si (97), Shenzhen Huamingyu Technology Co., Ltd. (98), Shenzhen Maibao Trading Co., Ltd. (99), shenzhen shi zhi li ying keji youxian gongsi (100), Shenzhen Yarong Technology Co., Ltd. (101), Shenzhen Xinxiangheng Technology Co., Ltd (102), shenzhenshixiangmiliwanjuyouxiangongsi (103), shenzhenshiyijiejiawanjuyouxiangongsi (104), shenzhenshiyimingdianzishangwuyouxiangongsi (105), SHEOWO (106), SPFX STORE (107), SQVISHTOY (108), Tebru STORE (109), Telisoe (110), UHNDY (111), VINTGH (112), WALFRONT LLC (113), Wmkox8yii (114), XGJG STORE (115), YICHAOFAN STORE (116), YLSHRF Store (117), YOODUDES (118), Youhuaxin (119), YOUTHINK STORE (120), ZHAOTAO STORE (121), Warehouses Overstock (122), wang hun (123) and zhangyu789 (124) added to case caption.

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. for extension of time Plaintiff's Second Motion to Extend Temporary Restraining Order as to Defendant Nos. 32, 33, 34, 35, 36, 37, 38, 39, 40, and 41.

Supplement Memo in support of Second Motion to Extend TRO

(Declaration David E. Hutchinson Declaration in support of Second Motion to Extend TRO)

SECOND PRELIMINARY INJUNCTION ORDER (as to certain defendants) signed by the Honorable Matthew F. Kennelly on 1/5/2023: Second motion for preliminary injunction (as to certain previously unserved defendants) 27 is granted. MOtion for extension of temporary restraining order (as to those same defendants) is denied as moot.

NOTICE of Voluntary Dismissal by FoxMind Canada Enterprises, Ltd. of Defendant No. 47 (iconicretailstore).

NOTICE of Voluntary Dismissal by FoxMind Canada Enterprises, Ltd. of Defendant Nos. 87 (OAVQHLG3B) and 114 (Wmkox8yii).

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. to approve consent judgment Agreed Motion for Entry of Consent Judgment.

CONSENT JUDGMENT signed by the Honorable Matthew F. Kennelly on 1/20/2023: Motion for consent judgment as to a particular defendant is granted 32.

NOTICE of Voluntary Dismissal by FoxMind Canada Enterprises, Ltd. of Defendants No. 48 (jeanb1981) and No. 77 (JAYBALLY INC).

ATTORNEY Appearance for Defendants Anggrek Store (63), BRRNOO (66), Conqueror's store (5), Fun Together No. 14 Store (10), Fun Toy Box Store (11), hubeihsi (46) by Timothy Tiewei Wang

(Exhibit A - List of Represented Defendants)

MOTION by Defendants Anggrek Store (63), BRRNOO (66), Conqueror's store (5), EOTVIA store (70), FEIXING STORE (71), Fun Together No. 14 Store (10), Fun Toy Box Store (11), Mother & Baby Toy Store (21), Octpeak Store (88), Shop3625110 Store (23), Someone 's 15 Store (25), hubeihsi (46), utoejkjd (54) for extension of time to file answer regarding complaint 1

NOTICE of Voluntary Dismissal by FoxMind Canada Enterprises, Ltd. of Defendant Nos. 42, 43, 55, 56, 57, 58, 59, 60, 61, 62, and 122.

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. for entry of default and default judgment.

Supplement Memo in support of Motion for Entry of Default and Default Judgment

Declaration David E. Hutchinson Declaration in support of Motion for Default and Default Judgment

Exhibit Ex. A to D. H. Declaration - 3424 Summons Service Emails

Exhibit Ex. B - Case Website

Exhibit Ex. C - First Amended Schedule A

(Exhibit Ex. D - Iron Maiden Default Judgment)

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendants Anggrek Store (63), BRRNOO (66), Conqueror's store (5), EOTVIA store (70), FEIXING STORE (71), Fun Together No. 14 Store (10), Fun Toy Box Store (11), Mother & Baby Toy Store (21), Octpeak Store (88), and Shop3625110 Store (23) for extension of time is granted 36. Response to complaint by these defendants is to be filed by 2/22/2023.

DEFAULT JUDGMENT ORDER AS TO CERTAIN DEFENDANTS, signed by the Honorable Matthew F. Kennelly on 2/9/2023: Motion for entry of default judgment as to certain defendants 38 is granted.

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 74 (guangzhoushijupingshangmaoyouxiangongsi).

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff failed to file a status report on 2/28/2023 as ordered (see dkt. no. 24). Plaintiff is ordered to comply with the Court's order by no later than 4:00 PM today (3/3/2023).

STATUS Report by FoxMind Canada Enterprises, Ltd.

MINUTE entry before the Honorable Matthew F. Kennelly: Based on plaintiff's status report, the telephonic status hearing set for 3/7/2023 is vacated and reset to 3/21/2023 at 8:55 AM. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. The Court will vacate the hearing if a stipulation for dismissal that makes it clear on its face that it covers all remaining defendants is filed before that date.

MOTION by Attorney Nathan Monroe-Yavneh to withdraw as attorney for FoxMind Canada Enterprises, Ltd. No party information provided

(Affidavit Affidavit in support of Motion for Withdrawal of Attorney of Record (Nathan Monroe-Yavneh))

(Text of Proposed Order Proposed Order for Withdrawal of Attorney of Record (Nathan Monroe-Yavneh))

MINUTE entry before the Honorable Matthew F. Kennelly: Motion to withdraw appearance of Nathan Monroe-Yavhen 45 is granted.

NOTICE of Voluntary Dismissal by FoxMind Canada Enterprises, Ltd. of Defendant Nos. 5, 10, 11, 21, 23, 25, 46, 54, 63, 66, 67, 68, 69, 70, 71, 72, 76, 78, 79, 80, 81, 82, 85, 86, 88, 89, 90, 92, 93, 95, 96, 97, 98, 101, 102, 107, 109, 115, 116, 117, 119, and 121.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's recently filed notice of voluntary dismissal says that no defendants remain pending in the case. The Clerk is directed to close the case and vacate the 3/21/2023 status hearing. Civil case terminated. Mailed notice.

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 34 (DOWNWINDU.S.)

MOTION by Plaintiff FoxMind Canada Enterprises, Ltd. for settlement and request for entry of disbursement order releasing bond.

(Text of Proposed Order Proposed Disbursement Order)

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's request for entry of a disbursement order is granted. Plaintiff should e-mail a Word and a PDF version of the proposed order to Judge Kennelly's proposed order e-mail address (this has not yet been done).

MAILED copyright report to Registrar, Washington DC (jk2,)

DISBURSEMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 3/21/2023. Mailed notice.

DISBURSEMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 3/21/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 38 (LSYDCARM Store).

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 41 (Yousheng Toy).

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 39 (Misike).

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 40 (PinkClouds-US).

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant Nos. 32 (AJIE-US) and 35 (DYXUS).

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant No. 49 (modernlife100).

FULL SATISFACTION of Judgment regarding order on motion for entry of default, terminate motions 40 of Defendant Nos. 14 (iBaseToy Zone Store), 20 (Mon Mere&Baby Store), 28 (Viego Store), and 31 (ZHWisdom FUN Store).