2024-cv-00684

COMPLAINT filed by Ubisoft Entertainment, S.A., Ubisoft, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-21569965.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. by Robert Payton Mcmurray

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ubisoft Entertainment, S.A., Ubisoft, Inc.

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 3).

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.

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Ubisoft Entertainment, S.A., Ubisoft, Inc. in support of motion for temporary restraining order, [10]

Declaration Muraccini Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 1 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 2 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 3 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 4 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 5 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 6 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 7 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 8 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 9 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 10 of Muraccini Declaration

SEALED DOCUMENT by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. Exhibit 2 Part 11 of Muraccini Declaration

Notice of Claims Involving Trademarks by Ubisoft Entertainment, S.A., Ubisoft, Inc.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motions for leave to file under seal 6 and for leave to file excess pages 9 are granted. Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication 10 is granted. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Charles P. Kocoras on 1/31/2024. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Trademarks)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

SURETY BOND in the amount of $ 10,000.00 posted by Ubisoft Entertainment, S.A., Ubisoft, Inc. (Document not scanned).

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Charles P. Kocoras: Motion for extension of time 29 is granted. The TRO is extended through 2/28/2024. Mailed notice

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal Without Prejudice as to Defendant No. 129

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal Without Prejudice as to Certain Defendants

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Ubisoft Entertainment, S.A., Ubisoft, Inc. in support of motion for preliminary injunction 33

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 33

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

SUMMONS Returned Executed by Ubisoft Entertainment, S.A., Ubisoft, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 2/23/2024, answer due 3/15/2024.

EMAIL correspondence from Nat Wora.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for Preliminary Injunction 33 is granted. The Plaintiff is directed to add the names of all defendants in the Schedule A to the docket within three (3) business days. Instructions can be found at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The Clerk is directed to unseal Plaintiff's Schedule A to the Complaint 7, the Exhibit 2 to the Declaration of Marc Muraccini 12 13 14 15 16 17 18 19 20 21 22 and the TRO 25.Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Charles P. Kocoras on 2/26/2024:Mailed notice

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal Without Prejudice as to Defendants No. 96, 216

NEW PARTIES: aoniyuqow, coneok, fragran_4799, hk-amigo, hongkongwond0, in_mcue, laparoladyindia, lixiaoming8588, viper_nova, 3dprintn_35, 4tobacci, a1rendering-8, alicesprings0870, allsortz23, amor-korea, apple_son, arfatskin, artifactorist, ataarza, au-velli, automa12, avid_e_o_gamer, awe-some-deals, be.mart_960, betthishasntbeentaken, big-bad-store, blackbright22, bodyspots, boss-collectibles-17, brightinside, c.o.a.t, camhopkins, carl_ontario, cartofolie, chakonoya, chasnorto9, cinema-prints, classicmovie_1900, coldbridgestore, collectible-mania-supply, collectorbypassion, commitmenteam, coscosplay, costume-crazy-online, craftandstitches, d.d.d.shop, darrylm6vki, david_b_20 and desmar38 added to case caption.

NEW PARTIES: dishi-1342, doms_toys, double_duncan_treasures, drummerboy-7, dudgau0, ECM Collectibles & Things, ehome_collection, fallscreekflips, flashtoy, flippedfoxfinds, fraoue-63, funfunoutlet, gameofasia, happysundayjapan, harthannanay-0, heblos_48, hzz04, i_find_for_you, i9s3_21, ia-leather-jackets, ig_rarehunter247, immoral_fashion_au, jagchan_40, japanhobbyoutpost, japantreasures, jessejessejessejesse, jpn-yh, js_option6644, jxw_gallery, kawaii_jpn_shop, keystones-creatives, kiwisanchez2, leatheroutfit.collections, lemar_2820, leno-2260, literalartsandcrafts, luxuriousleathers_in, m_cdirect and maiduo added to case caption.

NEW PARTIES: mamosubb, maneki, maritimesvintage, michemarge, mintytoysandcollectables, moddballs, mtctoyscanadaonline, nadasniknax, nakameshi, nicoplace31, nightbringer1313, niimohon_10, niko-o-onlineshop-uk, noble_renard, nordev, notonlybuy, oh-canada, oldbollywoodposters, oreste_23, outbackncity, oxhr5742, panda_call, peach514, poke_jym, poolroomsupplies, pop_toyz, Popcultcha, profere, quinto04, ragsnthreadz, rayjinadrianaustralia, redhon7303, retroramaau, ri-223118, rove_4386, royoune-0, rptoys1979, sail-international, shohashirt, smelllikenatto, smile.angel, somebodys_vintage and stadium_sports_bar added to case caption.

NEW PARTIES: steelbooks1, steveyboy882009, stevie19yzerman, storejapan_seven, sua_9556, sunilele-0, superstoys, susanhollo, templejapan, The DiDi's Shop, the_cardboard_investor, the_count_of_monte_clothington, theleatherfactory, thigb_0, tinker_taylor_collectables, tjk fashions, tk_japan41, toy_3288, toyfigureman, toysandwich, Treasure Gifts Brisbane, trepaz, unicorns.and.rainbows, uniquethilina, uvesvaho, watchchainandjewelry, wavenauticl, win-9597, wish_n_pick, wonatta, xhxj6340, xingmingart, yhana9416, Yigastore, youmilai, ypqk8591, zheng-8291 and zhuhuishan09 added to case caption.

MINUTE entry before the Honorable Charles P. Kocoras: The Court is in receipt of email correspondence 39 dated 2/24/24 from Nat Wora (tomatobear@hotmail.com), signed "Nattapong". The Court notes that there is no "Nattapong" listed as a defendant on the Amended Schedule A 38, and the substance of the email is clearly directed to Plaintiff's counsel, not the Court. Nevertheless, because there is no appearance on file for this individual or entity, the email correspondence is stricken. To the extent that this individual or entity wishes to file a motion before the Court, they must first file an appearance. If the sender of the email is a non-attorney and sole proprietor, they may represent themselves after filing a pro se appearance form. The form is available online at: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_online/ProSeApp.pdf. If "Nattapong" is a corporation, LLC, or partnership, it must retain counsel in order to proceed. The Clerk is directed to email a copy of this order to tomatobear@hotmail.com. Mailed notice.

MAILED Order [41] dated 02/28/2024 to tomatobear@hotmail.com.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal Without Prejudice as to Certain Defendants

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 144, 166, 246

MAILED Order 41 dated 02/28/2024 to tomatobear@hotmail.com.

CIVIL Cover Sheet. (Exhibits).

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 145

STATEMENT to be removed from the case by yhana9416.

MINUTE entry before the Honorable Charles P. Kocoras: The Court is in receipt of a filing by Defendant yhana9416 entitled "Statement to be removed from case" 46. Because there is no appearance on file, this document is stricken. If Defendant yhana9416 wishes to file a motion in this case, they must first file a pro se appearance form, which is available online at: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_online/ProSeApp.pdf. Once they have filed their appearance, Defendant yhana9416 may file an appropriate motion. Mailed notice.

PRO SE Appearance by Defendant yhana9416. (Received via pro se email on 3/6/2024)

STATEMENT to be removed from the case filed by Defendant yhana9416. (Received via pro se email on 3/6/2024)

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 247

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal Without Prejudice as to Defendant No. 241

STATEMENT by Nattapong. (Exhibits) (Received via pro se email on 03/08/2024)

ATTORNEY Appearance for Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. by John Wilson

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 159

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 125

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. to strike Plaintiffs' Motion to Strike the Statement by "NATTAPONG" [Dkt. No. 52]

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's motion to strike statement by "Nattapong" docket number 52 56 is granted. Mailed notice.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 158

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 71

MINUTE entry before the Honorable Charles P. Kocoras: Defendant yhana9416 has filed a pro se appearance [49] and a "Statement to be removed from case" [50], in which Defendant yhana9416 denies the allegations against them and asks to be taken out of the lawsuit. At this stage of the proceedings, all allegations are deemed true and construed in Plaintiff's favor, and therefore a mere denial of the allegations is not grounds for dismissal. Defendant yhana9416 must answer Plaintiff's complaint or file an appropriate motion to dismiss in accordance with the Federal Rules of Civil Procedure, supported by legal argument and authority, by 4/10/2024. Although the Court liberally construes pro se filings, this liberal construction does not extend so far as developing and researching legal arguments for litigants proceeding without counsel. Anderson v. Hardman, 241 F.3d 544, 545 (7th Cir. 2001). The Court encourages Defendant yhana9416 to retain legal counsel. Mailed notice.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 25

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Ubisoft Entertainment, S.A., Ubisoft, Inc.

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified in Amended Schedule A

MEMORANDUM by Ubisoft Entertainment, S.A., Ubisoft, Inc. in support of motion for default judgment, [64]

Exhibit 1

Exhibit 2

DECLARATION of Michael A. Hierl regarding motion for default judgment, [64]

Exhibit Hierl Exhibit 1

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for default judgment 64 is granted; Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 3/20/2024. Mailed notice.

SATISFACTION of Judgment

MAILED trademark report to Patent Trademark Office, Alexandria VA

SATISFACTION of Judgment

SATISFACTION of Judgment

MAILED trademark report with certified copy dated 3/20/2024 to Patent Trademark Office, Alexandria VA. (jn,)

SATISFACTION of Judgment

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of Ubisoft Entertainment, S.A., Ubisoft, Inc.

MOTION by Plaintiffs Ubisoft Entertainment, S.A., Ubisoft, Inc. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendant Identified in Amended Schedule A

MEMORANDUM by Ubisoft Entertainment, S.A., Ubisoft, Inc. in support of motion for default judgment 76

Exhibit 1

Exhibit 2

(Exhibit 3)

DECLARATION of Michael A. Hierl regarding motion for default judgment 76

(Exhibit Hierl Exhibit 1)

SATISFACTION of Judgment

SATISFACTION of Judgment

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's motion for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendant Identified in Amended Schedule A 76 is granted. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 4/16/2024. Mailed notice.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Ubisoft Entertainment, S.A. to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602 via certified mail # 7001 2510 0005 7681 6504.

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment