2024-cv-01086

COMPLAINT filed by Howard Robinson; Filing fee $ 405, receipt number BILNDC-21615821.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBITS by Plaintiff Howard Robinson Schedule A to Complaint 1 Modified on 3/12/2024.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Howard Robinson by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Howard Robinson by Yanling Jiang

ATTORNEY Appearance for Plaintiff Howard Robinson by Yi Bu

ATTORNEY Appearance for Plaintiff Howard Robinson by Adam Grodman

ATTORNEY Appearance for Plaintiff Howard Robinson by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Howard Robinson by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Howard Robinson by Christopher Romero

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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.

MAILED copyright report to Registrar, Washington DC

MOTION by Plaintiff Howard Robinson for leave to file under seal

MOTION by Plaintiff Howard Robinson for leave to file excess pages

MEMORANDUM in support of 14 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Howard Robinson

(Exhibit 1, of Howard Robinson's declaration)

EXHIBIT by Plaintiff Howard Robinson Sealed Exhibit 2, Declaration of Howard Robinson regarding memorandum in support of motion, 15 Modified on 3/12/2024.

Exhibit 2-1

(Exhibit 2-2)

Presentment for Exparte motion 14 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 13, motion for leave to file 12 before Honorable Manish S. Shah on 2/21/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion for a temporary restraining order, asset restraint, expedited discovery, and electronic service of process, motion for excess pages, and motion to seal 12 13 14 are granted, and no appearance on the motions is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits as to the defendants listed in Schedule A, the harm to plaintiff is irreparable, and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property and causes consumer confusion. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunction. Plaintiff's evidence covers three copyrighted works, no more; the court enters injunctive relief only for the works submitted. Enter Sealed TRO. Notices mailed.

TEMPORARY Restraining Order: Signed by the Honorable Manish S. Shah on 2/20/2024. Notices mailed. Modified on 3/12/2024.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 50,000 posted by Howard Robinson (Document not scanned.)

MOTION by Plaintiff Howard Robinson for preliminary injunction

MEMORANDUM by Howard Robinson in support of motion for preliminary injunction 21

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's declaration)

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 21 before Honorable Manish S. Shah on 3/5/2024 at 09:45 AM.

SUMMONS Returned Executed by Howard Robinson as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/27/2024, answer due 3/19/2024.

(Declaration of Service)

MINUTE entry before the Honorable Manish S. Shah:Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 21 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Mailed notice

PRELIMINARY Injunction Order. Signed by the Honorable Manish S. Shah on 3/5/2024. Mailed notice

NEW PARTIES: GUANGFA MAOYI STORE, Maripa-US, limoting, Sensfun Backdrops, yichuangkj, doudou decorate, TYSMYC, Calmd, Yaoyodd19, Newrys, Ahwow Gift, AFOKAR, CCFLY, Tengss and Toy-baby added to case caption.

NEW PARTIES: dingwenlinbaihuodian, Pasamer, Socialme, HFAMAZMN, XIAMEN HOWKKI ENTERPRISE CO., LTD, Orfatya, SONARIN, jingfushangmaode and LOWORO added to case caption.

NEW PARTIES: zipengbaihuo, ATTX, Byeanmall66, WorldGES, NXJYKJYXGS, LSHOKJ, WHXRDSMYXGS, ZOOYUU, dhsdhi34hv, Happy day Store, lisenbaihuo, GO JIAXIAO, yunxiaocbaihuo, CSSYHQ and Scott Polly added to case caption.

NEW PARTIES: zhaoqingtian15676, wanzaixianpengningtibaihuodian, SWWBD, HaiChuangShiDaiMaoYiYouXianGongSi, SQATDS, yingtai01, kevinleesx, SHUONUOSHANGMAO, xiongmaodaxia, Yunplsad-US and FuDD added to case caption.

NEW PARTIES: MoreToys, LvYuanQuAoZheBanGongYongPinJingXiaoChu, ShenZhen Shi AiLiLian E-Business Co.,Ltd, weijupengwanjudianus, MANQIAN, YaoMuChenshop, MayaStar, telglass, Pingyu County Feitian Trading Company, henanshengjiajiafengnongyekejiyouxiangongsi, jiayinwu123jw, RecurFitstore, Lexfvpoo store, shi bi chun, Ginyia U, Mxtech, WEIERHUI01, WXHouse, junjun965, Yokuna, yanhongbaihuodian, Nitrip, MALLOOM, Cairhuire, GO BIN RUI, Prexey, reima art, Huizhke and Jadpes mg added to case caption.

NEW PARTIES: WJNNA007, EARVO, nusind, Yuze-US, huayue store, Magwen226, Naroote, Goldzun, Domgoge-US, Densive, Funwehua-US, Balonta, Aohicon-US, yafa, Hongzer, Eight Degrees Of Sunshine, Chen shi fan Arts and crafts, Similane, Mssy, UfcellStore, ELEQIN, dengzhoushiyanbeicaishangmaoyouxiangongsi, FLYEHI, Lurss and NGUYENTHIHONG141414 added to case caption.

NEW PARTIES: Vi Anh Dung, DTHHShop, NguyenNgocMai, AKPXRT store, LiCheng Art, SHILI HOME, changtengshangmao, hongdonghuafanmaoyiyouxiangongsi, gehaodianzishangwu, GEEREE, jinghexinchengshengfeibenbaihuodian, quanzhoushilichengqukuabadianzishangwuLtd, HQER, xinzhengshiyangshengjingluoguan, wesley Hu, HBRise, Runzesha INC, Lin Living, FSSZNB, PrettyPlate, Ran_O, SZDR, feng poster, BTTY, Homli, Nikoal, heropleasestay, The Wortex, CBB Home Decor, GEEOEE, quanzhoulichengbaitingdianzishangwuyouxiangongs i, Cairnsi, DOTZSO, TripStan, liziciti and ADVOCATOR added to case caption.

NEW PARTIES: CHAQLIN, quanzhoushiyasenfenglvzhipinyouxiangongsi, zadasdsada, MMACWHB, TOADDMOS, BuyBai, LoveTaoTao, Ayaatee, Calm down and think, Tiloser, shouyangxianhoujiashanghang, CCCCCCL, wenchangshiqingyuelanwangluokejiyouxiangongsi, Xin Xiu Lai, Liaok, KangRongDianZiShangWuYouXianGongSi, GRAN BEDDING, Luofanfei, anqingbudushangmaoyouxiangongsi, usa duvet set, Click for more offers, hjinghuochi, TerryBDoyalp, kekieer, guangzhoufenmeishangmao and duhighg added to case caption.

NEW PARTIES: Defendant 13, Defendant 57, Defendant 62, Defendant 67, Defendant 118, Defendant 131, Defendant 138, Defendant 145 and Defendant 156 added to case caption.

ATTORNEY Appearance for Defendants Aohicon-US, Balonta, Cairhuire, Densive, Funwehua-US, Ginyia U, Goldzun, Hongzer, Huizhke, Jadpes mg, Magwen226, Mxtech, Naroote, Nitrip, Orfatya, Pasamer, Prexey, Socialme, Yokuna, Yunplsad-US, Yuze-US, nusind, yafa by Timothy Tiewei Wang

(Exhibit A - List of Represented Defendants)

MOTION by Defendants Aohicon-US, Balonta, Cairhuire, Densive, Funwehua-US, Ginyia U, Goldzun, Hongzer, Huizhke, Jadpes mg, Magwen226, Mxtech, Naroote, Nitrip, Orfatya, Pasamer, Prexey, Socialme, Yokuna, Yunplsad-US, Yuze-US, nusind, yafa for extension of time to file answer regarding complaint 1

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer, 28 before Honorable Manish S. Shah on 3/26/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 28 is granted, and no appearance on the motion is necessary. Defendants Yunplsad-US, Naroote, Huizhke, Prexey, Aohicon-US, Funwehua-US, Ginyia U, Goldzun, Nusind, Mxtech, Pasamer, Densive, Socialme, Cairhuire, Magwen226, Jadpes mg, Yokuna, Nitrip, Yafa, Yuze-US, Hongzer, Orfatya, and Balonta have until 4/18/24 to respond to the complaint. Notices mailed.

MOTION by Plaintiff Howard Robinson for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Howard Robinson in support of motion for default judgment 31

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 31 before Honorable Manish S. Shah on 3/26/2024 at 09:45 AM.

ATTORNEY Appearance for Defendants Newrys, Yaoyodd19, SONIPO by Adam Edward Urbanczyk

MOTION by Defendants Newrys, SONIPO, Yaoyodd19 for extension of time UNOPPOSED

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time 35 before Honorable Manish S. Shah on 3/26/2024 at 09:45 AM.

ATTORNEY Appearance for Defendants Newrys, SONIPO, Yaoyodd19 by Brian Swift

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. With no objection, the motion for extension of time 35 is granted, and Defendants Newrys, SONIPO, Yaoyodd19 have until 4/22/24 to respond to the complaint. For the reasons stated in open court, the motion for default judgment 31 is granted. Enter Default Judgment Order. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 3/26/2024. Notices mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

SATISFACTION of Judgment as to Defendant no. 4 Sensfun Backdrops

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

SATISFACTION of Judgment as to [Certain] defendants

MINUTE entry before the Honorable Manish S. Shah: All of plaintiff's claims having been resolved, this case is dismissed. Civil case terminated. Notices Mailed.

MAILED copyright report to Registrar, Washington DC

SATISFACTION of Judgment as to Defendant no. 35 Happy day Store