2024-cv-01673

COMPLAINT filed by Rarog j.d.o.o.; Filing fee $ 405, receipt number AILNDC-21686785.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Rarog j.d.o.o. Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Yi Bu

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Adam Grodman

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Christopher Romero

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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 Plaintiff Rarog j.d.o.o. for leave to file under seal

MOTION by Plaintiff Rarog j.d.o.o. for leave to file excess pages

MEMORANDUM in support of 13 Exparte motion

Declaration of Keith A. Vogt

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

Declaration of Sanda Krstulovic

(Exhibit 1, of Sanda Krstulovic's declaration)

SEALED EXHIBIT by Plaintiff Rarog j.d.o.o. Sealed Exhibit 2, Declaration of of Sanda Krstulovic regarding memorandum in support of motion, 14

Exhibit 2-1

(Exhibit 2-2)

Presentment for Exparte motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 11, motion for leave to file excess pages 12 before Honorable Manish S. Shah on 3/5/2024 at 09:45 AM.

[CORRECTED] Notice of Motion; Presentment for Exparte Motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 11, motion for leave to file excess pages 12 before Honorable Manish S. Shah on 3/5/2024 at 09:45 AM.

MAILED Copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. Plaintiff's ex parte motion to seal, motion to exceed page limitation, and motion for a temporary restraining order, including a temporary injunction, asset restraint, and expedited discovery and electronic service of process 11 12 13 are granted. 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, 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. 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 $100,000 bond is sufficient to secure the injunctive relief against over 100 defendants. Enter Sealed Temporary Restraining Order. Mailed notice

SEALED Temporary Restraining Order. Signed by the Honorable Manish S. Shah on 3/5/2024. Mailed

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

SURETY BOND in the amount of $ 100,000 posted by Rarog j.d.o.o. (Document not Imaged)

MOTION by Plaintiff Rarog j.d.o.o. for preliminary injunction

MEMORANDUM by Rarog j.d.o.o. in support of motion for preliminary injunction 22

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 22 before Honorable Manish S. Shah on 3/19/2024 at 09:45 AM.

SUMMONS Returned Executed by Rarog j.d.o.o. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/13/2024, answer due 4/3/2024.

(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 22 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. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 3/19/2024. Notices mailed.

NEW PARTIES: Carpet Monopoly, FaceYee, ZFqiong, yunyangquyaodanyongbaihuodian, shanxijinhuiaikeshangmaoyouxiangongsi, foshanshizhanyunmaoyiyouxiangongsi, lingongjian, DASHIKOU-US, XIAOYOUZI, HANGA, THUNGKARAT, YYDY SHOP, NOQUAN, PNJGoldent, kunmingniexiexinxikejiyouxiangongsi, ZUIWEIA US, YLSDY, hanguoxin1995, Landao Innovations, Xiloccer(7-20 Days Delivery), chuitianshangmao, HAPPYSTOREBCS, ONGGIU, ZhaiDuo, yuanzhouqubainuoyanbaihuodian and MIUERSA added to case caption.

NEW PARTIES: mINKSOE, ShanDing, OVBBESA, Lipoipo, Gale Abeop, Liting1CD, nameroiu, Osborniool, DEXIANGTT, Charbolin, YuXinXin, guangzhoudifangshangmaoyouxiangongsi, GYXRAT, WXXBOO, JiaCong, sitongyi, Shop Thuy Vuong, guangzhoutaigongshangmaoyouxiangongsi, Kokope, LandOFrug, anqingtaozhishangmaoyouxiangongsi, putianshichengxiangqulijinguobaihuoshanghan g, zhuzhoushilingwenshangmaoyouxiangongsi123, WEIXINGMAOYI, TNN SMARTSOLUX, Zhao Yong, havegoodtime, wenchangzhuliuyushangmaoyouxiangongsi, chongqinglinyufangfuzhuangyouxiangongsi, yingdegongyinglian, DIGTIA, VINSHOES, UPPADA, CYMMPU, Scyoekwg and kcdigr Spring fashion added to case caption.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant No. 19 Landao Innovations

NEW PARTIES: PIMOXV Spring fashion, FITORON Co., Ltd., Gyedtr, YFPWM, Ziloco, Segaven, SMihono, Zodggu, Geyes, Mrat, Lingdang, Shenzhen Shi Tang Qin Ke Ji You Xian Co. ltd, NaRHbrg, QWERTYU, Paptzroi INC, HATTEN store, Congjing Electronic Commerce Co., Ltd., BELLZELY, DNDKILG, TZNBGO, Fashion Ornaments, Hot6sl, HOMBOM, Qiyuan Co.Ltd, Dqueduo, XUE Co.ltd, Ryawan, Harderson Z, Fiudx, jjayotai Clearance, Pld LLC, GAF Co., LTD., Cloudedge Fushi, HSGTRH, CAICJ98 Trading Co.Ltd, SZWZ Technology, FASHIONIAL SHOPPING, CZHJS, QIAN GONG, Moonker Toys, Hong Co. Ltd, ASFHML, shenzhenshipanjiedianziyouxiangongsi, REORIAFEE, Xiadi Co.,Ltd, Brilliant, HelloQQQ, Dibo Trading Co.Ltd, VALMASS Stylish Clothing, yubikelmi Dtydtpe, Cloud, C-N-M-D, Hinvhai, Snick Store, Extraordinary lucky, YUAN-NENG and TXYshop added to case caption.

NEW PARTIES: skyscape, Creative Factory Shop, Cute Sticker, My Honey Baby, Leading HD, Art Sticker, See You Shy, JOJO Fashion Shopping and TTTST added to case caption.

NEW PARTIES: Defendant 26, Defendant 31, Defendant 35, Defendant 96 and Defendant 121 added to case caption.

MOTION by Plaintiff Rarog j.d.o.o. for default judgment as to The Defendants Identified In First Amended Schedule A

MEMORANDUM by Rarog j.d.o.o. in support of motion for default judgment 29

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 29 before Honorable Manish S. Shah on 4/18/2024 at 09:45 AM.

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

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 29 is granted. Enter Default Judgment Order. Terminate civil case. Notices Mailed.

DEFAULT FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 4/18/2024. Notices Mailed.

MAILED Closing Copyright report to Registrar, Washington DC.

(Closing Minute Entry dated 4/18/2024)

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 16 ZUIWEIA US

SATISFACTION of Judgment as to Defendant no. 28 mINKSOE and no. 37 Osborniool

SATISFACTION of Judgment CORRECTED SATISFACTION of Judgment 37 as to Defendant no. 28 mINKSOE and no. 37 Osborniool

SATISFACTION of Judgment as to Defendant no. 49 LandOFrug