2024-cv-02432

COMPLAINT filed by Epoch Company, Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-21783597.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Epoch Company, Ltd. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Epoch Company, Ltd. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Epoch Company, Ltd. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Epoch Company, Ltd. by John Wilson

MOTION by Plaintiff Epoch Company, Ltd. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Epoch Company, Ltd.

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2).

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 Epoch Company, Ltd. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Epoch Company, Ltd. 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 Epoch Company, Ltd. in support of motion for temporary restraining order, 11

Declaration Fumuro Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 1 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 2 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 3 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 4 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 5 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 6 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 7 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 8 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 9 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 10 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 11 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 12 of Fumuro Declaration

SEALED DOCUMENT by Plaintiff Epoch Company, Ltd. Exhibit 2 Part 13 of Fumuro Declaration

Notice of Claims Involving Trademarks by Epoch Company, Ltd.

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Motion for Leave to File Under Seal 7 and motion for leave to Exceed Page Limitation 11 are granted. Telephonic hearing on 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 12 set for 4/4/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic motion hearing held on 4/4/2024. For the reasons stated on the record, 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 12 is granted. Enter sealed order. Telephonic hearing set for 4/18/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 4/4/2024. Emailed notice

SURETY BOND in the amount of $ 10,000 posted by Epoch Company, Ltd. (Document not Imaged)

MOTION by Plaintiff Epoch Company, Ltd. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Ex-Parte Motion To Extend The Temporary Restraining Order 33 is granted. The Sealed Temporary Restraining Order entered on 4/4/2024 31 is extended to 5/2/2024. Telephonic hearing set for 4/18/2024 is stricken and reset to 5/2/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

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

MOTION by Plaintiff Epoch Company, Ltd. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Epoch Company, Ltd. in support of motion for preliminary injunction 35

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 35

SUMMONS Returned Executed by Epoch Company, Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 4/29/2024, answer due 5/20/2024.

NOTICE of Voluntary Dismissal by Epoch Company, Ltd. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic status and motion hearing held on 5/2/2024. No defendants appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion For Entry Of A Preliminary Injunction 35 is granted. The law firm of Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add the Defendants' names included in this motion to the docket within three business days. The Clerk is directed to unseal Schedule A to the Complaint 8, Exhibit 2 to the Declaration of Kazuto Fumuro (Docket entries 13 through 25) and the TRO 31. Telephonic hearing continued to 6/13/2024 at 9:15 a.m. Plaintiff is directed to file a brief status report by 6/6/2024. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 5/2/2024. Emailed notice

NEW PARTIES: UXSIO Toys, Novel design, Lehui Shopping, Jekero, Hoopu Shop, H Select, Frank Selling Factory, EYEL Toy Fairyland, Crafts Beads TOY, Carmen Childrens Products Fir, BeiLanDi, Baby Tao, Yiwu Maikai Crafts Co,Ltd, Yiwu Liuyi Trading Co., Ltd., Yiwu Keyou Toy Factory, Yiwu Juyi Import And Export Co., Ltd., Yiwu Haolu Arts & Crafts Co., Ltd., Yiwu Fashion Craft Gift Co., Ltd., Yiwu City Panda Arts & Crafts Co., Ltd., Shantou Onew Toys Co., Ltd., Ninghai Jodee Craft Co., Ltd., Ningbo Royal Import And Export Co., Ltd., Jinjiang Naike Gifts Co., Ltd., Hangzhou Artamber Culture Creative Co., Ltd., Free Market Co., Ltd., Chengdu CDM Imp.& Exp Co., Ltd., Wtong, Waterballl, WANONEE, Saieomnuew, QMINUS Ltd., limit, Give You Best, GGDZ, Eorta, Coogifts, ANDYKEN, zhazhahui1818, yantbeads, Wingdaying, Tomhousetrade Trading Co.,Ltd, Road, Pantopmall Trading Co.,Ltd, NiuXhh, liling0907, Johndhj, hellowcsy, Hasta, Gettingwhatyouwant, Diezhongdie, channy trade, AYOHOME, alice geo, yuez-du, yiyimy, yanbest, yaka_8238, xuefezha_0, xdeal2013 and wonderstshop added to case caption.

NEW PARTIES: wondersonline, warming-mall, victorywo, upforbest, tzk00b, twbangg7, trs.123, trs-welcome, team-alfashop, susuway, sunhouse88, stylishmoment, speedy-china, smz1765, smilelightly, simitter02, shoppingeveryday, shopping-home888, sachem0, river-rhine, rainbowring, prizeshop, plmew2016_6, peoplemarketing, outlave, orelushrachum, o-7399, nuoleida_2, npower007, nansh_9392, mzp5484, million*billion, martialey-0, luckystars.japan, liugua-91, lightlyshopping, libing36920133, lanuite_4, kwotop2014, kuentl, koala_outside, kingtown12, junyan2016-2, janathfx-2, j_store68, hukan0, homesale_estore, haopenp-2, hanzhetrade, guoxiangmm7, greentree199, fzeroinestore, extrasports, ellieshang, ecamonline2012, eb-blackfox, e-vanc74, e-commerce.shop, downtownmall, dongdong50, denus_shopz, debol2010, dcantshop, ctrr2669, cskwin2015, cs201_97, craftsmania, chenyuancherry, bythechance_1, boomtoo, boomshakalakatw, bollybelly and blair-gao added to case caption.

NEW PARTIES: blackfox2017, bingylov, bg27cyf, beyongbusiness, bex-shop, bettybellaa, bestoffer365, best-choice88, beautyzz2009, baokuan, anytime.commerce, anglestore, amplhood7, 8season-gift, 2014gusci, 2013blingmall, 18fashion4u, Zhejiang Yiwu Baotai Household Products Co., Ltd., Yiwu Tucheng Outdoor Products Co., Ltd., Pujiang Tongsheng Culture & Creative Co., Ltd., nidiselzu, mgatrade, Babycute Toy Online Store, ygim Store, rogd Store, n6q2 Store, ltf7 Store, k6bq Store, h35u Store, fzctj3 Store, fu2p Store, dwyp Store, christmas ornaments Store, zwrypd, zucijiang, Ystwqa, Ugghsa, pension shop, kunmingliaotudianzishangwuyouxiangongsi, chongzhoushilongxinghezhongyuxianr, windstowal, whitedew07, waltown, tingtinglive, ronald-2316, pinpin_yan, liuxiaofei1, kakabellshop, jingzhifu_2, golow9rier, eka.store, denyakim, dealwonderland, avo.shop and albkhan-0 added to case caption.

NEW PARTIES: UXSIO Toys, Novel design, Lehui Shopping, Jekero, Hoopu Shop, H Select, Frank Selling Factory, EYEL Toy Fairyland, Crafts Beads TOY, Carmen Childrens Products Fir, BeiLanDi, Baby Tao, Yiwu Maikai Crafts Co,Ltd, Yiwu Liuyi Trading Co., Ltd., Yiwu Keyou Toy Factory, Yiwu Juyi Import And Export Co., Ltd., Yiwu Haolu Arts & Crafts Co., Ltd., Yiwu Fashion Craft Gift Co., Ltd., Yiwu City Panda Arts & Crafts Co., Ltd., Shantou Onew Toys Co., Ltd., Ninghai Jodee Craft Co., Ltd., Ningbo Royal Import And Export Co., Ltd., Jinjiang Naike Gifts Co., Ltd., Hangzhou Artamber Culture Creative Co., Ltd., Free Market Co., Ltd., Chengdu CDM Imp.& Exp Co., Ltd., Wtong, Waterballl, WANONEE, Saieomnuew, QMINUS Ltd., limit, Give You Best, GGDZ, Eorta, Coogifts, ANDYKEN, zhazhahui1818, yantbeads, Wingdaying, Tomhousetrade Trading Co.,Ltd, Road, Pantopmall Trading Co.,Ltd, NiuXhh, liling0907, Johndhj, hellowcsy, Hasta, Gettingwhatyouwant, Diezhongdie, channy trade, AYOHOME, alice geo, yuez-du, yiyimy, yanbest, yaka_8238, xuefezha_0, xdeal2013 and wonderstshop added to case caption.

NOTICE of Voluntary Dismissal by Epoch Company, Ltd. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Epoch Company, Ltd. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Epoch Company, Ltd. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

CERTIFICATE of Service by William Benjamin Kalbac on behalf of Epoch Company, Ltd.

MOTION by Plaintiff Epoch Company, Ltd. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified in Amended Schedule A

(Exhibit A)

MEMORANDUM by Epoch Company, Ltd. in support of motion for default judgment 46

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 46

(Exhibit Hierl Exhibit 1)

STATUS Report by Epoch Company, Ltd.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 6/13/2024. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion For Entry Of Default And Default Judgment Against The Defendants Identified In Amended Schedule A 46 is granted. Enter order. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 6/13/2024. Emailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA.

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment