2024-cv-03143

COMPLAINT filed by Ubisoft Entertainment, S.A. and Ubisoft, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-21873558.

(Exhibit 1)

CIVIL Cover Sheet

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

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

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

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

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

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

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

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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 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, 13

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

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

NOTICE of Motion by Michael A. Hierl for presentment of motion for leave to file excess pages 12, motion to seal document 7, motion for temporary restraining order, 13 before Honorable Elaine E. Bucklo on 4/29/2024 at 09:00 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion to exceed page limitation 12 ; Plaintiffs' motion for leave to file under seal 7 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 13 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 5/15/2024 any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 5/8/2024. Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. 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 status hearing on 6/17/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 6/10/2024 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 5/1/2024. Mailed notice.

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

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

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 29 before Honorable Elaine E. Bucklo on 5/15/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 29 is granted to 5/29/2024. Mailed notice.

NEW PARTIES: yiboyy Store, ugg123_store Store, totals store, topseller5699 Store, taddllee Store, superleo2012 Store, slf51gs Store, sderf671 store, riching2 Store, pradas_store Store, plpaa Store, nnjoi15 Store, mu03 Store, mu01 Store, Men's Jeans Store, macqueens Store, luo05 Store, luo04 Store, luo01 Store, lulues Store, lucky_symbol Store, lizhiwei003 Store, Ladymm Store, kun6 Store, ksijf987 Store, jkokk Store, jknf450 store, jishencifu Store, janet1221 Store, installation7 Store, harlyx Store, guccies_store Store, fuvlkb Store, frank0098 Store, forseason Store, fashionclothes089 Store, fascinations store, eastercn Store, dldl123123 Store, diors_store store, designerbagschina Store, cvfr5609 store, creations Store, cong01 Store, clotheskind Store, cbjmly Store, bin8688c3 Store, bgvvcf Store, asert Store, amamhy3 Store and aicfza Store added to case caption.

NEW PARTIES: ZA-Fashed, Yuedewangluo, xianyouxianlichengjiedaochenxuezhangbaihuolingshou, xianyouxiandajizhenlinrongjiejiadianshanghang, wenzhihongyishu, WeiHongXiangHDFLKJJDKLSJLDKF, walletsnhats4u, Vintage Shop Item, Verona Leather, Skin Crafts, shenzhi, shanxiyishengtielupeijianyouxiangongsi, shanxishenyuhaoshangmaoyouxiangongsi, Robiteno, PU TIAN ZHANG LONG MAO YI YOU XIAN GONG SI, PoVaTaSo, Pink Wish Shop, ooinxs, Nvt593, Monicart DXN, Miaikvs, MANDAHAR STORE, LLiSSun, Lilith Coverdale, Kefa Trading Company, JieXinYF, IA COLLECTION, HUAZHIMU JP, huangshishidingyunshangmaoyouxiangongsi, homieson, Hidetaka Design, HELI-SHOP, Harbin Shang, hainanshengxiazhiyemeibaihuoshanghang(gerenduzi), guochengxian, guniangzainalidianzishangwuyouxiangongsi, Goshfun, GENYUANKJ, Gan Gardner, Fuxyang, fengsiruimaoyi, Fanta Department Store, Duanweinan, Chuntianhua Handmade Toy Shop, Cheryl Whitehead, ChengShunArtPrint, Batustou, Antique Makers, AEI Hobby, zhangyong123, yuyang1314520.a, Yongjiali, yangwenhai025621, yangkai5574, XUEFEISB, taizuzongjian, sunyang5667, Rufengtu, roberts90fossms92, punogiftshop, minx2828, lzx22, luwenhao9871, liyutong20833, liming1134, liaolinchun668, ladoew, Kexiangying, Joanne Harrower, hfeilsu6g, gf90-ywh, furulei123, fritz77tubbs94, Filing susunten, Fashion viho, cosiok, ashtoncharles, vanillaundergroundcom, untoldcomics, TriadStore, tommystreats76, tiktokvintage, ti_465007, theresellersvintage, thegoonies1987, the-toy-hunter, the_velveteen_rabbit, the_urbang86, the_entertainment_hub, textiletransfers, teevaultgb, tat_llc and targetcars-85 added to case caption.

NEW PARTIES: t-shirtsbysteve, superking-mk, ststephensbooks, spikedabomb, sonnier82, sniffybadger1987, skippy41uk, shoppymcshopshop, shinobi.blak, secondchancefashions, sciencefictionworld, revolutsia, retrostyler, retro_tech_atl, ranran456, qxy_5690, ptlless, pawd9, mathiamuchu_0, majesticleather2016, lijianwe_31, ka_31692, just4games, j-artwork, hongtu666, honghuo868, halloweenandhobby, freesty, eliaelmalia_0, dudu-anime, changzhishuijiesha-0, buyallhappy, BobbyDobby-0520, beautiful1890, bearsden9776, audiwolf, anibreak, ajcreativeclothes, 5thlj, polongshun Store, noxinfashionstore Store, monclairss Store, lily_zhang5 Store, jansport Store, yueyulongshangmaodian, xieyangpengshop, XiaLingXiaoDian, Thesaha, tangmeijie, mianyu, KongXiangHua-shop, KING-TY, henqsmyxgs, Hefeitiren, haikougupishangmaoyouxiangongsi, GuanJuan, dvcxv, chongqingzhangjunziwujinjiancaiyouxiangongsi, Aright2, Zzresez, Zzqjcjy, Zznetto, Zzmilan, Zzmarti, zmjnvzhuang, ytwqo, yangqin, xzvfkm, wanghaiyu1234, vxvhgj, shuchengjiao22, NKGBJYG, mkjyfgv, mjbgfdg, mfydfygi, mbvmnrfh, mabxdf, kmjlojg and jmnftujyh added to case caption.

NEW PARTIES: top-gun!, factory*store, fbdbdr, gfdzcxg, gfbcvbh, fgdcvb, eetryl, dsfdghj, bmjkkh, bffdsfd, bdgdas, adenexuuzwus, zhjycq, xx02, tome.gidon, taron-store, subgal1992, seventhavenue*jeep, sdfrvf, ndt_7107 and global_premium_shop added to case caption.

NEW PARTIES: Shaanxi Wangkuilan Network Technology Co., Ltd added to case caption.

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 32

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 32

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 32 before Honorable Elaine E. Bucklo on 5/29/2024 at 09:45 AM.

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

SUMMONS Returned Executed by Ubisoft, Inc., Ubisoft Entertainment, S.A. as to The Individuals, Corporation, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 5/22/2024, answer due 6/12/2024.

MINUTE entry before the Honorable Elaine E. Bucklo: Motion hearing held on 5/29/2024. Defendant to respond to plaintiffs' motion for entry of a preliminary injunction 32 by 6/12/2024. Plaintiffs' reply due by 6/26/2024. Ruling set for 7/10/2024. The Court will issue a ruling by mail. Mailed notice.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 96

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiffs' Notice of Voluntary Dismissal as to Defendant No. 116

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

ATTORNEY Appearance for Defendant sciencefictionworld by Erin Kathryn Russell

ATTORNEY Appearance for Defendant halloweenandhobby by Randy R Micheletti

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 73

STATUS Report Joint Initial Status Report by Ubisoft Entertainment, S.A., Ubisoft, Inc.

MOTION by Defendant sciencefictionworld for extension of time to file answer regarding complaint 1 (UNOPPOSED)

(UNOPPOSED) NOTICE of Motion by Erin Kathryn Russell for presentment of motion for extension of time to file answer 45 before Honorable Elaine E. Bucklo on 6/19/2024 at 09:45 AM.

PRO SE Appearance by Defendant Sean Kinge. (Received via pro se email on 6/12/24.)

MOTION by Defendants Sean Kinge, shoppymcshopshop for extension of time to file answer or other response. (Received via pro se email on 6/12/24.)

NOTICE of Motion by Sean Kinge, shoppymcshopshop for presentment of motion for extension of time to file answer or other response 49 before Honorable Elaine E. Bucklo on 6/21/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendant sciencefictionworld's unopposed motion for extension of time to answer or otherwise plead Plaintiffs' complaint 45 is granted to 6/26/2024. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendant shoppymcshopshop's motion for extension of time to file answer or other response to Plaintiffs' complaint 49 is granted to 6/26/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiffs' Notice of Voluntary Dismissal as to Defendant No. 92

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiffs' status report. Pending defendant(s) responsive pleadings, the ruling on plaintiffs' motion for entry of a preliminary injunction 32 as to all non-appearing Defendants is set for 7/10/2024. Plaintiff is directed to submit their revised proposed preliminary injunction order to this court's proposed order email inbox. Mailed notice. (jn,)

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

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

NOTICE of Voluntary Dismissal by Ubisoft Entertainment, S.A., Ubisoft, Inc. Plaintiffs' Notice of Voluntary Dismissal as to Defendant No. 89

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

CERTIFICATE of Service by John Wilson 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

(Exhibit A)

MEMORANDUM by Ubisoft Entertainment, S.A., Ubisoft, Inc. in support of motion for default judgment, 59

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 59

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment, 59 before Honorable Elaine E. Bucklo on 8/14/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction 32 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Plaintiffs' Schedule A to the Complaint Dkt. No. 8, Exhibit 2 to the Declaration of Marc Muraccini Dkt. Nos. 15 - 23 and the TRO Dkt. No. 27. Plaintiffs' motion for entry of default and default judgment against the defendants identified in Amended Schedule A 59 is granted. Enter Final Default Judgment Order. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 8/14/2024. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 8/14/2024. Mailed notice.

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment