2024-cv-04203

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 405, receipt number AILNDC-21992619.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Christopher Romero

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Monica Rita Martin

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yi Bu

CASE ASSIGNED to the Honorable Sara L. Ellis. 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.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ground Works Co., Ltd., Khara Inc.

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file under seal

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file excess pages

MEMORANDUM in support of [14] Exparte motion

Declaration of Keith A. Vogt

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

Declaration of Yasuhiro Kamimura

Exhibit 1, of Yasuhiro Kamimura's declaration

SEALED EXHIBIT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Sealed Exhibit 2, Declaration of Yasuhiro Kamimura regarding memorandum in support of motion, [15]

Presentment for [14] Exparte motion and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file[12], motion for leave to file excess pages[13] before Honorable Sara L. Ellis on 5/28/2024 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motions for leave to file under seal [12], for leave to file excess pages [13], and for a temporary restraining order [14]. The Court sets a status date for 6/6/2024 at 1:45 PM. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status hearing. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Sara L. Ellis on 5/24/2024. Mailed notice.

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

CIVIL BOND in the amount of $ 10,000 posted by Ground Works Co., Ltd., Khara Inc. (Document Not Imaged).

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for extension of time for Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time[21] before Honorable Sara L. Ellis on 6/6/2024 at 01:45 PM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for extension of the temporary restraining order [21]. The Court extends the TRO through 6/21/2024. The Court strikes the status date set for 6/6/2024 and resets it to 6/20/2024 at 1:45 PM. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for preliminary injunction

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for preliminary injunction 24

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 24 before Honorable Sara L. Ellis on 6/20/2024 at 01:45 PM.

SUMMONS Returned Executed by Khara Inc., Ground Works Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/6/2024, answer due 6/27/2024.

(Declaration of Service)

ATTORNEY Appearance for Defendant Vaxson by Huicheng Zhou

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for entry of a preliminary injunction [24]. The Court strikes the status date set for 6/20/2024 and resets it to 7/23/2024 at 9:45 AM. Plaintiff should file any motion for entry of default and for default judgment and notice it for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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

MEMORANDUM by Vaxson in opposition to Plaintiff's Motion for entry of preliminary injunction

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Sara L. Ellis on 6/20/2024:Mailed notice

NEW PARTIES: 76pitungpu13, agbatu0, allyaccessory, anime*store*2018, atelier.doll, baik58, blkuopar, car16888, cef8860, chromezgk, chuyushang96, cosplay_anime, desh_arcade, erofra, fanplusfriend2004, fastoper, fryb569210-4, gabayu_0, grizzly_anime, hugo345, illusion_collectibles, jokusw_93, lasakd-0, marakipae, motion-controls_6, nadpeuatha, nanayakk66, newpepa-6, noosiri_store, noridaifuku88, orangesucculent, osaka_japanbrand25, pologviran-0, powerhook, rca0_50, reliable-japan, rising-again2021, rispat_85, riyanto-tee, saengnusaenfo_0, sodiyathibir0, tamrincollection, thebikerjacket, wangnime, wenjia001, wishow6-8, xipanpan02, yeran4_87, yupei-55 and CANONLINE added to case caption.

NEW PARTIES: CHAUDHARY Store, guangzhoumeigengmaoyiyouxiangongsi, Gur Gur Stickers, JapaneedS, JPN_AKT_store, kuiyoshangmao, kunmingwuhuaquhuinianfanshangmaoyouxiangongsi, louistoy, MRCFTC Store, MUDD DISTRIBUTORS, ONEDOMMESTORE, Seung Chul, SOH DISTRIBUTORS, sonanh2006amztb, SS Printer, TRONYFUN, UDALI, VAstore big, Vaxon, VIVAO JAPAN, weiyuefashangmao, Xing qiao bai jiu shang hang, YtYzhangxianjie, YUANGANG, 91430181MABX67Y725, Big Step Cases, dollhouse-Ling, EARLFAMILY J2, lichangying, Made in China002, Made in China666, NDHJM Case, Prime Picks and tuhairu added to case caption.

STIPULATION of Dismissal JOINT AGREED

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant no. 69 Vaxon Direct

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for default judgment[34]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[34] before Honorable Sara L. Ellis on 7/23/2024 at 09:45 AM.

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

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

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for entry of default and for default judgment [34]. The Court enters default judgment in favor of Plaintiff and against Defendants identified in Amended Schedule A. Order to follow. Hearings set for 7/23/2024 are stricken. Emailed notice

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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 42 tamrincollection

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 36 reliable-japan

DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 11/8/2024. Mailed notice.

Civil Case Terminated.

SATISFACTION of Judgment as to defendant no. 30 noridaifuku88