2024-cv-04935

COMPLAINT (Redacted Public Version) filed by Roadget Business Pte. Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-22142326.

Schedule A (Redacted)

(Exhibit 1 (Redacted))

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Roadget Business Pte. Ltd.

ATTORNEY Appearance for Plaintiff Roadget Business Pte. Ltd. by Steven Joseph Horowitz

ATTORNEY Appearance for Plaintiff Roadget Business Pte. Ltd. by Matthew D. Binder

ATTORNEY Appearance for Plaintiff Roadget Business Pte. Ltd. by Deepa Arundati Chari

ATTORNEY Appearance for Plaintiff Roadget Business Pte. Ltd. by Michael Springer-ingram

ATTORNEY Appearance for Plaintiff Roadget Business Pte. Ltd. by Taylor James Wilson

MOTION by Plaintiff Roadget Business Pte. Ltd. to seal (Motion for leave to file under seal its complaint and exhibits to motion for entry of a temporary restraining order)

SEALED DOCUMENT by Plaintiff Roadget Business Pte. Ltd. Under Seal Complaint

Schedule A

(Exhibit 1)

MOTION by Plaintiff Roadget Business Pte. Ltd. for temporary restraining order

(Proposed Temporary Restraining Order (redacted version))

MEMORANDUM by Roadget Business Pte. Ltd. in support of motion for temporary restraining order 11

Declaration of Deepa A. Chari

Exhibit 1

Exhibit 2

Exhibit 3 (redacted)

Exhibit 4 (redacted)

Exhibit 5 (redacted)

(Declaration of Tim Wei)

SEALED EXHIBIT by Plaintiff Roadget Business Pte. Ltd. (Proposed sealed temporary restraining order) regarding MOTION by Plaintiff Roadget Business Pte. Ltd. for temporary restraining order 11

SEALED EXHIBIT by Plaintiff Roadget Business Pte. Ltd. Exhibits 3, 4 and 5 to the declaration of Deepa A. Chari regarding memorandum in support of motion, 12

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 3). (Text entry; no document attached.)

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. (Text entry; no document attached.)

Exhibit 4

(Exhibit 5)

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion to seal 9, motion for temporary restraining order 11 before Honorable Manish S. Shah on 6/20/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 9 11 are granted, and no appearance 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, 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. The court finds that security in the amount of $10,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 6/17/2024. Notices Mailed.

MOTION by Plaintiff Roadget Business Pte. Ltd. To Extend The Temporary Restraining Order

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion for miscellaneous relief 18 before Honorable Manish S. Shah on 6/27/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 18 is granted, and no appearance on the motion is necessary. The TRO is extended to 7/15/24. Mailed notice.

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto (Text entry; no document attached.)

SUMMONS Returned Executed by Roadget Business Pte. Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 6/25/2024, answer due 7/16/2024.

ATTORNEY Appearance for Defendants MOKAJUN, March th, UNYS, Volcano PJ, The One Queen, Happy Sleeping, AINK, TMSYfzc:, Jin Wang, Shenghong Pajama Clothing Store, Yohad by Christopher Paul Keleher

ATTORNEY Appearance for Defendants AINK, Happy Sleeping, Jin Wang, MOKAJUN, March th, Shenghong Pajama Clothing Store, TMSYfzc:, The One Queen, UNYS, Volcano PJ, Yohad by Lan Li

MOTION by Defendants AINK, Happy Sleeping, Jin Wang, MOKAJUN, March th, Shenghong Pajama Clothing Store, TMSYfzc:, The One Queen, UNYS, Volcano PJ, Yohad Modify The Asset Restraint

Exhibit Custodial Declaration (filed under seal)

(Exhibit Store Owner Declarations)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for miscellaneous relief, 24 before Honorable Manish S. Shah on 7/17/2024 at 09:45 AM.

MOTION by Defendants AINK, Happy Sleeping, Jin Wang, MOKAJUN, March th, Shenghong Pajama Clothing Store, TMSYfzc:, The One Queen, UNYS, Volcano PJ, Yohad to seal document (Exhibit A to Motion to Modify Asset Restraint)

SEALED DOCUMENT by Defendants AINK, Happy Sleeping, Jin Wang, MOKAJUN, March th, Shenghong Pajama Clothing Store, TMSYfzc:, The One Queen, UNYS, Volcano PJ, Yohad Exhibit A to Motion to Modify Asset Restraint

MOTION by Plaintiff Roadget Business Pte. Ltd.To Extend The Temporary Restraining Order Through Disposition Of The Preliminary Injunction Motion

MOTION by Plaintiff Roadget Business Pte. Ltd. for preliminary injunction

Memorandum In Support

Declaration of Deepa A. Chari

(Exhibit 1)

MOTION by Plaintiff Roadget Business Pte. Ltd. to seal Supporting Papers To Motion For Entry Of A Preliminary Injunction

SEALED DOCUMENT by Plaintiff Roadget Business Pte. Ltd. - Sealed Declaration Of Deepa A. Chari Support Of Plaintiff's Motion For Preliminary Injunction

(Exhibit 1)

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion for preliminary injunction 29, motion to seal 30, motion for miscellaneous relief 28 before Honorable Manish S. Shah on 7/11/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion to convert the temporary restraining order into a preliminary injunction 28 is granted, pending consideration of the motion for preliminary injunction and assets restraint issue. The Clerk's Office is directed to unseal any previously sealed documents except 27 and 31. 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. Defendants' response to the motion for preliminary injunction 29 is due 7/22/24. Plaintiff's reply is due 7/29/24. Plaintiff's response to the motion to modify the asset restraint 24 is due 7/29/24. Defendants' reply is due 8/5/24. The motions for leave to file exhibits under seal 26 and 30 are granted, subject to the court lifting the seal after it rules on the preliminary injunction and asset restraint. Temu has leave to file a position statement regarding the seal by 8/5/24. No appearance on 7/17/24 is necessary and the hearing is stricken. Notices Mailed.

NEW PARTIES: Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Guangzhoumeiyimeifushi Co., Ltd. d/b/a MYM, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Guangzhouaoxiangfushichang d/b/a AINK, Juntao Bie d/b/a BJL fashion, Shuying Wang d/b/a LESLIEActive, Dongguanshihumenyiyifuzhuangchang d/b/a YIYIfuzhang, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Ming Li d/b/a Vicinity, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Shiling Wang d/b/a jin Wang, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store and Hanchuanshimokajunfushidian d/b/a MOKAJUN added to case caption. Terminating Yohad (Text entry; no document attached.)

ANSWER to Complaint with Jury Demand by Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad

ANSWER to Complaint with Jury Demand by Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ

ANSWER to Complaint with Jury Demand by Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping

ANSWER to Complaint with Jury Demand by Guangzhouaoxiangfushichang d/b/a AINK

ANSWER to Complaint with Jury Demand by Guangzhouyisifushi Co., Ltd. d/b/a UNYS

ANSWER to Complaint with Jury Demand by Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen

ANSWER to Complaint with Jury Demand by Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc

ANSWER to Complaint with Jury Demand by Shiling Wang d/b/a jin Wang

ANSWER to Complaint with Jury Demand by Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th

ANSWER to Complaint with Jury Demand by Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store

ANSWER to Complaint with Jury Demand by Hanchuanshimokajunfushidian d/b/a MOKAJUN

MOTION by Defendants Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhouaoxiangfushichang d/b/a AINK, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Shiling Wang d/b/a jin Wang to dismiss or alternatively, sever

(Exhibit Merchant Declarations)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to dismiss, 45 before Honorable Manish S. Shah on 7/23/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 7/23/24 is necessary. Plaintiff shall respond to the motion to dismiss or sever by 8/5/24 and defendants may reply by 8/19/24. The court will rule by cm/ecf. Notices Mailed.

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad for extension of time to file response/reply as to order on motion to seal document, order on motion for miscellaneous relief, motion hearing, terminate hearings, terminate motions, set deadlines, 33 AGREED

AGREED NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file response/reply, 48 before Honorable Manish S. Shah on 7/31/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 48 is granted, and no appearance on the motion is necessary. Defendants' response to the motion for a preliminary injunction is due 7/29/24 and plaintiff's reply is due 8/5/24. Notices mailed.

RESPONSE by Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohadin Opposition to MOTION by Plaintiff Roadget Business Pte. Ltd. for preliminary injunction 29

Exhibit Merchant Declaration

Exhibit Custodial Declaration (sealed)

(Exhibit Hearing Transcript 23-cv-2286)

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad to seal document response in opposition to motion, 51 UNOPPOSED

SEALED DOCUMENT by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad

UNOPPOSED NOTICE of Motion by Christopher Paul Keleher for presentment of motion to seal document, 52 before Honorable Manish S. Shah on 8/7/2024 at 09:45 AM.

RESPONSE by Roadget Business Pte. Ltd.in Opposition to MOTION by Defendants AINK, Happy Sleeping, Jin Wang, MOKAJUN, March th, Shenghong Pajama Clothing Store, TMSYfzc:, The One Queen, UNYS, Volcano PJ, Yohad Modify The Asset Restraint 24

DECLARATION of Deepa A. Chari regarding response in opposition to motion, 55

Exhibit 1

(Exhibit 2)

MOTION by Plaintiff Roadget Business Pte. Ltd. to seal document

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion to seal document 57 before Honorable Manish S. Shah on 8/7/2024 at 09:45 AM.

SEALED RESPONSE by Roadget Business Pte. Ltd. to MOTION by Defendants AINK, Happy Sleeping, Jin Wang, MOKAJUN, March th, Shenghong Pajama Clothing Store, TMSYfzc:, The One Queen, UNYS, Volcano PJ, Yohad Modify The Asset Restraint 24

SEALED DOCUMENT by Plaintiff Roadget Business Pte. Ltd. Declaration of Deepa A. Chari

(Exhibit 2)

MINUTE entry before the Honorable Manish S. Shah: The motions for leave to file under seal 52 57 are granted. No appearance on 8/7/24 is necessary. Notices Mailed.

MOTION by Plaintiff Roadget Business Pte. Ltd. for extension of time to file response/reply as to motion for preliminary injunction 29

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion for extension of time to file response/reply 62 before Honorable Manish S. Shah on 8/6/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 62 is granted, and no appearance on the motion is necessary. Plaintiff's reply is due 8/19/24. Notices Mailed.

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad for extension of time to file answer regarding complaint 1 AGREED

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad for extension of time to file response/reply as to response in opposition to motion, 55 AGREED

AGREED NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file response/reply, 66 before Honorable Manish S. Shah on 8/8/2024 at 09:45 AM.

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad to amend/correct MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, 65

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to amend/correct, 68 before Honorable Manish S. Shah on 8/8/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motions 66 and 68 are granted. Defendants' filing 65 is stricken and defendants' reply in support of the motion to modify the asset restraint is due 8/12/24. No appearance on the motions is necessary. Notices Mailed.

Notice of Intent To File Amended Complaint by Roadget Business Pte. Ltd.

AMENDED complaint by Roadget Business Pte. Ltd. against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

Schedule A

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff has filed an amended complaint in response to the motion to dismiss. The motion to dismiss 45 is terminated as moot. Defendants shall respond to the amended complaint by 8/27/24. The parties shall file a joint status report proposing a case schedule by 9/6/24. Mailed notice

REPLY by Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad to sealed response, 59

Exhibit product listing

Exhibit product listing

Exhibit product listing

Exhibit product listing

Exhibit tik tok screenshot

Exhibit product listing

Exhibit product listing

Exhibit product listing

Exhibit product listing

Exhibit product listing

(Exhibit product listing)

REPLY by Plaintiff Roadget Business Pte. Ltd. to motion for preliminary injunction 29

Declaration of Deepa A. Chari

Exhibit 1 - Screenshot Comparison

Exhibit 2 - Copyright Certificate and Photos

(Exhibit 3 - Durkin Transcript)

EXECUTIVE COMMITTEE ORDER: GENERAL ORDER 24-0024: IT APPEARING THAT, the civil cases on the attached list have been selected for reassignment to form the initial calendar of the Honorable Georgia N. Alexakis; therefore IT IS HEREBY ORDERED that the attached list of 293 cases be reassigned to the Honorable Georgia N. Alexakis; and IT IS FURTHER ORDERED that all parties affected by this Order must review the Honorable Georgia N. Alexakis' webpage on the Court's website for the purpose of reviewing instructions regarding scheduling and case management procedures; andIT IS FURTHER ORDERED that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new district judge for twelve months from the date of this Order; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Georgia N. Alexakis to the Court's civil case assignment system during the next business day, so that she shall receive a full share of such cases; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Georgia N. Alexakis to the Court's criminal case assignment system twelve (12) months from the date of this order so that Judge Alexakis shall thereafter receive a full share of such cases. Case reassigned to the Honorable Georgia N Alexakis for all further proceedings. Honorable Manish S. Shah no longer assigned to the case. Signed by Honorable Virginia M. Kendall on 8/23/2024.

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shiling Wang d/b/a jin Wang, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad for extension of time to file answer regarding complaint 1 AGREED

NOTICE of Motion by Lan Li for presentment of motion for extension of time to file answer, 77 before Honorable Georgia N Alexakis on 9/3/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis:Defendants' agreed motion for an extension of time to answer the complaint 77 is granted. Defendants' response to Plaintiff's second amended complaint is due by 9/12/24. No appearance is required on the motion.

Notice of Intent to File Second Amended Complaint by Roadget Business Pte. Ltd.

Second AMENDED complaint by Roadget Business Pte. Ltd. against AINK, Dongguanshihumenyiyifuzhuangchang d/b/a YIYIfuzhang, Guangzhouaoxiangfushichang d/b/a AINK, Guangzhoumeiyimeifushi Co., Ltd. d/b/a MYM, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Happy Sleeping, Jin Wang, Juntao Bie d/b/a BJL fashion, MOKAJUN, March th, Ming Li d/b/a Vicinity, Shenghong Pajama Clothing Store, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, Shuying Wang d/b/a LESLIEActive, TMSYfzc:, The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, UNYS, Volcano PJ, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad, The One Queen youth in full bloom

Schedule A

Exhibit 1

(Exhibit 2)

STATUS Report (Joint Initial) by Roadget Business Pte. Ltd.

MOTION by Plaintiff Roadget Business Pte. Ltd. for temporary restraining order for Entry of a Modified Temporary Restraining Order, MOTION by Plaintiff Roadget Business Pte. Ltd. for preliminary injunction

Declaration of Deepa A. Chari

Exhibit 1

Exhibit 2

(Exhibit 3)

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion for temporary restraining order, motion for preliminary injunction, 83 before Honorable Georgia N Alexakis on 9/16/2024 at 09:30 AM.

MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen, Guangzhouyisifushi Co., Ltd. d/b/a UNYS, Hanchuanshimokajunfushidian d/b/a MOKAJUN, Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ, Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping, Shiling Wang d/b/a jin Wang, The One Queen youth in full bloom, Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc, Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad to sever (OPPOSED)

Exhibit Merchant Declarations

(Exhibit Merchant Declarations)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to sever, 85 before Honorable Georgia N Alexakis on 9/17/2024 at 09:30 AM.

ANSWER to amended complaint by Yiwushiranchuangmaoyi Co., Ltd. d/b/a Yohad

ANSWER to amended complaint by Shenzhenshibaoanshunyifushichang(getigongshanghu) d/b/a VolcanoPJ

ANSWER to amended complaint by Shenzhenshiluohuquoushangmeifushishangxing d/b/a Happy sleeping

ANSWER to amended complaint by Guangzhouaoxiangfushichang d/b/a AINK

ANSWER to amended complaint by Guangzhouyisifushi Co., Ltd. d/b/a UNYS

ANSWER to amended complaint by Tianmenshishaoyinfuzhuangchang d/b/a TMsyfzc

ANSWER to amended complaint by Shiling Wang d/b/a jin Wang

ANSWER to amended complaint by Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th

ANSWER to amended complaint by Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store

ANSWER to amended complaint by Hanchuanshimokajunfushidian d/b/a MOKAJUN

ANSWER to amended complaint by Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen

MINUTE entry before the Honorable Georgia N Alexakis: Motion hearing held on 9/16/24. For the reasons stated on the record, Defendant's motion to modify the asset restraint 24 and Plaintiff's motion for preliminary injunction 29 remain under advisement. Defendants' response to Plaintiff's motion for entry of a modified temporary restraining order and motion for preliminary injunction 83 is due on or before 9/26/24, and any reply from plaintiff in support of its motion is due on or before 10/3/24. Plaintiff's response to defendant's motion to dismiss all but the first-named Defendant without prejudice or, alternatively, sever the claims against each Defendant is due on or before 9/26/24, and any reply from defendants in support of their motion is due on or before 10/3/24. In addition, this case is referred to Magistrate Judge Holleb Hotaling for all discovery scheduling and supervision, including the authority to set, adjust, and extend all discovery-related deadlines. The referral also includes the authority to conduct a settlement conference, as necessary. The Court will set a dispositive motion schedule after all discovery is completed. No appearance is required on 9/17/24.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Keri L. Holleb Hotaling for the purpose of holding proceedings related to: Discovery supervision and for settlement conference.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: This matter has been referred to Judge Holleb Hotaling for discovery management and settlement. By 10/10/2024, the parties are to file their initial Rule 26(f) conference report which shall, inter alia, propose a fact discovery schedule and include a statement on whether the parties are interested in a settlement conference at this juncture. Mailed notice.

ATTORNEY Appearance for Defendant The One Queen youth in full bloom by Christopher Paul Keleher

MOTION by Defendant The One Queen youth in full bloom for joinder (AGREED) Presented before District Judge

(Exhibit Platform Declaration)

RESPONSE by Roadget Business Pte. Ltd.in Opposition to MOTION by Defendants Guangzhouaoxiangfushichang d/b/a AINK, Guangzhousanmukuahaifuzhuangmaoyi Co., Ltd. d/b/a March th, Guangzhoushishenghongfuzhuang Co., Ltd. d/b/a Shenghong Pajama Clothing Store, Guangzhoushiyifeimengfushishangxing d/b/a TheOneQueen 85

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants Defendant No. 11's unopposed motion 102 seeking leave to join, on behalf of its youth in full bloom storefront, defendants' pending asset restraint modification motion 24 and defendants' opposition to plaintiff's preliminary injunction 29, and to adopt defendants' briefing therein.

MINUTE entry before the Honorable Georgia N Alexakis: For the reasons set forth in the accompanying order, defendants' motion to modify the asset restraint 24 is entered and continued, and the parties must file a joint status report addressing the Court's directives and questions on or before October 11, 2024.

ORDER Signed by the Honorable Georgia N Alexakis on 10/3/24.

TRANSCRIPT OF PROCEEDINGS held on September 16, 2024 before the Honorable Georgia N Alexakis. Court Reporter Contact Information: Jennifer Costales, CRR, RMR, CRC - jenny.uscra@yahoo.com. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 10/24/2024. Redacted Transcript Deadline set for 11/4/2024. Release of Transcript Restriction set for 1/1/2025.

REPORT of Rule 26(f) Planning Meeting by Roadget Business Pte. Ltd.

MOTION by Attorney Matthew D. Binder to withdraw as attorney for Roadget Business Pte. Ltd. No party information provided Presented before District Judge

NOTICE of Motion by Matthew D. Binder for presentment of before Honorable Georgia N Alexakis on 10/17/2024 at 09:30 AM.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: The Court adopts the parties' proposed firm fact discovery deadline of 2/28/2025. It is not the Court's practice to subdivide discovery and trusts the parties to manage their discovery obligations accordingly to meet their fact discovery deadline. The Court will not set an expert discovery schedule until it is clear the fact discovery deadline will be met. The parties are reminded to promptly bring any discovery motions before the Court, including motions to enforce subpoenas or motions for protective orders. Additionally, in their planning report [Dkt. 108], the parties raise a potential issue with the issuance of interrogatories; to the extent the parties cannot come to an agreement on this issue, the Court will not rule on this issue until a proper motion is in front of it. The parties also report that settlement discussions have been successful and that "Settlement offers have been accepted as to all but one Defendant, and negotiations are underway as to that final Defendant." [Dkt. 108.] The parties are to file an updated joints status report on 12/3/2024.

STATUS Report (Joint Status Report) by Roadget Business Pte. Ltd. Presented before District Judge

MINUTE entry before the Honorable Georgia N Alexakis: Motion to withdraw Matthew D. Binder as attorney 109 is granted. No appearance is required on 10/17/24.

MINUTE entry before the Honorable Georgia N Alexakis: The Court has reviewed the parties joint status report, which reflects that the parties have agreed to reduce the restraint of assets to the revenue from sales of the allegedly infringing goods. In light of that agreement, the Court grants defendants motion to modify the asset restraint 24. The parties are directed to submit a proposed order modifying the asset restraint to this Courts proposed order inbox on or before 10/16/24.

ORDER modifying Temporary Restraining Order Signed by the Honorable Georgia N Alexakis on 10/16/24.

MOTION by Plaintiff Roadget Business Pte. Ltd. for default judgment as to Defendants 3, 6 and 7 Presented before District Judge

Exhibit A

Memorandum In Support

Declaration of Taylor Wilson

Exhibit 1

Exhibit 2

(Exhibit 3)

MOTION by Plaintiff Roadget Business Pte. Ltd. to seal Supporting Papers To Motion For Default Judgment Presented before District Judge

SEALED DOCUMENT by Plaintiff Roadget Business Pte. Ltd. - Sealed Memorandum of Law In Support of Motion For Default Judgment Against Defendants Nos. 3, 6 and 7

Declaration of Taylor Wilson

(Exhibit 3)

MOTION by Plaintiff Roadget Business Pte. Ltd. for default judgment as to Defendant No. 1 (Unopposed) Presented before District Judge

Exhibit A - Proposed Order

Memorandum In Support

Declaration of Taylor Wilson

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

MOTION by Plaintiff Roadget Business Pte. Ltd. to seal Supporting Papers To Unopposed Motion For Default Judgment Presented before District Judge

SEALED DOCUMENT by Plaintiff Roadget Business Pte. Ltd. - Sealed Memorandum Of Law In Support Of Plaintiff's Unopposed Motion For Default Judgment As To Defendant No. 1

Declaration of Taylor Wilson

Exhibit 3

(Exhibit 4)

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion to seal 120, motion to seal 117, motion for default judgment, 116, motion for default judgment, 119 before Honorable Georgia N Alexakis on 12/2/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Motion hearing held on 12/2/24. Counsel for Plaintiff and Defendant No. 1 present. For the reasons stated on the record and reflected in Plaintiff's motion and accompanying memorandum, plaintiff's motion for entry of default and default judgment against Defendants Nos. 3, 6, and 7 [116] is granted. Enter order. For the reasons stated on the record and reflected in Plaintiff's motion and accompanying memorandum, Plaintiff's unopposed motion for entry of default and default judgment against Defendant No. 1 [116] is granted. Enter order. Plaintiff's motion to seal [117] and [120] are granted. In light of the settlement agreements that Plaintiff has reached with the remaining defendants in this matter [116-1], plaintiff's opposed motion for a preliminary injunction [29], plaintiff's motion for entry of a modified temporary restraining order [83], and defendants' motion to sever [85] are denied as moot without prejudice to renewal. Plaintiff's notice of voluntary dismissal for the remaining defendants is due by 1/2/25.

DEFAULT JUDGMENT ORDER Signed by the Honorable Georgia N Alexakis on 12/2/24.

DEFAULT JUDGMENT ORDER Signed by the Honorable Georgia N Alexakis on 12/2/24.

MINUTE entry before the Honorable Georgia N Alexakis: Pursuant to the notice of voluntary dismissal, Defendant No. 9 UNYS is dismissed with prejudice. The Parties shall bear their own attorneys' fees and costs.

MOTION by Plaintiff Roadget Business Pte. Ltd. for judgment (entry of final judgment), MOTION by Plaintiff Roadget Business Pte. Ltd. for bond (release of bond)

(Exhibit 1 - proposed final judgment and order)

NOTICE of Motion by Steven Joseph Horowitz for presentment of motion for judgment, motion for bond, 144 before Honorable Georgia N Alexakis on 12/12/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis:Plaintiff's motion for entry of final judgment and release of bond [144]is granted. Enter order. The cash bond in the amount of $10,000 will be released to Roadget's counsel of record, Michael C. Springer-Ingram of Sidley Austin LLP. Civil case terminated.

FINAL JUDGMENT AND ORDER Signed by the Honorable Georgia N Alexakis on 12/9/24.

AMENDED FINAL JUDGMENT ORDER Signed by the Honorable Georgia N Alexakis on 12/10/24.