2024-cv-05692

COMPLAINT filed by Manchester United Football Club Limited; Filing fee $ 405, receipt number AILNDC-22215103.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff Manchester United Football Club Limited Schedule A regarding complaint 1 Modified on 8/28/2024.

MOTION by Plaintiff Manchester United Football Club Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Manchester United Football Club Limited

Notice of Claims Involving Trademarks by Manchester United Football Club Limited

ATTORNEY Appearance for Plaintiff Manchester United Football Club Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Manchester United Football Club Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Manchester United Football Club Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff Manchester United Football Club Limited by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 2). (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.)

MOTION by Plaintiff Manchester United Football Club Limited for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Defendant Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Manchester United Football Club Limited in support of motion for temporary restraining order, 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Laura Harrington regarding memorandum in support of motion 12

Exhibit 1

(Exhibit 2)

EXHIBIT by Plaintiff Manchester United Football Club Limited Exhibit 3 - Parts 1 - 2 regarding declaration 14 Modified on 8/28/2024.

Exhibit 3-1

(Exhibit 3-2)

MOTION by Plaintiff Manchester United Football Club Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Manchester United Football Club Limited in support of motion for miscellaneous relief 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order, 11, motion for miscellaneous relief 16, motion for leave to file 3 before Honorable Manish S. Shah on 7/18/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 3 11 16 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 $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed.

TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 7/16/2024. Notices Mailed. Modified on 8/28/2024.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

Registry Deposit Information Form by Manchester United Football Club Limited

CIVIL BOND in the amount of $ 50,000 posted by Manchester United Football Club Limited. (Document not Imaged)_.

MOTION by Plaintiff Manchester United Football Club Limited for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Manchester United Football Club Limited in support of motion for preliminary injunction 24

Declaration of Justin T. Joseph

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 24 before Honorable Manish S. Shah on 7/30/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Manchester United Football Club Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/25/2024, answer due 8/15/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 24 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 7/30/2024. Notices Mailed.

ATTORNEY Appearance for Plaintiff Manchester United Football Club Limited by Trevor Christian Talhami

ATTORNEY Appearance for Defendant Shandong Longxiang Textile Co., Ltd. by Christopher Paul Keleher

MOTION by Plaintiff Manchester United Football Club Limited for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Manchester United Football Club Limited in support of motion for preliminary injunction 32

Declaration of Trevor C. Talhami

(Exhibit 1)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 32 before Honorable Manish S. Shah on 8/14/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Manchester United Football Club Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/8/2024, answer due 8/29/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: No appearance on 8/14/24 is necessary. Any objections to the motion for a preliminary injunction must be properly filed by 8/13/24. If no objections are filed, the motion will be considered unopposed and the court will rule by cm/ecf. Notices Mailed.

ATTORNEY Appearance for Defendant Guangzhou DOY Label Co., Ltd. by Christopher Paul Keleher

ATTORNEY Appearance for Defendant Zhuji Dule Textile Co., Ltd. by Christopher Paul Keleher

MOTION by Defendant Shandong Longxiang Textile Co., Ltd. for extension of time to file answer regarding complaint 1 AGREED

(AGREED) NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 39 before Honorable Manish S. Shah on 8/15/2024 at 09:45 AM.

ATTORNEY Appearance for Defendants Guangzhou DOY Label Co., Ltd., Shandong Longxiang Textile Co., Ltd., Zhuji Dule Textile Co., Ltd. by Lan Li

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 39 is granted, and no appearance is necessary. Defendant Shandong Longxiang Textile Co. has until 9/3/24 to respond to the complaint. Notices Mailed.

MOTION by Defendant Guangzhou DOY Label Co., Ltd. for extension of time to file answer regarding complaint 1 (AGREED)

(AGREED) NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 43 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

MOTION by Defendant Shandong Longxiang Textile Co., Ltd. Modify Asset Restraint (OPPOSED)

(Exhibit Declaration of Jean Geng)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for miscellaneous relief 45 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

MOTION by Defendant Zhuji Dule Textile Co., Ltd. Modify Asset Restraint (OPPOSED)

(Exhibit Declaration of Fang Xia)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for miscellaneous relief 47 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 43 is granted. Defendant Guangzhou DOY Label Co. has until 9/3/24 to respond to the complaint. Plaintiff shall respond to the motions to modify the asset restraint 45 47 by 8/21/24. No reply is permitted unless requested by the court. The court will rule by cm/ecf. No appearance on 8/28/24 is necessary. Notices Mailed.

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited as to certain defendants

MINUTE entry before the Honorable Manish S. Shah: Although the court has under advisement motions to lift the asset restraint as to two defendants, based on the absence of any other timely filed objection to the motion for a preliminary injunction and the court's review of the materials submitted in support of the motion and the TRO, the motion 32 is granted. Enter Preliminary Injunction. The court will revisit the asset restraint upon reviewing plaintiff's response briefs due 8/21/24. Plaintiff is further reminded that if the court determines that the asset restraint was wrongful, plaintiff should be liable to defendants for the damages caused by the wrongful restraint. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 8/15/2024. Notices Mailed.

MOTION by Plaintiff Manchester United Football Club Limited to compel OPPOSED, MOTION by Plaintiff Manchester United Football Club Limited to stay regarding order on motion for extension of time to answer, terminate hearings, terminate motions, 49

DECLARATION of Trevor C. Talhami regarding motion to compel, motion to stay, 53

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion to compel, motion to stay, 53 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

RESPONSE by Manchester United Football Club Limitedin Opposition to MOTION by Defendant Shandong Longxiang Textile Co., Ltd. Modify Asset Restraint (OPPOSED) 45, MOTION by Defendant Zhuji Dule Textile Co., Ltd. Modify Asset Restraint (OPPOSED) 47

Declaration of Trevor C. Talhami

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

(Exhibit 7)

MOTION by Defendant Guangzhou DOY Label Co., Ltd. To Modify Asset Restraint (OPPOSED)

(Exhibit Declaration of Principal)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for miscellaneous relief 57 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

MOTION by Plaintiff Manchester United Football Club Limited to compel OPPOSED

Declaration of Trevor C. Talhami

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion to compel 59 before Honorable Manish S. Shah on 9/3/2024 at 09:45 AM.

TRANSCRIPT OF PROCEEDINGS held on 08/28/2024, Motion Hearing, before the Honorable Manish S. Shah. Order Number: 49648. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. 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 9/18/2024. Redacted Transcript Deadline set for 9/30/2024. Release of Transcript Restriction set for 11/26/2024.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motions to compel 53 59 are denied without prejudice. Defendants' motions to modify the asset restraint 45 47 57 are granted. The asset restraint is vacated as to defendants Shandong Longxiang Textile Co., Ltd., Zhuji Dule Textile Co., Ltd., and Guangzhou DOY Label Co., Ltd. No appearance on 9/3/24 is necessary. Notices Mailed.

NEW PARTIES: Dongguan Hon Keung Haberdashery Ltd., Guangzhou Yifan Technology Co., Ltd., Jurong Ruixin Hat And Garments Co., Ltd., Kunshan Frank Gifts Co., Ltd., Shenzhen Bridgetoworld Technology Co., Ltd., Shenzhen Gelibo Technology Co., Ltd., Shenzhen XinYuanRui Opto-Electronic Technology Co.Ltd, Shenzhen Zhonglian Wong Industrial Co., Ltd., Shishi City Guanglian Accessories Factory, Wenzhou Longgao Arts & Crafts Co., Ltd., Wuhan QB Workshop Technology Co., Ltd., Xiamen Huoma Technology Co., Ltd., Yangxi Tianshun Caps & Hats Co.,Ltd., Yiwu Fangtuo Jewelry Factory, Yiwu Honggu Clothing Co., Ltd., Yiwu Lanshuo Trade Co., Ltd., Yiwu Linuo E-Commercial Firm, Yiwu Manyi Electronic Commerce Co., Ltd., Yiwu Xiche E-Commerce Firm, Zhongshan Tlon Gifts & Crafts Co., Ltd., Zhuji Hewei Socks Co., Ltd., Zhuji Junkai Knitting Co., Ltd, A2XAJSGROEBCWK, A31H4R51MCJ0AC, ang zhou yun qun shang mao you xian gong si, art poster Yhongbo, baodaoposter, CHENXUEE POSTER, dahai1212, DIEHARDDIECAST2020, DuKaLuFaJiuWangLuoKeJi, GUANG LLZ, GXFC988, Hexinxinc, huanghuip, jiahu1212, jinghuang0, junpingposter, LICAIFA, lvxuyyse, mengzhaomeng, MinMin ART Shop, Newbegins, philosophy xxs, putianchengxiangxuanwanshengmaoyiyouxiangongsi, putianlichenghuichenyunmaoyiyouxiangongsi, QIMING NGAOTECH STORE, qingyong666, SHANGXINH, VA StoreXO, wulinglong, xianyoujinglixuanmaoyiyouxiangongsi, xqddd, Yongji Peiqi Information Technology Co., Ltd., zhijiangshishuimubaihuodian, zhiweiposter, zhujiaqi2024, lightinthebox-0301, yuz0-73, 3262song, aa416614, chen19970707, china_jersey_supplier1, footballandvintagejerseys, jersey.jersey.54540, jersey_supplier10, may17620040580, ou_wenjie, senjersey66, wxiusen, youtubefamilyworld, feooe puzzle, MG Wall Decor Art, BestieGifts, GOFANSTORE, Guoqu Store and buyfootballjersey.com added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Manchester United Football Club Limited for entry of default, MOTION by Plaintiff Manchester United Football Club Limited for default judgment as to all Defendants with the Exception of Certain Defendants

(Exhibit A)

MEMORANDUM by Manchester United Football Club Limited in support of motion for entry of default, motion for default judgment, 63

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 64

(Exhibit 1)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, 63 before Honorable Manish S. Shah on 9/10/2024 at 09:45 AM.

(Exhibit A)

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited as to certain defendants

MINUTE entry before the Honorable Manish S. Shah: Hearing on the motion for entry of default judgment 63 is reset to 9/11/24 at 9:45 a.m. Notices Mailed.

MOTION by Defendants Guangzhou DOY Label Co., Ltd., Shandong Longxiang Textile Co., Ltd., Zhuji Dule Textile Co., Ltd.for extension of time to file answer regarding complaint

(UNKNOWN IF OPPOSED) NOTICE of Motion by Lan Li for presentment of motion for miscellaneous relief 69 before Honorable Manish S. Shah on 9/18/2024 at 09:45 AM.

ATTORNEY Appearance for Defendants Wenzhou Longgao Arts & Crafts Co., Ltd., Yiwu Linuo E-Commercial Firm, Zhuji Hewei Socks Co., Ltd., Zhuji Junkai Knitting Co., Ltd by Adam Edward Urbanczyk

MOTION by Defendants Wenzhou Longgao Arts & Crafts Co., Ltd., Yiwu Linuo E-Commercial Firm, Zhuji Hewei Socks Co., Ltd., Zhuji Junkai Knitting Co., Ltd for extension of time

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time 72 before Honorable Manish S. Shah on 9/11/2024 at 09:45 AM.

ATTORNEY Appearance for Defendants Wenzhou Longgao Arts & Crafts Co., Ltd., Yiwu Linuo E-Commercial Firm, Zhuji Hewei Socks Co., Ltd., Zhuji Junkai Knitting Co., Ltd by Brian Swift

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motions for extension of time to respond to the complaint 69, 72 are granted. Defendants Guangzhou DOY Label Co., Ltd., Shandong Longxiang Textile Co., Ltd., Zhuji Dule Textile Co., Ltd., Wenzhou Longgao Arts & Crafts Co., Ltd., Yiwu Linuo E-Commercial Firm, Zhuji Hewei Socks Co., Ltd., and Zhuji Junkai Knitting Co., Ltd. must respond to the complaint by 9/30/24. No appearance on 9/18/24 is necessary. Plaintiff's motion for entry of default judgment as to the non-appearing defendants 63 is granted. Enter Default Judgment Order. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 9/11/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited as to certain defendants

MOTION by Defendant Zhuji Dule Textile Co., Ltd. to dismiss for lack of jurisdiction (OPPOSED)

Exhibit Merchant Declaration

Exhibit Sales Chart

(Exhibit Custodial Declaration)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to dismiss/lack of jurisdiction 78 before Honorable Manish S. Shah on 10/9/2024 at 09:45 AM.

MOTION by Defendant Shandong Longxiang Textile Co., Ltd. to dismiss for lack of jurisdiction (OPPOSED)

Exhibit Merchant Declaration

Exhibit Sales Chart

(Exhibit Custodial Declaration)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to dismiss/lack of jurisdiction, 80 before Honorable Manish S. Shah on 10/9/2024 at 09:45 AM.

MOTION by Defendant Guangzhou DOY Label Co., Ltd. to dismiss for lack of jurisdiction (OPPOSED)

Exhibit Merchant Declaration

Exhibit Sales Chart part 1

Exhibit Sales Chart part 2

Exhibit Sales Chart part 3

Exhibit Sales Chart part 4

(Exhibit Custodial Declaration)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to dismiss/lack of jurisdiction, 82 before Honorable Manish S. Shah on 10/9/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 10/9/24 is necessary. Plaintiff shall respond to the motions to dismiss by 10/16/24 and defendants may reply by 10/23/24. The court will rule by cm/ecf. Notices Mailed.

ATTORNEY Appearance for Plaintiff Manchester United Football Club Limited by Berel Yonathan Lakovitsky

MOTION by Plaintiff Manchester United Football Club Limited to Conduct Jurisdictional Discovery for Defendants' Motions to Dismiss [78, 80, 82] and to Stay or Extend the Briefing Schedule 84 Opposed

DECLARATION of Trevor C. Talhami regarding motion for miscellaneous relief 86

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for miscellaneous relief 86 before Honorable Manish S. Shah on 10/8/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 10/8/24 is necessary. Plaintiff's motion includes some argument suggesting that plaintiff already has enough information to support its prima facie case for personal jurisdiction, without additional discovery. The court will take the motion under advisement, but does not stay the briefing schedule on defendants' motion to dismiss. Plaintiff's response remains due 10/16/24, and defendant's reply, which may include any argument in opposition to jurisdictional discovery, remains due 10/23/24. Notices Mailed.

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited as to certain defendant

RESPONSE by Manchester United Football Club Limitedin Opposition to MOTION by Defendant Guangzhou DOY Label Co., Ltd. to dismiss for lack of jurisdiction (OPPOSED) 82, MOTION by Defendant Zhuji Dule Textile Co., Ltd. to dismiss for lack of jurisdiction (OPPOSED) 78, MOTION by Defendant Shandong Longxiang Textile Co., Ltd. to dismiss for lack of jurisdiction (OPPOSED) 80

DECLARATION of Lijia Chen regarding response in opposition to motion, 91

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

(Exhibit 6)

DECLARATION of Jennifer V. Nacht regarding response in opposition to motion, 91

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

Exhibit 9

Exhibit 10

(Exhibit 11)

REPLY by Guangzhou DOY Label Co., Ltd., Zhuji Dule Textile Co., Ltd., Shandong Longxiang Textile Co., Ltd. to response in opposition to motion, 91

(Exhibit Appellate Brief NBA case)

SATISFACTION of Judgment regarding order 76 in the amount of $50,000 as to certain defendant

NOTICE of Removal of Material from the Custody of the Clerk's Office by Manchester United Football Club Limited (Received at the Intake Counter on 11/22/24.)

Notice of Recent Related Decision by Manchester United Football Club Limited

Exhibit 1

MEMORANDUM Opinion and Order. Signed by the Honorable Manish S. Shah on 12/23/2024: Defendants' motions to dismiss for lack of jurisdiction, [78], [80], [82], are denied. Because there was no need to conduct jurisdictional discovery to find jurisdiction proper, Manchester United's motion for jurisdictional discovery, [86], is denied as moot. [For further detail see attached order.] Notices Mailed.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MOTION by Plaintiff Manchester United Football Club Limited for entry of default as to all Remaining Defendants, MOTION by Plaintiff Manchester United Football Club Limited for default judgment as to all Remaining Defendants

Exhibit A

MEMORANDUM by Manchester United Football Club Limited in support of motion for entry of default, motion for default judgment, [100]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[101]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, [100] before Honorable Manish S. Shah on 1/30/2025 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated on the record, the motion for entry of default judgment [100] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Manish S. Shah on 1/30/2025. Mailed notice

EMAILED Trademark report with certified copy of minute order dated 1/30/25 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 105 in the amount of $50,000 as to certain defendant