2024-cv-07113

COMPLAINT filed by AJM Packaging Corp; Filing fee $ 405, receipt number AILNDC-22353394.

Supplement Schedule A (filed under seal)

Exhibit Exhibit 1

Exhibit Exhibit 2

Exhibit Exhibit 3 (filed under seal)

Exhibit Exhibit 4

Exhibit Exhibit 5

Exhibit Exhibit 6 (filed under seal)

(Exhibit Exhibit 7)

SEALED MOTION by Plaintiff AJM Packaging Corp

Supplement Schedule A

Exhibit Exhibit 3 to Complaint

(Exhibit Exhibit 6 to Complaint)

MEMORANDUM by AJM Packaging Corp in support of Sealed motion 2

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by AJM Packaging Corp Corporate Disclosure Statement

CIVIL Cover Sheet

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-22357873.

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-22357899.

MINUTE entry before the Honorable Steven C. Seeger: The motions for leave to appear pro hac vice (Dckt. Nos. [10] and [11]) are hereby granted. Attorney Mark A. Cantor and Muhammad A. Siwani are added as counsel for AJM Packaging Corp. Mailed notice.

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-22360375.

MINUTE entry before the Honorable Steven C. Seeger: The motion for leave to appear pro hac vice (Dckt. No. 13) are hereby granted. Attorney Rebecca J. Cantor are added as counsel for AJM Packaging Corp. Mailed notice.

MOTION by Plaintiff AJM Packaging Corp for leave to file excess pages to it's Motion for entry of a Temporary Restraining Order, a Preliminary Injunction, a Temporary Asset Restraint and Expedited Discovery

MOTION by Plaintiff AJM Packaging Corp for temporary restraining order and a Preliminary Injunction, a Temporary Asset Restraint and Expedited Discovery (Ex Parte)

MEMORANDUM by AJM Packaging Corp in support of motion for temporary restraining order 16, motion for leave to file excess pages 15

DECLARATION of Mark A. Cantor regarding memorandum in support of motion 17, motion for temporary restraining order 16

Exhibit 1 - Amazon Brand Registry_ Help Protect Your Brand on Amazon

Exhibit 2 - Amazon Brand Registry_ Eligibility, Enrollment, and Access

Exhibit 3 - brandservices.amazon.com_transparency

Exhibit 4 - TM App 98239035

Exhibit 5 - Report - IP Property Rights Seizure Statistics 2023

Exhibit 6 - Report - Measuring the Magnitude of Global Counterfeiting

(Exhibit 7 - Report - The Economic Impacts of Counterfeiting and Piracy)

SEALED MOTION by Plaintiff AJM Packaging Corp regarding declaration of Robert Epstein

(Declaration Robert Epstein)

NOTICE of Motion by Mark A. Cantor for presentment of Sealed motion 19, motion for temporary restraining order 16 before Honorable Steven C. Seeger on 10/2/2024 at 09:30 AM.

MOTION by Plaintiff AJM Packaging CorpElectronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by AJM Packaging Corp in support of motion for miscellaneous relief 21

DECLARATION of Mark A. Cantor regarding memorandum in support of motion 22, motion for miscellaneous relief 21

(Exhibit 1 - Hague Convention on Service Abroad)

MINUTE entry before the Honorable Steven C. Seeger: The motion hearing set for October 2, 2024 at 9:30 a.m. is stricken. The motions are taken under advisement. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: The motion to seal (Dckt. No. 2) is hereby denied for the reasons stated by the Court in Zorro Productions, Inc. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (23-cv-5761). Mailed notice.

Schedule A to Complaint by AJM Packaging Corp

MINUTE entry before the Honorable Steven C. Seeger: At plaintiff's request, the deadline to file a joint initial status report is extended to January 10, 2024. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for a temporary restraining order (Dckt. No. 16) is hereby granted in part. Temporary Restraining Order to follow. Plaintiff's motion for electronic service of process (Dckt. No. 21) is hereby granted. Mailed notice.

TEMPORARY Restraining Order Signed by the Honorable Steven C. Seeger on 12/3/2024. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file excess pages (Dckt. No. 15) is hereby denied as moot. Mailed notice.

REGISTRY Deposit Information Form by AJM Packaging Corp

INJUNCTION BOND in the amount of $ 3000 (3 checks) posted by AJM Packaging Corp Receipt numbers: 10001402, 10001403, 10001404

SUMMONS Issued as to Defendant The Partnership and Foreign Corporation Identified on Schedule A

SUMMONS Returned Executed by AJM Packaging Corp as to The Partnership and Foreign Corporation Identified on Schedule A on 12/16/2024, answer due 1/6/2025.

MOTION by Plaintiff AJM Packaging Corp for temporary restraining order to Extend the Temporary Retraining Order

MEMORANDUM by AJM Packaging Corp in support of motion for temporary restraining order 33

DECLARATION of Muhammad A. Siwani regarding memorandum in support of motion 34, motion for temporary restraining order 33

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 AJM Packaging Corp for preliminary injunction

MEMORANDUM by AJM Packaging Corp in support of motion for preliminary injunction 37

DECLARATION of Muhammad A. Siwani regarding memorandum in support of motion 38, motion for preliminary injunction 37

ATTORNEY Appearance for Defendant The Partnership and Foreign Corporation Identified on Schedule A by James B. Zaczek

ATTORNEY Appearance for Defendant The Partnership and Foreign Corporation Identified on Schedule A by Anthony Michael Verna, NextG

STATUS Report JOINT by AJM Packaging Corp

ANSWER to Complaint by The Partnership and Foreign Corporation Identified on Schedule A

MOTION by Plaintiff AJM Packaging Corp for Entry of Stipulated Preliminary Injunction

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. 19) is hereby denied for the reasons stated by the Court in Zorro Productions, Inc. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (23-cv-5761). Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion to extend the TRO (Dckt. No. 33) is hereby denied as moot. Plaintiff's motion for entry of a stipulated preliminary injunction (Dckt. No. 44) is hereby granted in large part. Preliminary Injunction Order to follow. Mailed notice.

STIPULATED PRELIMINARY INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 4/7/2025. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for a preliminary injunction (Dckt. No. 37) is hereby denied as moot. Mailed notice

MINUTE entry before the Honorable Steven C. Seeger: The original joint initial status report was due on January 10, 2025. At that time, Defendant had not yet answered, and so Plaintiff filed an initial status report without Defendant. Defendant answered on January 21, 2025. Since then, the parties have entered into a stipulated preliminary injunction. The Court directs the parties to make every reasonable effort to settle the case. The Court directs the parties to have meaningful, good faith settlement discussions, and file a status report within one week of entry of this order. The parties must file a joint initial status report by that date, too. A failure to comply will lead to appropriate relief, including possible dismissal or the entry of judgment. Plaintiff must serve a copy of this order on Defendant and file a certificate of service. Mailed notice

CERTIFICATE of Service by Plaintiff AJM Packaging Corp regarding text entry, 49 Minute Entry

STATUS Report Joint Initial Status Report Under Rule 26(f) by AJM Packaging Corp

STATUS Report Joint Settlement Status Report by AJM Packaging Corp

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the joint settlement status report. (Dckt. No. 52) The parties have had productive settlement discussions. The parties proposed a fact discovery deadline of October 1, 2025. That's far too long. Fact discovery will close on July 15, 2025. The parties must file a status report on settlement by May 26, 2025. The Court directs the parties to engage in good faith, energetic settlement discussions in the meantime. Plaintiff must press the case forward in a diligent manner, with a sense of purpose. Mailed notice

STATUS Report (Joint) by AJM Packaging Corp

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the status report about settlement discussions. (Dckt. No. 54) The parties have engaged in meaningful settlement discussions, and "remain optimistic." But they need to exchange "additional information" before they could get to the next stage. The Court directs the parties to exchange any information reasonably necessary to facilitate productive settlement discussions by June 11, 2025. The parties must provide that information on an expedited basis. The parties must engage in immediate settlement talks, and must file a status report about their (presumably substantial) progress by June 16, 2025. If the parties have not settled by that point, then the parties can expect to come to the courthouse for a settlement conference in the days that follow, with mandatory attendance by the clients. This Court would not allow telephonic participation. In the meantime, the Court directs the parties to keep talking settlement. Mailed notice

MOTION by Plaintiff AJM Packaging Corp to amend/correct Joint Motion to Amend the Case Caption

MOTION by Plaintiff AJM Packaging Corp for permanent injunction

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for a permanent injunction (Dckt. No. [64]) is hereby granted as described in the Order to follow. Plaintiff's motion suggests that the parties will file a joint stipulation of dismissal without prejudice, so that the Court retains jurisdiction to enforce the permanent injunction. They're not mutually exclusive. That is, this Court could dismiss the claims with prejudice, and retain jurisdiction over a permanent injunction. A permanent injunction is permanent, and its enforceability does not turn on whether claims are dismissed with or without prejudice. If anything, it would be unusual to dismiss claims without prejudice and enter a permanent injunction. That said, the parties are free to negotiate the terms of a dismissal. Mailed notice

ORDER Signed by the Honorable Steven C. Seeger on 10/6/2025. Mailed notice.

MOTION by Plaintiff AJM Packaging Corp to dismiss Joint Motion for Entry of Order of Dismissal