2024-cv-08669

COMPLAINT filed by Tee Turtle, LLC.; Filing fee $ 405, receipt number AILNDC-22500930.

Exhibit 1 - Copyrights

Exhibit 2 - Trademarks

(Schedule A Slip Sheet)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Tee Turtle, LLC. by Samantha Diane Parrish

SEALED DOCUMENT by Plaintiff Tee Turtle, LLC. - Schedule A to Complaint

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tee Turtle, LLC.

CLAIM - AO 120 Form (Trademarks) by Tee Turtle, LLC.

CLAIM - AO 121 Form (Copyright) by Tee Turtle, LLC.

(Exhibit A)

MEMORANDUM in Support of Plaintiff's Ex Parte Motion for Entry of a TRO

MOTION by Plaintiff Tee Turtle, LLC. for leave to file excess pages

(Exhibit A)

DECLARATION of Samantha Parrish in Support of Plaintiff's Ex Parte Application for Entry of a Temporary Restraining Order

Exhibit 1 - Jan 2011 MarkMonitor

Exhibit 2 - IP Rights Seizure Statistics

Exhibit 3 - BASCAP Report

Exhibit 4 - 2013 Registrar Agreement

Exhibit 5 - Hague Convention of Service Abroad

(Exhibit 6 - Translation of Civil Procedure Law of the People of China)

DECLARATION of Lisa Gajjar in Support of Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

Exhibit 1 - Copyrights

(Exhibit 2 - Trademarks)

SEALED DOCUMENT by Plaintiff Tee Turtle, LLC. - Exhibit 3 - (Part 1 of 32)

Exhibit 3 - (Part 2 of 32)

Exhibit 3 - (Part 3 of 32)

Exhibit 3 - (Part 4 of 32)

Exhibit 3 - (Part 5 of 32)

Exhibit 3 - (Part 6 of 32)

Exhibit 3 - (Part 7 of 32)

Exhibit 3 - (Part 8 of 32)

Exhibit 3 - (Part 9 of 32)

Exhibit 3 - (Part 10 of 32)

Exhibit 3 - (Part 11 of 32)

Exhibit 3 - (Part 12 of 32)

Exhibit 3 - (Part 13 of 32)

Exhibit 3 - (Part 14 of 32)

Exhibit 3 - (Part 15 of 32)

Exhibit 3 - (Part 16 of 32)

Exhibit 3 - (Part 17 of 32)

Exhibit 3 - (Part 18 of 32)

Exhibit 3 - (Part 19 of 32)

Exhibit 3 - (Part 20 of 32)

Exhibit 3 - (Part 21 of 32)

Exhibit 3 - (Part 22 of 32)

Exhibit 3 - (Part 23 of 32)

Exhibit 3 - (Part 24 of 32)

Exhibit 3 - (Part 25 of 32)

Exhibit 3 - (Part 26 of 32)

Exhibit 3 - (Part 27 of 32)

Exhibit 3 - (Part 28 of 32)

Exhibit 3 - (Part 29 of 32)

Exhibit 3 - (Part 30 of 32)

Exhibit 3 - (Part 31 of 32)

(Exhibit 3 - (Part 32 of 32))

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 3).

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.

MAILED copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Manish S. Shah: The motions to file under seal and for excess pages 8 and 11 are granted. The motion for an ex parte TRO 9 is taken under advisement. Plaintiff must submit a proposed order in Microsoft Word format to proposed_order_shah@ilnd.uscourts.gov. The court advises counsel that, in the future, all motions must be noticed for in-person presentment on Judge Shah's motion call, and the court will advise counsel by docket entry in advance of the hearing (usually by 4:00 p.m. the day before the hearing) if an in-person appearance will be required. In this case, plaintiff's filing includes over 5000 pages of exhibits, and the court can give plaintiff no prediction as to when the court will rule on its motion. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion for a TRO, Expedited Discovery, and Service by Alternative Means 9 is granted in part. The court declines to enter an asset restraint or domain name transfer. An accounting can be accomplished through discovery of sales information, and the harm to defendants from an asset restraint and domain name transfer and the corresponding effect on defendants' ability to sell noninfringing products outweighs the harm to plaintiff. Injunctive relief is not an aid to collection of damages. The court has doubts about joinder and personal jurisdiction, but will await adversarial presentation before resolving those issues. The court also has doubts about whether using a trademark in search engine optimization techniques is infringing. See 1-800 Contacts, Inc. v. JAND, Inc., No. 22-1634, 2024 WL 4439136 (2d Cir. Oct. 8, 2024). But for now, the court is satisfied that plaintiff has some likelihood of success on the merits of some of plaintiff's theories, and the loss of control over its intellectual property is an irreparable harm. The court notes that if not all defendants are infringing all of plaintiff's asserted works and marks, plaintiff's request is overbroad and risks damages to some defendants in the form of unnecessary expenditure of time and resources. Damages would be recoverable from a wrongful injunction. Security in the amount of $147,000 is necessary to secure the injunction against 147 defendants. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 11/6/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by Tee Turtle, LLC.

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.

MINUTE entry before the Honorable Manish S. Shah: Pursuant to the notice of voluntary dismissal, this case is dismissed without prejudice. Terminate civil case.