2024-cv-09296

COMPLAINT filed by Bug Art Limited; Filing fee $ 405, receipt number AILNDC-22549448.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Bug Art Limited Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bug Art Limited by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Bug Art Limited by Adam Grodman

ATTORNEY Appearance for Plaintiff Bug Art Limited by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Bug Art Limited by Christopher Romero

ATTORNEY Appearance for Plaintiff Bug Art Limited by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Bug Art Limited by Yanling Jiang

ATTORNEY Appearance for Plaintiff Bug Art Limited by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bug Art Limited

CASE ASSIGNED to the Honorable Georgia N Alexakis. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

CASE ASSIGNED to the Honorable Georgia N Alexakis. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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 Georgia N Alexakis: Upon review of the complaint, the Court sua sponte raises the propriety of joining 128 defendants 2 in a single action involving 39 copyright registrations 1. See, e.g., Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). By 11/15/24, plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder. Plaintiff may also want to reference this Court's order in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28, where the Court expressed its joinder-related concerns in cases of this size and type. In the alternative, plaintiff has leave to file an amended complaint by 11/15/24 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Estee Lauder, 334 F.R.D. at 189.

AMENDED complaint by Bug Art Limited against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

(Exhibit 2)

SEALED DOCUMENT by Plaintiff Bug Art Limited [Amended] Schedule A to Complaint 1 ; Schedule A 2 ; and Amended Complaint 14

MEMORANDUM by Bug Art Limited Establishing that Joinder is Proper

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

MEMORANDUM in Support of 17 Exparte Motion

Exhibit 1

Declaration of Keith A. Vogt

(Exhibit 1-2, of Keith A. Vogt's Declaration)

Presentment for Exparte Motion 17 NOTICE of Motion by Keith A. Vogt for presentment of before Honorable Georgia N Alexakis on 11/21/2024 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Motion for leave to conduct expedited discovery and electronic service of process 17 is granted. No appearance is required on 11/21/24.

ORDER for leave to conduct expedited discovery and service of process by e-mail and/or electronic publication. Signed by the Honorable Georgia N Alexakis on 11/20/24.

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

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff is directed to submit a status report regarding this matter on or before 12/30/24.

SUMMONS Returned Executed by Bug Art Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/23/2024, answer due 1/13/2025.

(Declaration of Service)

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 Bug Art Limited for default judgment as to the Defendants Identified in the [Amended] Schedule A

MEMORANDUM by Bug Art Limited in support of motion for default judgment[25]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[25] before Honorable Georgia N Alexakis on 1/28/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Before the Court is Plaintiff's motion for entry of default and default judgment 25 against the remaining defendants identified in the Amended Schedule A 15. The remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default against the defendants identified on the Amended Schedule A is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment by the defaulted Defendants must be filed on or before 1/24/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon the remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service.

CERTIFICATE of Service by Plaintiff Bug Art Limited regarding text entry, 28

MINUTE entry before the Honorable Georgia N Alexakis: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 25 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's intellectual property irreparably harms Plaintiff and confuses the public. Because this infringement was willful and considering the value of Plaintiff's brand as well as the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $5,000 is an appropriate award of statutory damages against each remaining defendant. Enter Final Judgment Order. Civil case terminated.

DEFAULT Final Judgment Order Signed by the Honorable Georgia N Alexakis on 1/27/25.