2024-cv-09708

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-22575967.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin Tyler Joseph

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable M. David Weisman. 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.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Adam Sapper regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 3 - Parts 1-2 regarding declaration 16

Exhibit 3-1

(Exhibit 3-2)

MOTION by Plaintiff Mattel, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 13, motion for leave to file 3, motion for miscellaneous relief 18 before Honorable Jorge L. Alonso on 10/17/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 3 13 18 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 $111,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 10/17/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 10/16/2024. Notice mailed by Judge's staff

Registry Deposit Information Form by Mattel, Inc.

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

ATTORNEY Appearance for Defendant CAR PASS by Erin Kathryn Russell

SURETY BOND in the amount of $ 111,000.00 posted by Mattel, Inc.

MOTION by Plaintiff Mattel, Inc. for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction 27

Declaration of Rachel S. Miller

(Exhibit 1)

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction 27 before Honorable Jorge L. Alonso on 10/30/2024 at 09:30 AM.

(Exhibit A)

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/25/2024, answer due 11/15/2024.

Declaration of Rachel S. Miller

(Exhibit A)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/30/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of preliminary injunction as to certain Defendants 27 is granted. Enter Preliminary Injunction Order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Telephonic status hearing set for 12/17/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 10/30/2024. Notice mailed by Judge's staff

ATTORNEY Appearance for Defendant ASTER Direct Store by Timothy Alan Duffy

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ASTER Direct Store

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

NEW PARTIES: Guangxi Nanning Mancai Trading Co.,ltd, Ningbo Haizilun Fashion Co., Ltd., Xiamen Huanqiu Aerospace Technology Co., Ltd., Yiwu Qingli Garment Co., Ltd., Zhongshan Aote Electronic Commerce Co., Ltd., Zunyi Red Fire Stationery Co., Ltd., A1YZH5JK788XJR, A3P939SP67VKNS, akarca2000, ANJA02TX66KJR, Anroop, aoqime, ASTER Direct Store, BEIBEILE TOYS, Bettina Toys, Bugrelsla, CAR PASS, Catalpa animation costumes, CHENZHUOSHANGMAO, Child's Growth Companion, Coldfire US, ESZLT-US, FENGRUIL, FuChen, GuangZhouBaiLeYinShuaBaoZhuangYouXianGongSi, guangzhouguansheshangmaoyouxiangongsi, guzhikeji-EU, Hitatol Toys, JIAJUNNA, Leo Yao Poster, LEQIANG, liuzhenmin, longersun, Longfun, Manuebed, MANYMANY, meiyanrong, pindienice, Quetaa, Ranhao Shop, RANLUP, richardshop, Shannon Wenha, Sheockiry, supmond21, SuxingToys, tainengO6JKVJAW24, TIMEWHEEL, Tospania Inc., TRAN HANG SHOP 1, TUKK, TUTUDEPOT, Uukaayoupin Direct, WOODMAM direct, wuajia, WUTOK7, xiaoqiaoshangmao-us, xiaoxiaodongman, XiongXiongLe, YKST6688A, Yushida Toys, Zixiang, ZJUNJIE, Backdrop996-Factory, BlueWhale-Store, demetrice37, enhulles, enjoylifeyeah, HEALER WORLD, hudashen, jinanyuezhuoelectro-0, lyfe7939, PLANWALK, RibowCorp, shuozhoushipingluquche, taianshunyi-1, victorycarpartseller, Anpro US, EWXY, foshanshicouxiyingshangmao, HuaFQ, jinwenliumaoyiyouxiangongsi, JSHIGUANG, Langzhongshangmaoltd, LinKero, Love Phone Phone, LUYE TOYS, Mini Tudou, R Choi's, tianyuezhaomingkeji, Toys for Childhood, Uncle Sam's Grocery Store, WangShuang12, WowSmile TOYS, xiangyangshifuniushangmao, xiaohua----shop, xingmingcanhushangmao, XinZeXing, yaosun, YTDSCS Co.Ltd, Ywlanda, zhengxuanxiaoshangmao, zhiyimoushangmao and zhouyuchao3946 added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant WOODMAM direct by Yong Chen

ATTORNEY Appearance for Defendant XinZeXing by Jianyin Liu

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ANSWER to Complaint with Jury Demand with Affirmative Defenses by XinZeXing

MOTION by Defendant WOODMAM direct for extension of time to file answer regarding complaint 1, CONSENTED

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. for Entry of an Agreed Asset Restraint Order as to Defendant No. 18 (Joint)

Exhibit A

NOTICE of Motion by Rachel S Miller for presentment of motion for miscellaneous relief[44] before Honorable Jorge L. Alonso on 11/27/2024 at 09:30 AM.

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: The parties' Joint motion for entry of an agreed asset restraint order as to Defendant No. 18 [44] is granted. Enter Agreed Asset Restraint Order as to Defendant No. 18. Motion hearing date of 11/27/24 is stricken. Notice mailed by Judge's staff

AGREED Asset Restraint Order As To Defendant No. 18. Signed by the Honorable Jorge L. Alonso on 11/25/2024. Notice mailed by Judge's staff

MOTION by Defendant Longfun for extension of time to file answer

ATTORNEY Appearance for Defendant Longfun by Longhao Wang

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

MINUTE entry before the Honorable Jorge L. Alonso: The call in number for the status hearing set for 12/17/24 at 9:30 a.m. has changed. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 1/9/25 at 9:30 a.m. Defendant WOODMAM direct's Motion for extension of time [42] and Defendant Longfun's Motion for extension of time [48] are granted to 12/31/24. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

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.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: In recognition of the National Day of Mourning for President James Earl Carter, Jr., the United States District Court for the Northern District of Illinois will be closed on 1/9/25. Therefore, the status hearing set for that date is stricken and reset to 1/30/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 2/27/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/31/2025, answer due 2/21/2025.

Declaration of Hannah A. Abes

Exhibit A

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment[66]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[67]

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment[66] before Honorable Jorge L. Alonso on 3/6/2025 at 09:30 AM.

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing previously set for 2/27/25 is stricken and reset to 3/6/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants [66] is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 3/6/2025. Notice mailed by Judge's staff

MAILED trademark report with certified copy of minute order dated 3/6/2025 to Patent Trademark Office, Alexandria VA. (jn,)