2024-cv-10355

COMPLAINT filed by Harlem Globetrotters International, Inc.; Filing fee $ 405, receipt number AILNDC-22604575.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Harlem Globetrotters International, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harlem Globetrotters International, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harlem Globetrotters International, Inc.

Notice of Claims Involving Trademarks by Harlem Globetrotters International, Inc.

ATTORNEY Appearance for Plaintiff Harlem Globetrotters International, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harlem Globetrotters International, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harlem Globetrotters International, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Harlem Globetrotters International, Inc. by Quinn Bradley Guillermo

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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 John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2).

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

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

MEMORANDUM by Harlem Globetrotters International, 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 Steve Earnest regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiff Harlem Globetrotters International, Inc. Exhibit 2 regarding declaration[16]

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

MEMORANDUM by Harlem Globetrotters International, 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

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file documents under seal [3] is granted. As such, plaintiff's sealed Schedule A [2], provisionally under seal pending order, is permitted to remain under seal, and Exhibit 2 to the Declaration of Steve Earnest may be filed under seal. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for a temporary restraining order [13] is taken under advisement. By 10/25/2024, the plaintiff is required to supplement its motion with: (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case, (3) a certification that the plaintiff has not used any of the screenshot evidence supplied in support or its motion in any prior proceeding, and (4) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. The plaintiff's motion for electronic service of process [18] is granted. Mailed notice

SUPPLEMENT to motion for temporary restraining order[13] pursuant to [22]

SEALED EXHIBIT by Plaintiff Harlem Globetrotters International, Inc. Exhibit 1 regarding supplement[23]

MINUTE entry before the Honorable John J. Tharp, Jr:Upon receipt of the plaintiff's supplement to its motion for a temporary restraining order [23], and on the grounds set forth in the motion, plaintiff's ex parte motion for TRO [13] is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 10/24/2024. Mailed notice

Registry Deposit Information Form by Harlem Globetrotters International, Inc.

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

SURETY BOND in the amount of $ 56,000 posted by Harlem Globetrotters International, Inc. (Document not scanned).

ATTORNEY Appearance for Plaintiff Harlem Globetrotters International, Inc. by Andrew Daniel Burnham

MOTION by Plaintiff Harlem Globetrotters International, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Harlem Globetrotters International, Inc. in support of motion for preliminary injunction[30]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Harlem Globetrotters International, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/31/2024, answer due 11/21/2024.

Declaration of Andrew D. Burnham

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 30 is taken under advisement. Any objection or response is due before 11/6/24. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement, by 11/4/2024, the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before November 6, 2024. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

CERTIFICATE of Service by Plaintiff Harlem Globetrotters International, Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 33

Exhibit A

(Exhibit B)

ATTORNEY Appearance for Plaintiff Harlem Globetrotters International, Inc. by Jennifer Van Nacht

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [30] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 11/12/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 11/7/2024. Mailed notice

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MOTION by Plaintiff Harlem Globetrotters International, Inc. for entry of default, MOTION by Plaintiff Harlem Globetrotters International, Inc. for default judgment as to all Defendants with the exception of a certain Defendant

Exhibit A

MEMORANDUM by Harlem Globetrotters International, Inc. in support of motion for entry of default, motion for default judgment, [38]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[39]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of default and default judgment against certain defendants [38] is taken under advisement. Any objections or responses are due by 12/11/2024. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 12/3/2024. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Harlem Globetrotters International, Inc. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 41

Exhibit A

(Exhibit B)

NOTICE of Voluntary Dismissal by Harlem Globetrotters International, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 43, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 5 is dismissed from this case Mailed notice

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 John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 38 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 3/3/2025. Mailed notice

NOTICE of withdrawal of bond 28 by John Summerfield