2024-cv-12589

COMPLAINT filed by BBC Studios Distribution Ltd; Filing fee $ 405, receipt number AILNDC-22812026.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Schedule A regarding complaint[1]

MOTION by Plaintiff BBC Studios Distribution Ltd for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BBC Studios Distribution Ltd

Notice of Claims Involving Trademarks by BBC Studios Distribution Ltd

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Andrew Daniel Burnham

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2).

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 Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED Copyright report to Registrar, Washington DC

MOTION by Plaintiff BBC Studios Distribution Ltd for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

DECLARATION of Diane Hamer regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Exhibit 3 - Parts 1-2 regarding declaration[17]

MOTION by Plaintiff BBC Studios Distribution Ltd for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for leave to file[3], motion for temporary restraining order[14], motion for miscellaneous relief[19] before Honorable Manish S. Shah on 12/17/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [14] [19] are granted. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 12/16/2024. Notices Mailed.

Registry Deposit Information Form by BBC Studios Distribution Ltd

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time of Temporary Restraining Order

MEMORANDUM by BBC Studios Distribution Ltd in support of extension of time[26]

DECLARATION of Andrew D. Burnham regarding memorandum in support of motion[27]

NOTICE of Motion by Andrew Daniel Burnham for presentment of extension of time[26] before Honorable Manish S. Shah on 12/19/2024 at 09:45 AM.

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

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time [26] is granted, and no appearance is necessary. The TRO is extended to 1/13/25. Notices Mailed.

SURETY BOND in the amount of $ 50,000.00 posted by BBC Studios Distribution Ltd. (Document not scanned.)

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 12/20/2024: Mailed notice.

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Madeline Halgren

MOTION by Plaintiff BBC Studios Distribution Ltd for preliminary injunction

(Exhibit A)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for preliminary injunction 34

DECLARATION of Andrew Burnham regarding memorandum in support of motion 35

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for preliminary injunction 34 before Honorable Manish S. Shah on 1/8/2025 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/3/2025, answer due 1/24/2025.

Declaration of Hannah A. Abes

(Exhibit A)

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Thomas Joseph Juettner

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. No defendants appeared. For the reasons stated in open court, plaintiff's motion for preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Manish S. Shah on 1/8/2025. Emailed notice

NEW PARTIES: BLUFOREST INTERNATIONAL LIMITED, Ningbo Colorswoo Art Supply Co., Ltd., Quanzhou City Licheng District Wuxia Clothing Accessories Firm(Individual Business), Quanzhou Lihuatoo Trading Co., Ltd., Shenzhen Yixinwang Gift Co., Ltd., Xiamen Best Technology Co., Ltd., Yiwu Aolan Import And Export Co., Ltd., Yiwu Hua Rui Trade Co., Ltd., Yiwu Jaye Trading Co., Ltd., A99AWD6ICJWU6, ADASJDFVDSGG, Ambishi, Ansuhai, anxixianhutoujincaibaihuodian, chencuiliQZUS, clmy88, Dayanm, dengzhoushixiaoyayashangmaoyouxiangongsi, Excellent life, FYY123, GUOBINGBING, Gzpuzhen, huangzehao121, jymysh, lulurelax, lxinqiUS, Nonudu, Pearfectlity, qwertugxs, ranzhitaoamz, renjianrenai, rhddd, sanmingshisanyuanquzherongshangmaoshanghanggerenduzi, THAIHOANG, Tran Huong Trang, VARIETICO, xianglin8130, xiangyangshimashishuiguohang, XYSGMYXGS, YangZiYiShangMaoShangHang, yichangshichaoxiqinshangmaoyouxiangongsi, ZhuZhouMengZhouShangMaoYouXianZeRenGongSi, ZXYTXC (7-12 Days Fast Delivery), aiyueele10, amazing522, dblt, judony, gemmanor-5, heyan-48, thh063, zhuzhanghustores, BOLANQ, changshashuangjun, cocoa, foshanshixuandefashangmao, GardenGlamour, GuangZhouQingYang, JHOMERIT, julantai99, Keep Elegant, LICHAHG, limizi, liuyanwei, longkoushiruihong, Nana Shop, NUIgan INC, perfect bracelet, ranxuxuri, Susoonfo INC, WONDBA, XIAshuix, Youuic and YSVIGI added to case caption.

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain Defendants

MOTION by Plaintiff BBC Studios Distribution Ltd for entry of default, MOTION by Plaintiff BBC Studios Distribution Ltd for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for entry of default, motion for default judgment 44

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 45

(Exhibit 1)

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for entry of default, motion for default judgment 44 before Honorable Manish S. Shah on 2/4/2025 at 09:45 AM.

(Exhibit A)

MOTION for extension by Defendant XIAshuix for extension of time (Received via pro se email on 2/2/25.)

PRO SE Appearance by Defendant Zhuang Zhaodi (Received via pro se email on 2/2/25.)

MOTION by Defendant Li Shihao for extension of time (Received via pro se email on 2/2/25.)

PRO SE Appearance by Defendant Li Shihao (Received via pro se email on 2/2/25.)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default [44] is granted. Enter Default Judgment Order. Civil case terminated. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 2/4/2025. Notices Mailed.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

MOTION by Defendant Zhuang Zhaodi for reconsideration of default judgment (Received via PDF Submission link on Box.com on 02/05/25)

MOTION by Defendant Li Shihao to reconsider default judgment (Received via PDF Submission link on Box.com on 02/05/25)

MINUTE entry before the Honorable Manish S. Shah: The motions for extensions of time [50] [52] are denied. Entities may not appear in federal court without an attorney; they may not represent themselves through the individual owners of the stores. To participate in this litigation, defendants must have counsel. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: The motions to reconsider 56 57 are denied because the entities are not represented by counsel. Notices Mailed.

FULL SATISFACTION of Judgment regarding order 49 as to certain defendants

ATTORNEY Appearance for Defendants XIAshuix, JHOMERIT, Youuic by Jianyin Liu

MOTION by Defendants XIAshuix, JHOMERIT to vacate order[49] Default Judgment

Plaintiff's Preliminary Response To Defendants' Motion To Vacate Default Judgment [62] by BBC Studios Distribution Ltd

Exhibit A

DECLARATION of Li Shihao regarding motion to vacate[62]

DECLARATION of Zhang Zhaodi regarding motion to vacate[62]

MINUTE entry before the Honorable Manish S. Shah: The motion to vacate default judgment [62] is denied because the motion was not noticed for presentment and hearing on the court's motion call. If defendants seek to renew the motion, the renewed motion should address plaintiff's assertion that its filings, [18-2] at 43, 92, demonstrate that defendants sold products into Illinois. Notices mailed.

MOTION by Defendants JHOMERIT, XIAshuix to vacate order[49]

DECLARATION of Shihao Li regarding motion to vacate 67

DECLARATION of Zhaodi Zhuang regarding motion to vacate 67

NOTICE of Motion by Jianyin Liu for presentment of motion to vacate[67] before Honorable Manish S. Shah on 3/18/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The renewed motion to vacate default judgment [67] is denied and no appearance on 3/18/25 is necessary. Defendants concede that they sold at least one product into Illinois, therefore, this court concludes that it had personal jurisdiction over defendants. Defendants' other arguments to vacate, namely that they were unfamiliar with U.S. law and court procedures and did not willfully infringe, are not adequate justifications to alter or amend the judgment under Fed. R. Civ. P. 59(e). Even if defendants relied on their supplier(s), there is no clear error or manifest injustice in the court relying on plaintiff's submissions to establish the appropriate amount of statutory damages to award, and ignorance of U.S. law does not excuse an entity from complying with the law and court procedures when that entity chooses to do business in the United States. Mailed notice.

FULL SATISFACTION of Judgment regarding order 49 as to certain defendant

FULL SATISFACTION of Judgment regarding order[49] in the amount of $50,000 as to certain defendants