2025-cv-00121

COMPLAINT filed by Warner Bros. Entertainment Inc.; Filing fee $ 405, receipt number AILNDC-22915276.

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff Warner Bros. Entertainment Inc. Exhibit 1 regarding complaint 1

Exhibit 1, Part 1

Exhibit 1, Part 2

Exhibit 1, Part 3

Exhibit 1, Part 4

Exhibit 1, Part 5

Exhibit 1, Part 6

Exhibit 1, Part 7

(Exhibit 1, Part 8)

SEALED EXHIBIT by Plaintiff Warner Bros. Entertainment Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Warner Bros. Entertainment Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Warner Bros. Entertainment Inc.

Notice of Claims Involving Trademarks by Warner Bros. Entertainment Inc.

ATTORNEY Appearance for Plaintiff Warner Bros. Entertainment Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Warner Bros. Entertainment Inc. by Sydney Paige Fenton

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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

MINUTE entry before the Honorable Thomas M. Durkin: Motion by Plaintiff Warner Bros. Entertainment Inc. for Leave to File Certain Documents Under Seal 4 is granted. Mailed notice. (jn,)

MOTION by Plaintiff Warner Bros. Entertainment Inc. for Entry of a Temporary Restraining Order Including a Temporary Injunction, and a Temporary Assest Restraint, as to Certain Defendants

MEMORANDUM by Warner Bros. Entertainment Inc. in support of motion for miscellaneous relief 12

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Paul Varley regarding memorandum in support of motion 13

EXHIBIT by Plaintiff Warner Bros. Entertainment Inc. Exhibit 1, Parts 1-8 regarding declaration 14

Exhibit 1, Part 1

Exhibit 1, Part 2

Exhibit 1, Part 3

Exhibit 1, Part 4

Exhibit 1, Part 5

Exhibit 1, Part 6

Exhibit 1, Part 7

(Exhibit 1, Part 8)

SEALED EXHIBIT by Plaintiff Warner Bros. Entertainment Inc. Exhibit 2, Parts 1-3 regarding declaration 14

Exhibit 2, Part 1

Exhibit 2, Part 2

(Exhibit 2, Part 3)

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold and shipped at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

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

MEMORANDUM by Warner Bros. Entertainment Inc. in support of motion for miscellaneous relief 18

Declaration of Martin F. Trainor

(Exhibit 1)

MOTION by Plaintiff Warner Bros. Entertainment Inc. for Expedited Discovery

(Exhibit 1)

DECLARATION of Martin F. Trainor regarding text entry, 17

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte telephone conference held on 2/5/2025. Ex parte motion for entry of a temporary restraining order including a temporary injunction, and a temporary asset restraint, as to certain defendants 12 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 is granted. Motion for expedited discovery 20 is granted. Mailed notice.

ORDER. Signed by the Honorable Thomas M. Durkin on 2/5/2025. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 2/5/2025. Mailed notice.

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

SURETY BOND in the amount of $ 48,000.00 posted by Warner Bros. Entertainment Inc.

MOTION by Plaintiff Warner Bros. Entertainment Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Warner Bros. Entertainment Inc. in support of motion for miscellaneous relief 26

(Declaration of Martin F. Trainor)

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the temporary restraining order 26 is granted. The Temporary Restraining Order entered on 2/5/2025 is extended by a period of fourteen (14) days until 3/5/2025. Mailed notice.

MOTION by Plaintiff Warner Bros. Entertainment Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Warner Bros. Entertainment Inc. in support of motion for miscellaneous relief 30

Declaration of Martin F. Trainor

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiffs' second motion to extend the temporary restraining order 30 is denied because Federal Rule of Civil Procedure 65 permits only one extension of a temporary restraining order. See H-D Michigan, LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 844 (7th Cir. 2012). If the temporary restraining order entered in this case expires before the Court enters a preliminary injunction, Plaintiffs are ordered to inform all the third parties informed of the temporary restraining order that it is no longer in effect. Mailed notice.

SUMMONS Returned Executed by Warner Bros. Entertainment Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 3/4/2025, answer due 3/25/2025.

Declaration of Alexander Whang

(Exhibit A)

MOTION by Plaintiff Warner Bros. Entertainment Inc. for preliminary injunction

Exhibit A

(Exhibit 1)

MEMORANDUM by Warner Bros. Entertainment Inc. in support of motion for preliminary injunction 34

Declaration of Martin F. Trainor

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction 34 before Honorable Thomas M. Durkin on 3/5/2025 at 09:30 AM.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 3/5/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Paul Varley 16, and the Temporary Restraining Order 24. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 4/8/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 3/5/2025. Mailed notice.

NEW PARTIES: IARTTOP, ABLKMpin044111ABLhao, Ai Le, AnDaGou, Anicon, ANYSHOEII, artbaby, Atesswy, AUII JO DESIGN, Aulaygo, AURORAPARTY Express Joy LLC, Ava Custom Store, Basicon-US, Bcjing, Be finer, Bergerio, Bestfull, BigEvents20, Bluecurry-Trade, bobysaili, BowenShopGift, BSTGIFT, Buffaloo, Calimento, Cande Home Store, candykisscase, CayyonStore, Chanding, ChenKajol, chenyikaidexiaodian, chenzimingdexiaodian, CHIJIANGLUYE, ChongYangXianKongYiBaiHuoDian, Cokonabo, Collection-Toy, Compr, CozyCloth, Craftstring, D4DREAM, dadalydecor, Daihongguang, DATOUKAIFEI, Davrock, Dazzling Costumes, DCLINA, dengqiaomei, DesiMao, dijunshop, DINGMAOKEJI, dingranmg, DoMiDola, DONGshi, DWYUFOKC, EIFFTER, Fangtex, Fanquexy Store, FanSH, FENAone, Fevedeco Shop, FLOYU, foshanshihanzhehengfumaoyiyouxiangongsi, Free Kingdom Discount Store, ganlongxuan, GemZono, GLYia, guangzhoujunjishangmaoyouxiangongsi, GuoyuanUS, GZLSXCL, HautHome, HEFEI FANGTANXIU SHANGMAO YOUXIANGONGSI, Helewilk, Heuhuww, hezongjuntwerjsdf, HLNIUC, HOIYLDS Store, Home-Gift, Hong Fu Da Ke Ji, hubeishenglanzhouwangluokejiyouxiangongsi, Hui Ying Ltd, HYHUA, iftnotea, iWishta, jepuyaya, JewelryWe, JIEXINA Zhang, Jinbao Lining, JiuJiangShiZhenBoMaoYiYouXianGongSi1, JOO-Feng, July 19 night, Kawacute, KELESILIANG, KMALeng, kunmingdizuowangluokejiyouxiangongsi, kunmingjiangyunshangmaoyouxiangongsi, KWISTQ, L.Parkin, L9x0u5n9U3L7y7u5eP, Landico, Lanpanzi Technology, lffdys, licson, LIDAzone, Lilbok Trading, LIVE,Inc., lixinxianouyunwangluokejiyouxiangongsii, LUHONGSEN, lxiuadpu, LYUMIE, MagicEB, Melix HOME, MINAZIS Official, Moon Suki, MR.LAMP, Mshaiying, MT Printers, Mutochy, New Happy Element, NsParty Supplies US, OFRKE, OuShi Ltd, Outtymate, Painting Direct, Party Super, Partyreal, pingdinhuajieshangmao, putianshihanjiangquwuhaoqinmaoyiyouxiangongsi, QINGTAI01, qingyuanmeizi, QIYUE Store, R2m4o7U49M0c2i1Y, Rainbow Baby Costumes, Razpah, Salmon Baby Clothing Store, sanyashibachengmaoyiyouxiangongsi, Sanyushine.high, Sheho Online, shenzhenshihongyuekejiyouxiangongsi, Skirfy Toy, Smileeeb, Something Blue & Something Green, songge232321, spring kang, Suwang-Direct, Sweetiyou, SWEETTALA Party Decors, The ostrich store, Tiwabb Store, TOMATO FANQIE US, tongwenshangmao, Tothink, TTXXLL, Tule Durimu, TUYUU, US BAIKE, US-JJW, Uywgaun, W JJJIEUN, W-Sehi Shop, WADOLLE, waiyqju, wangchuanxu147, WanLaiTe, WeChip Official Shop, Wenhandianzi, Wenzhou Hanyan e-commerce Co., Ltd., wenzhouzhifuzhoumaoyiyouxiangongsi, Winnsty, Wish-Card, Wonderful Party LLC, xiangyangshikazaizaishangmaoyouxiangongsi, XIKAINUO, Xin Zhi Suo Yuan, XXQSHOP, yangyangdeshangmaodian, YANGyYang, YEZZZZ, YHgift, YINBANGKE, YiRAN US, yiwushilouyimaoyiyouxiangongsi, yiwushiyigangmaoyiyouxiangongsi, YOKIOU, Yongchun Qiaofeng Trading Co., LTD, YOUHUBUY, YSMY-US, YSUNETER ARTS, yuehuashangmaodian, zhanghongqinyingzenan, zhenbangbang, zhenyifushi, zhijiangshisehengshangmaoyouxiangongsi, ZHOUCHANGJUN, zlhcgd, ZUOKA, Zwin-us, A1PSKYZKB5T1F2, A1YW948BBFE14G, A39HY9POJLC7C5 and A3NPYW48ODS0DY added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 4/8/2025. A telephone status hearing is set for 6/3/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to a certain defendant

ATTORNEY Appearance for Defendants Home-Gift, Party Super, yiwushilouyimaoyiyouxiangongsi, yiwushiyigangmaoyiyouxiangongsi by Timothy Tiewei Wang

(Exhibit A)

MOTION by Defendants Home-Gift, Party Super, yiwushilouyimaoyiyouxiangongsi, yiwushiyigangmaoyiyouxiangongsi for extension of time to file answer regarding complaint 1 Unopposed

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time to answer 50 is granted. Defendants yiwushilouyimaoyiyouxiangongsi, yiwushiyigangmaoyiyouxiangongsi, Home-Gift, and Party Super are to answer or otherwise respond to the complaint by 6/11/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to a certain defendant

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 6/3/2025. A telephone status hearing is set for 7/3/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

ATTORNEY Appearance for Plaintiff Warner Bros. Entertainment Inc. by Alexander Whang

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to a certain defendant

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 7/3/2025. Counsel was present on behalf of Defendant No. 34. The deadline for Defendant No. 34 to respond to the complaint is extended to 8/4/2025. A telephone status hearing is set for 8/4/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 8/4/2025 is reset for 8/5/2025 at 9:15 a.m. Mailed notice.

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to a certain defendant

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 8/5/2025. A telephone status hearing is set for 9/12/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/12/2025 is reset for 9/16/2025 at 9:00 a.m. Mailed notice.

NOTICE of Voluntary Dismissal by Warner Bros. Entertainment Inc. as to certain Defendants

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/16/2025 at 9:00 a.m. is reset for 9:15 a.m. Time change only. Mailed notice.

MOTION by Plaintiff Warner Bros. Entertainment Inc. for entry of default, MOTION by Plaintiff Warner Bros. Entertainment Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Warner Bros. Entertainment Inc. in support of motion for entry of default, motion for default judgment[64]

Exhibit 1

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[65]

Exhibit 1

EXHIBIT by Plaintiff Warner Bros. Entertainment Inc. Exhibit 2, Parts 1-12 regarding declaration[66]

Exhibit 2, Part 1

Exhibit 2, Part 2

Exhibit 2, Part 3

Exhibit 2, Part 4

Exhibit 2, Part 5

Exhibit 2, Part 6

Exhibit 2, Part 7

Exhibit 2, Part 8

Exhibit 2, Part 9

Exhibit 2, Part 10

Exhibit 2, Part 11

Exhibit 2, Part 12

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/16/2025 at 9:15 a.m. is converted to a telephone hearing on the motion for entry of default and default judgment [64]. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 9/16/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and default judgment [64] is granted. Plaintiff's counsel is to submit an updated proposed order with the requested modification. The forty-eight thousand dollars ($48,000) surety bond posted by WBEI is hereby released to WBEI or its counsel, TME Law P.C. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to WBEI or its counsel. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 9/16/2025. Mailed notice.

EMAILED Trademark report with certified copy of minute order dated 9/16/25 to Patent Trademark Office, Alexandria VA

MAILED original Forty-Eight Thousand ($48,000) dollars surety bond posted by Warner Bros. Entertainment Inc. to Attorney, Martin Francis Trainor TME Law, P.C. 10 S. Riverside Plaza, Suite 875 Chicago, IL 60606 certified mail 9589 0710 5270 0579 7833 56 (Text entry; no document attached.)