2025-cv-01066

COMPLAINT filed by Anagram International, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23028483.

Exhibit 1

Exhibit 2 Part 1

Exhibit 2 Part 2

Exhibit 2 Part 3

(Exhibit 2 Part 4)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Anagram International, LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Anagram International, LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Anagram International, LLC by John Wilson

MOTION by Plaintiff Anagram International, LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Anagram International, LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Anagram International, LLC

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.)

MOTION by Plaintiff Anagram International, LLC for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Anagram International, LLC for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Anagram International, LLC in support of motion for temporary restraining order, 11

Declaration Wiles Declaration

Exhibit 1

Exhibit 2 Part 1

Exhibit 2 Part 2

Exhibit Exhibit 2 Part 3

Exhibit Exhibit 2 Part 4

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 1 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 2 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 3 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 4 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 5 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 6 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 7 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 8 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 9 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 10 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 11 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 12 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 13 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 14 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 15 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 16 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 17 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 18 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 19 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 20 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 21 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 22 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 23 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 24 of Wiles Declaration

SEALED DOCUMENT by Plaintiff Anagram International, LLC Exhibit 3 Part 25 of Wiles Declaration

Notice of Claims Involving Trademarks by Anagram International, LLC

MAILED trademark report to Patent Trademark Office, Alexandria VA.

Part 1

Part 2

Part 3

Part 4

(Part 5)

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

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file under seal 7 and motion to file excess pages 10 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order (etc.) 11 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Preliminary injunction hearing is set for 2/18/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 2/12/2025. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. In addition if plaintiff waits until too close to the preliminary injunction hearing to serve defendants with summons the Court may deny entry of a preliminary injunction due to inadequate notice of the lawsuit. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 2/4/2025.

SURETY BOND in the amount of $ 10,000.00 posted by Anagram International, LLC. (Document not imaged)

MOTION by Plaintiff Anagram International, LLC for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of of TRO 44 is granted; the temporary restraining order entered by the COurt on 2/4/2025 is extended through 3/4/2025. The telephonic preliminary injunction hearing set for 2/18/2025 is vacated and reset to 3/4/2025 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction must be filed by 2/28/2025. Plaintiff is again reminded that if it waits until too close to the preliminary injunction hearing to serve defendants with summons the Court may deny entry of a preliminary injunction due to inadequate notice of the lawsuit.

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Plaintiff Anagram International, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Anagram International, LLC in support of motion for preliminary injunction 48

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 48

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

SUMMONS Returned Executed by Anagram International, LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 2/25/2025, answer due 3/18/2025.

ATTORNEY Appearance for Defendant Crosize Official (Shenzhen Xinyou Chengxi Technology Co., Ltd.) by Daniel I. Konieczny

ATTORNEY Appearance for Defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, The Danes, Tick, TOPBATHY, Ulthilift, Yanxinjia, ZHAOYIQ by Adam Edward Urbanczyk

RESPONSE by Crosize Official (Shenzhen Xinyou Chengxi Technology Co., Ltd.)in Opposition to MOTION by Plaintiff Anagram International, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction 48

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

DECLARATION of Li regarding response in opposition to motion, 55

RESPONSE by Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQin Opposition to MOTION by Plaintiff Anagram International, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction 48

Exhibit 1

Exhibit 2

Exhibit 3

Declaration of Peimin Huang

(Declaration of Yanmei Tang)

MOTION by Defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ for leave to file excess pages re: [Dkt. 57]

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic preliminary injunction hearing held on 3/4/2025. Counsel for defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ did not appear for the hearing. Defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ for leave to file in excess pages 58 is granted. Plaintiff is given until 3/14/2025 to file a reply in support of the motion for preliminary injunction as to defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ. The previously entered Temporary Restraining Order as to defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ is extended to 3/20/2025. The case is set for a telephonic status hearing on 3/20/2025 at 9:15 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. The plaintiff's motion for preliminary injunction as to defendant Crosize Official 48 is denied for the reasons stated on the record. The plaintiff's motion for preliminary injunction 48 is granted as to all other defendants. Plaintiff's counsel is directed to send a revised preliminary injunction order that carves out defendants Crosize Official, Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, and ZHAOYIQ. The draft order needs to be sent to Judge Kennelly's proposed order email address in Word format. 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 AS TO CERTAIN DEFENDANTS, signed by the Honorable Matthew F. Kennelly on 3/4/2025.

MOTION by Defendant Crosize Official (Shenzhen Xinyou Chengxi Technology Co., Ltd.) for Direction Following Expiration of TRO

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Matthew F. Kennelly: Defendant Crosize Official's motion for direction 61 is granted. Plaintiff's counsel is ordered to promptly communicate to Amazon regarding the expiration of the TRO and its asset restraints as to Crosize and is to promptly confirm with Crosize's counsel and to the Court that counsel has done do.

ATTORNEY Appearance for Defendant Canrevel Infinite by Jianyin Liu

ATTORNEY Appearance for Defendants ChimiSawo, ScienYv by Christopher Paul Keleher

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Canrevel Infinite

MOTION by Defendants ChimiSawo, ScienYv for extension of time to file answer regarding complaint, 1 (UNKNOWN IF OPPOSED)

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendants Chimi Sawo and ScienYv for extension of time 66 is granted; response to complaint is to be filed by 4/4/2025. Motion to dismiss filed by defendant Canrevel Infinite 65 will be discussed at the telephonic hearing previously set for 3/20/2025 at 9:15 AM, using call-in number 650-479-3207, access code 2305-915-8729.

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ANSWER to Complaint by Crosize Official (Shenzhen Xinyou Chengxi Technology Co., Ltd.)

MOTION by Defendants GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, Ulthilift, Yanxinjia, ZHAOYIQ for extension of time UNOPPOSED

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by GANSWAN and 10 other defendants for extension of time 70 is granted; response to complaint is to be filed by 4/18/2025.

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status and motion hearings held on 3/20/2025. The preliminary injunction order is denied as to defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ. The claims against defendants Everlasting Light, GANSWAN, INSTAKA, Liliping, MLINS, PeggyDoll, Sexagesimo, Shannoy, TOPBATHY, The Danes, Tick, Ulthilift, Yanxinjia, ZHAOYIQ are dismissed for lack of personal jurisdiction. The plaintiff's response to defendant Canrevel Infinite's motion to dismiss 65 is due 4/17/2025; defendant's reply is due 5/1/2025. The case is set for a telephonic status and motion hearing on Canrevel Infinite's motion to dismiss 65 on 5/9/2025 at 8:50 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. 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 Defendant Lamjam Store by Hua Chen

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Defendant Lamjam Store for extension of time to file answer regarding complaint, 1 UNOPPOSED

MOTION by Defendants ChimiSawo, ScienYv To Modify Asset Restraint

Exhibit Store Manager Declaration

Exhibit Store Manager Declaration

Exhibit Amazon Payments Dashboard

(Exhibit Amazon Payments Dashboard)

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendant Lamjan Store for extension of time 76 is granted; response to complaint is to be filed by 4/28/2025. Response to motion by defendants ChimiSawo and ScienYv to modify asset restraint is to be filed by 4/14/2025; reply to response is to be filed by 4/21/2025. Telephonic hearing is set for 4/25/2025 at 8:55 AM, using call-in number 650-479-3207, access code 2305-915-8729.

CERTIFICATE of Service by William Benjamin Kalbac on behalf of Anagram International, LLC

MOTION by Plaintiff Anagram International, LLC for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Anagram International, LLC for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

(Exhibit A)

MEMORANDUM by Anagram International, LLC in support of motion for default judgment, 82

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 82

(Exhibit Hierl Exhibit 1)

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ANSWER to Complaint by ChimiSawo, ScienYv

FINAL DEFAULT JUDGMENT ORDER AS TO CERTAIN DEFENDANTS, signed by the Honorable Matthew F. Kennelly on 4/5/2025: Plaintiff's motion for entry of default judgment as to certain defendants 82 is granted.

RESPONSE by Plaintiff Anagram International, LLC Plaintiff's Response to the Motion to Modify the Asset Restraint of Defendant Nos. 12 "CHIMISAWO" and 49 "SCIENYV" [Dkt. No. 77]

Exhibit A

Exhibit B

(Exhibit C)

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 11

SATISFACTION of Judgment

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 11 "Canrevel Inifinite"

REPLY by Defendants ChimiSawo, ScienYv to Response, 88 (In Support of Motion to Modify Asset Restraint)

SATISFACTION of Judgment

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic motion hearing held on 4/25/2025. Defendants' ChimiSawo and ScienYv's motion to modify the asset restraint 77 is granted. The asset restraint is reduced to $18,519 for ChimiSawo and $68,014 for ScienYv. The parties are directed to send a proposed order regarding the assent restraint to Judge Kennelly's proposed order email address. The case remains set for a telephonic status hearing on 5/9/2025 72. Mailed notice.

REVISED ASSET RESTRAINT ORDER (as to defendants "Chimi Sawo" and "ScienYv" signed by the Honorable Matthew F. Kennelly on 4/27/2025.

MOTION by Defendant Lamjam Store for extension of time to file answer regarding complaint, 1 UNOPPOSED

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file excess pages 81 is granted. Defendant Lamjam Stores' motion for extension of time 96 is granted; response to complaint is to be filed by 5/12/2025.

MINUTE entry before the Honorable Matthew F. Kennelly: The motion to dismiss by defendant Canrevel Infinite 65 is denied as moot due to the dismissal of plaintiff's claims against that defendant. The case remains set for a telephonic status hearing on 5/9/2025 as previously ordered for the purpose of setting a discovery and pretrial schedule with regard to the remaining parties. Counsel are to confer in advance of the hearing and are to be prepared to propose a schedule to the Court.

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 5/9/2025. Rule 26(a)(1) disclosures are to be made by 5/30/2025. Written discovery requests are to be served by 6/20/2025. The parties are to confer on a discovery and pretrial schedule that goes all the way through filing dispositive motions. A joint status report with the proposed schedule is to be filed by 6/6/2025. The deadline for defendant Lamjam Store to respond to the complaint is extended to 6/12/2025. The case is set for a telephonic status hearing on 6/13/2025 at 8:55 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. 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.

SATISFACTION of Judgment

SATISFACTION of Judgment

STIPULATION of Dismissal Stipulation of Voluntary Dismissal with Prejudice

NOTICE of Voluntary Dismissal by Anagram International, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 1

MOTION by Plaintiff Anagram International, LLC for extension of time Plaintiff's Motion for a First Extension of Time to File a Joint Status Report [Dkt. No. 99]

STATUS Report Joint Status Report by Anagram International, LLC

MINUTE entry before the Honorable Matthew F. Kennelly: Motion to file late status report 104 is granted. Based on the status report, the Court sets the following schedule with regard to the claims involving the 2 remaining defendants, Chimi Sawo and ScienYv. Rule 26(a)(1) disclosures are to be made by 6/27/2025. Written discovery requests are to be served by all parties by 7/25/2025. The deadline for amending the pleadings and adding parties is 8/15/2025. Fact discovery is to be completed by 9/26/2025. Rule 26(a)(2) disclosures are to be made by plaintiff by 10/31/2025, with depositions by 11/28/2025, and by defendants by 12/26/2025, with depositions by 1/30/2026. The 3eadline for filing dispositive motions is 4/27/2026. The telephonic status hearing set for 6/13/2025 is vacated and reset to 8/22/2025 at 8:55 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. A joint status report regarding the progress of discovery and any settlement discussions is to be filed on 8/15/2025.

STIPULATION of Dismissal Stipulation of Dismissal as to Defendant No. 12 "ChimiSawo"

STATUS Report Joint Status Report by Anagram International, LLC

MINUTE entry before the Honorable Matthew F. Kennelly: The Court has reviewed the status report. The telephonic status hearing set for 8/22/2025 is vacated and reset to 10/8/2025 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. A joint status report regarding the progress of discovery and any settlement discussions is to be filed on 10/1/2025 (which is after the fact discovery completion deadline).

STIPULATION of Dismissal Stipulation of Voluntary Dismissal with Prejudice

MINUTE entry before the Honorable Matthew F. Kennelly: Pursuant to the stipulation of dismissal 110, this case is dismissed with prejudice and without costs. Any hearing dates set before this Court are stricken. Civil case terminated. Mailed notice.