2025-cv-04855

COMPLAINT filed by Scott Radke; Filing fee $ 405, receipt number AILNDC-23511838.

Exhibit Exhibit 1

Declaration Declaration of Plaintiff

Exhibit Exhibit 2 (Part 2 of 7)

Declaration Declaration of David Gulbransen

Declaration Declaration of David Gulbransen

SEALED DOCUMENT by Plaintiff Scott Radke Schedule A to Complaint

Exhibit Exhibit 1

Exhibit Exhibit 2 (Part 3 of 7)

Exhibit Exhibit 1

Exhibit Exhibit 1

CIVIL Cover Sheet

Declaration Declaration of David Gulbransen

Exhibit Exhibit 2 (Part 4 of 7)

Exhibit Exhibit 2

ATTORNEY Appearance for Plaintiff Scott Radke by David Lee Gulbransen, Jr

Exhibit Exhibit 2 (Part 5 of 7)

MOTION by Plaintiff Scott Radke to seal document sealed document[2]

Exhibit Exhibit 2 (Part 6 of 7)

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 3). (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 Copyright report to Registrar, Washington DC

(Exhibit Exhibit 2 (Part 7 of 7))

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Jorge L. Alonso for all further proceedings pursuant to 28:294(b). Mailed notice

MOTION by Plaintiff Scott Radke for temporary restraining order

MEMORANDUM by Scott Radke in support of motion for temporary restraining order[8]

SEALED DOCUMENT by Plaintiff Scott Radke

MOTION by Plaintiff Scott Radke for leave to file excess pages

MOTION by Plaintiff Scott Radke to seal document sealed document, [10]

NOTICE of Motion by David Lee Gulbransen, Jr for presentment of motion to seal document[5], motion for temporary restraining order[8], motion for leave to file excess pages[11], motion to seal document[12] before Honorable Jorge L. Alonso on 6/12/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [5] [8] [11][12] 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 $37,000$1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 6/12/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 6/11/2025. Notice mailed by Judge's staff

SURETY BOND in the amount of $ 37,000 posted by Scott Radke (Document not scanned)

NOTICE of Voluntary Dismissal by Scott Radke of Certain Doe Defendants

MINUTE entry before the Honorable Jorge L. Alonso: A telephonic status hearing is set for 7/23/2025 at 9:30 a.m. The parties are directed to file a status report at least three days prior to the next status hearing. 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. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) HeyLeyJey and all other Defendants identified in the Complaint by Plaintiff Scott Radke

SUMMONS Issued (Court Participant) as to Defendant HeyLeyJey and all other Defendants identified in the Complaint

MOTION by Plaintiff Scott Radke for preliminary injunction

SUMMONS Returned Executed by Scott Radke as to Partnerships and Unincorporated Associations Identified on Schedule A on 7/13/2025, answer due 8/4/2025.

MEMORANDUM by Scott Radke in support of motion for preliminary injunction[21]

NOTICE of Motion by David Lee Gulbransen, Jr for presentment of motion for preliminary injunction[21] before Honorable Jorge L. Alonso on 7/16/2025 at 09:30 AM.

CERTIFICATE of Service by Plaintiff Scott Radke regarding notice of motion[24], MOTION by Plaintiff Scott Radke for preliminary injunction [21], sealed document[2], complaint[1], summons issued (court participant)[20]

ATTORNEY Appearance for Defendants FANQI Co.Ltd, HAONAI Co.Ltd by He Cheng

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 7/16/25 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 motion hearing held. Defendants FANQI Co. Ltd, HAONAI Co. Ltd's response in opposition to Plaintiff's Motion for entry of preliminary injunction [21] shall be filed by 7/18/25; Plaintiff's reply shall be filed by 7/25/25. Plaintiff's Motion for entry of preliminary injunction [21] is granted as to the remaining Defendants. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal all previously sealed documents. 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 previously set for 7/23/25 is stricken and reset to 8/19/25 at 9:30 a.m. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 7/16/2025. Notice mailed by Judge's staff

Notice of Settlement by FANQI Co.Ltd, HAONAI Co.Ltd

STIPULATION of Dismissal of Does 25 and 27

NOTICE of Voluntary Dismissal by Scott Radke of Certain Doe Defendants

NOTICE of Voluntary Dismissal by Scott Radke of Certain Doe Defendants

NOTICE of Voluntary Dismissal by Scott Radke of Certain Doe Defendants

NOTICE of Voluntary Dismissal by Scott Radke of Certain Doe Defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 9/11/25 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

MOTION by Plaintiff Scott Radke for default judgment as to all remaining defendants

MEMORANDUM by Scott Radke in support of motion for default judgment[37]

NOTICE of Motion by David Lee Gulbransen, Jr for presentment of motion for default judgment[37] before Honorable Jorge L. Alonso on 9/11/2025 at 09:30 AM.