2025-cv-06648

COMPLAINT filed by Mark Sanders LLC; Filing fee $ 405, receipt number AILNDC-23632456.

Exhibit Exhibit 1

SEALED DOCUMENT by Plaintiff Mark Sanders LLC Schedule A to Complaint

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Mark Sanders LLC by David Lee Gulbransen, Jr

MOTION by Plaintiff Mark Sanders LLC to seal document sealed document[2]

CASE ASSIGNED to the Honorable April M. Perry. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 3).

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 copyright report to Registrar, Washington DC

MINUTE entry before the Honorable April M. Perry: It appearing that the case filed is a "Schedule A" case, Plaintiff is directed to the Court's standing order on its website directing the filing of the Court's Schedule A Template within 14 days. Plaintiff's Motion to Seal [5] is granted. Upon review of the complaint, the Court sua sponte raises the propriety under Federal Rule of Civil Procedure 20(a)(2) of joining 70 defendants to this action. See, e.g., Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). Plaintiff is reminded that "[c]ourts in this district generally agree that alleging that multiple defendants have infringed on the same copyright in the same way does not create the substantial evidentiary overlap required to find a similar transaction or occurrence." See Roadget Bus. Pte. Ltd. v. Individuals, Corps, Ltd. Liab. Companies, Partnerships & Unincorporated Associations Identified on Schedule A, No. 23-cv-17036, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) (collecting cases). Plaintiff should reference this Court's opinion in Zaful v. Schedule A Defs., 24-cv-11111, Doc. 12 (N.D. Ill. Jan. 10, 2025), where the Court expressed its views on joinder in such cases. By July 2, 2025, Plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the principles described above. In the alternative, Plaintiff has leave to file an amended complaint by July 2, 2025, with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Mailed notice. (jcc,)

SEALED DOCUMENT by Plaintiff Mark Sanders LLC Schedule A Template

MOTION by Plaintiff Mark Sanders LLC for extension of time to file Memorandum in Support of Joinder

MINUTE entry before the Honorable April M. Perry: Motion for extension of time [9] is granted. Plaintiff's deadline to file a Supplemental Memorandum in Support of Joinder is extended to 7/16/2025. Mailed notice. (jcc,)

SEALED DOCUMENT by Plaintiff Mark Sanders LLC Supplemental Memo in Support of Joinder

MINUTE entry before the Honorable April M. Perry: The Court is in receipt of Plaintiff's Memorandum in Support of Joinder [11]. Plaintiff is directed to appear at a hearing on 8/6/2025 at 10:00 a.m. in person in Courtroom 1725 to discuss its representations in support of joinder. In conducting its preliminary review of the memorandum, the Court notes that Plaintiff has included copyright registrations without actual images of its protected works. See Doc. 1-1. Furthermore, Plaintiff has included no examples of infringing works sold by Defendants. And while Plaintiff's memorandum claims that all 70 defendants use the same manufacturers, the Court has no ability to verify that the works sold on the alleged manufacturer websites were protected by Plaintiff's copyrights or allegedly sold by Defendants. The Court also questions the argument that "the Defendants all appear to operate in the same geographic region." Doc. 11 at 8. According to the Schedule A Template submitted by Plaintiff, Defendants list addresses in China, the United Kingdom, Hong Kong, Turkey, Israel, Australia, Sri Lanka, Japan, Jamacia, Vietnam, Canada, the Republic of Azerbaijan, Malaysia, and Poland. See Doc. 8. Finally, it is wholly unclear how many defendants Plaintiff is attempting to join to this case the Schedule A lists 70 defendants, Doc. 2, the joinder memorandum says that severance "would create 75 individual cases," Doc. 11 at 12, and the Schedule A Template lists information for 73 different defendants. See Doc. 8. This type of confusion is precisely why the Court has repeatedly found that it is not in the interests of judicial economy and convenience for dozens of defendants to be joined in one Schedule A case. Rule 20(a) allows multiple parties to proceed in one action together; it does not create lower pleading or evidentiary standards for each of them. Plaintiff may file any supplemental materials in support of joinder or an amended Schedule A by 8/1/2025. Mailed notice. (jcc,)

NOTICE of Voluntary Dismissal by Mark Sanders LLC of all remaining defendants

MINUTE entry before the Honorable April M. Perry: Notice of Voluntary Dismissal 13 is acknowledged. Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, this case is dismissed without prejudice. Any or all previously set deadlines/hearings to be struck. Civil case terminated. Mailed notice. (jcc,)