2025-cv-06774

COMPLAINT filed by BBC Studios Distribution Ltd; Filing fee $ 405, receipt number AILNDC-23644280.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Luana Faria de Souza

Declaration of Madeline B. Halgren

Exhibit Ex. 1 - Infringing Evidence Provided by Plaintiff

Exhibit A

(Exhibit A)(Faria De Souza, Luana)

Exhibit Ex. 1 - Infringing Evidence Provided by Plaintiff

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

Exhibit 2

Exhibit 2

Exhibit A

Exhibit Ex. 2 - Declaration of Xiao in Support of Defendant's Opposition

Exhibit Ex. 2 - Declaration in support of Defendant's Motion to Dismiss

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

(Exhibit Ex. 3 - Declaration of Peng in Support of Defendant's Opposition)

(Exhibit Ex. 2 - Declaration in support of Defendant's Motion to Dismiss)

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 Luana Faria De Souza (Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Madeline Halgren

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.)

BOND in the amount of $ 10,000 check, Receipt No.100021891, posted by BBC Studios Distribution Ltd. (Text entry; no document attached.)

NEW PARTIES: A1O9W912BUSRO7, A34JZ0ZR36MMOC, AI204PNVW01OC, ANH QUOC SHOP, BOHO home US, chaojunshangm, Do a good job of service, dongguanshihenglimianhukejiyouxiangongsi, hujunshangmao, Ice mint cream, JALESC, JDDZSWZX, Joseph Technology Co., Ltd., lianyungangyongzhixubaihuojingyingbu, liufengjiededianpu, lulurelax, MeiBeilailai, Merry Mates, pai you mao yi, ShoesCharmsShop, Shop tea 97, ssmysh, suixingoubaihuojingyingbu, SuiZhouShiWanYanLeiShangMaoYouXianGongSi, TienDung.Store, TienNguyenShop, TTDQ Party Direct, tung na, Vetadu, WC-JP, XiangYangShiMoJiaoBaiHuoDianGeRenDuZi, XIAQIANGDEXIAODADIANDIAN, XinJiangXinHongLingHuanBaoKeJiYouXianGongSi, Xiuzhaoshangwudian, Yan Lin, YingZhenMaoYiYouXianGongSi, zhiweichen, zqymyzx, zzshengli, CozyCoves, GZjcjiafang, HaoChenxi home Textiles, Miqiaikids, S552457_apo_shop, Tin Testament, YiYouYu, YouLe Decoration, Balloonia, BLUE ROSE, Cromar, FeiCHI, feimiaoshop, Forfamy, FUZUOMAOYI, GAFICO, HLANDSKY, Lanyao, Sell-together, SunnySpot, Theme decorations, VVWA, Wangwang, Wishta, Worth having fun, XianYouShanZhiCai, xianyouxianyuegousen and YZXSHOP added to case caption. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Diane Hamer regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Exhibit 3 - Parts 1-2 regarding declaration[16]

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[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are set for a telephonic motion hearing on 7/2/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. (jn,)

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Lucas Allen Peterson

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 7/2/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A regarding complaint [2], and (2) Exhibit 3 - Parts 1-2 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 7/2/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 7/16/2025 at 9:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 7/2/2025. Mailed notice

Registry Deposit Information Form by BBC Studios Distribution Ltd (Faria De Souza, Luana)

SUMMONS Submitted (Court Participant) for defendant(s) A1O9W912BUSRO7 and all other Defendants identified in the Complaint by Plaintiff BBC Studios Distribution Ltd (Faria De Souza, Luana)

SUMMONS Issued (Court Participant) as to Defendant A1O9W912BUSRO7 and all other Defendants identified in the Complaint

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time of Temporary Restraining Order (Faria De Souza, Luana)

MEMORANDUM by BBC Studios Distribution Ltd in support of extension of time[28] (Faria De Souza, Luana)

DECLARATION of Luana Faria de Souza regarding memorandum in support of motion[29] (Faria De Souza, Luana)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 28 is granted. The Court finds good cause to extend the temporary restraining order an additional 14 days to 7/30/2025. Telephonic status hearing set for 7/16/2025 is stricken and reset for 7/30/2025 at 9:00 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

MOTION by Plaintiff BBC Studios Distribution Ltd for preliminary injunction

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for preliminary injunction[32]

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/16/2025, answer due 8/6/2025.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction [32] will be heard at the telephonic hearing set for 7/30/2025 at 9:00 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 Defendants SANHE Co.Ltd, YUTI Co.Ltd by He Cheng

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/30/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [32] is entered and continued. Defendant requests a briefing schedule. Accordingly, any opposition to Plaintiff's motion for preliminary injunction shall be filed by 8/13/2025. Plaintiff shall file any reply by 8/27/2025. The Temporary restraining order will remain in place as to all Defendants until resolution of the motion for entry of preliminary injunction. By 8/6/2025, Plaintiff shall file a supplemental submission that reflects the amount of frozen funds for each defendant. Plaintiff is granted leave to file the document under seal. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint [2], (2) Exhibit 3 - Parts 1-2 [17], and (3) the sealed temporary restraining order [24]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Term inate_Instructions.pdf. Telephonic status hearing set for 9/4/2025 at 10:30 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 BBC Studios Distribution Ltd as to certain defendants (Faria De Souza, Luana)

RESPONSE by Plaintiff BBC Studios Distribution Ltd to order on motion for preliminary injunction, telephone conference, set/reset hearings, [37]

MOTION by Defendants SANHE Co.Ltd, YUTI Co.Ltd for extension of time to file answer regarding complaint[1]

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants (Faria De Souza, Luana)

MINUTE entry before the Honorable Andrea R. Wood: Defendants SANHE Co.Ltd, YUTI Co.Ltd's unopposed motion for extension of time to answer or otherwise respond to Plaintiff's complaint [40] is granted. Those Defendants shall answer or otherwise respond to the complaint by 9/5/2025. Mailed notice

RESPONSE by SANHE Co.Ltd, YUTI Co.Ltdin Opposition to MOTION by Plaintiff BBC Studios Distribution Ltd for preliminary injunction 32

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Jennifer Van Nacht

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time to file response/reply as to response in opposition to motion, [43] (Unopposed)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's unopposed motion for extension of time to respond to Defendants' response in opposition to Plaintiff's motion for entry of a preliminary injunction [45] is granted. Plaintiff shall file their reply by 9/10/2025. Mailed notice

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendant (Faria De Souza, Luana)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing set for 9/4/2025 is stricken and reset for 9/18/2025 at 9:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time to respond to Defendants' response in opposition to Plaintiff's motion for entry of a preliminary injunction 43 (Unopposed)

MOTION by Defendants SANHE Co.Ltd, YUTI Co.Ltd to dismiss for lack of jurisdiction