2025-cv-06816

COMPLAINT filed by Universal City Studios LLC ; Filing fee $ 405, receipt number AILNDC-23647262.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Luana Faria de Souza

(Exhibit A)

Exhibit 1

(Exhibit 1)

(Exhibit A)

SEALED EXHIBIT by Plaintiff Universal City Studios LLC Schedule A regarding complaint[1]

Exhibit 2

Exhibit 2

Exhibit A

Exhibit 2-1

MOTION by Plaintiff Universal City Studios LLC for leave to file under seal

(Exhibit 2-2)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Universal City Studios LLC

Notice of Claims Involving Trademarks by Universal City Studios LLC

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Jorge L. Alonso. 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.)

NEW PARTIES: Overseas Deals, Pandoraaa, Paul Poster Art House, Personalize Fashion, PersonalizeC, Personalized ThreadworksC, Personalized ThreadworksJ, Personalized ThreadworksM, PHPQ, PINGANJIAFANG, Pivot Studio, PLAYFULPALACEA, PosterPulse, PP Funny Sticker, Pretty Art Painting, PrimeTees shop, Printifyt shirt, Puswear, QAQ blanket, QBA SHOP, qianheupus, Qiaokeli sticker, QIN kkp, QINGCHECHEN, QingfenS, Qinglong Art Poster s, qinqingd, qndasc, Quan Shen art, RCshoping, Red Red decor shop, Resou mall, Rice hair hair, RNG Decorative painting, RNGDE, Rolling in Wealth, romanzhai, rong poster, RongxingSH, Ruilana, RV Rainveil, S Art Poster, S Fast decorative painting, S W Decorative painting, Sanrio Fashionable Shop, Sarah Poster Art House, Shangpin Fashion, SHENGMUDE, SHI poster, Sign DDF, singpulse, SLBA Online, SLO HUATIEPI, SnuggleTide, Snugglew, SnugThrows, Softwild, SOJJLKK, songdongA, sooiff, Sootop RadiantPans, SpaceSaver, SQ sticker, Street fashion hat, Street Lab, Street Photography HAT, Street Snap, StreetBrim, Style Rave, StyleSpindle, Stylish Spaces, Sudden Poster, Sunny Day Life, Surprise poster style, Sweet persimmon, SwiftTrends Shop, TA AleinPod Tees, TAIFANGYE, Taiguanji Shop, TAKULALA, TeamCapStyle, ThriftyTreasuresTrove, ThursdayStyle, Travel Baseball cap, Trend Lane, Trendy Brim Boutique, Variety wardrobe, Very impressive shop, VibeCup, VividMuse, Warm wearable, weisansan, what great fun, Yams New Lo, Anshu LDT and Colourchange 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 Universal City Studios LLC for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Universal City Studios LLC in support of motion for temporary restraining order[13]

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

DECLARATION of Monique Cheng Joe regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff Universal City Studios LLC Exhibit 3 - Parts 1-2 regarding declaration[16]

MOTION by Plaintiff Universal City Studios LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Universal City Studios LLC in support of motion for miscellaneous relief[18]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[13], motion for miscellaneous relief[18], motion for leave to file[3] before Honorable Jorge L. Alonso on 6/26/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [13] [18] 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 $96,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 6/26/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 6/25/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Universal City Studios LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Universal City Studios LLC

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

SURETY BOND in the amount of $ 96,000 posted by Universal City Studios LLC (document not imaged)

MOTION by Plaintiff Universal City Studios LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Universal City Studios LLC in support of extension of time[28]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[29]

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of extension of time[28] before Honorable Jorge L. Alonso on 7/9/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order [28] is granted. The temporary restraining order is extended for 14 days to 7/23/25. Motion hearing date of 7/9/25 is stricken. Telephonic status hearing set for 7/23/25 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

EXTENSION Of Temporary Restraining Order. Signed by the Honorable Jorge L. Alonso on 7/8/2025. Notice mailed by Judge's staff

MOTION by Plaintiff Universal City Studios LLC for preliminary injunction

MEMORANDUM by Universal City Studios LLC in support of motion for preliminary injunction 34

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[35]

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for preliminary injunction[34] before Honorable Jorge L. Alonso on 7/15/2025 at 09:30 AM.

SUMMONS Returned Executed by Universal City Studios LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/9/2025, answer due 7/30/2025.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 7/15/25 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

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 8/28/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction 34 is granted. 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. 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

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 7/15/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Universal City Studios LLC as to certain defendants

NOTICE of Voluntary Dismissal by Universal City Studios LLC as to certain defendants

NOTICE of Voluntary Dismissal by Universal City Studios LLC as to a Certain Defendant

MOTION by Plaintiff Universal City Studios LLC for entry of default as to all Remaining Defendants, MOTION by Plaintiff Universal City Studios LLC for default judgment as to all Remaining Defendants

MEMORANDUM by Universal City Studios LLC in support of motion for entry of default, motion for default judgment, 46

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 47

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for entry of default, motion for default judgment, 46 before Honorable Jorge L. Alonso on 8/12/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Motion hearing previously set for 8/12/25 is stricken and reset to telephonic motion hearing on 8/19/25 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

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Andrew Daniel Burnham

NOTICE of Voluntary Dismissal by Universal City Studios LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Rachel S Miller

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants [46] is granted. Enter Final Default Judgment Order. Status hearing previously set for 8/28/25 is stricken. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 8/19/2025.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 55 in the amount of $200,000 as to certain defendant