2025-cv-07223

COMPLAINT filed by Chapter 4 Corp.; Filing fee $ 405, receipt number AILNDC-23682763.

Exhibit 1

(Exhibit 1)

(Exhibit 1)

(Exhibit 1)

(Exhibit 2-1)

Exhibit A

Declaration of Rachel M. Ackerman

Exhibit A

(Exhibit A)

Exhibit 1

(Exhibit 1)

Exhibit A

SEALED EXHIBIT by Plaintiff Chapter 4 Corp. Schedule A regarding complaint[1]

Exhibit A

Exhibit B

(Exhibit 2)

Exhibit B

MOTION by Plaintiff Chapter 4 Corp. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chapter 4 Corp.

Notice of Claims Involving Trademarks by Chapter 4 Corp.

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Rachel Meira Ackerman

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.)

check BOND in the amount of $ 35000.00 Rcpt. No: 100022401 posted by Chapter 4 Corp. (Text entry; no document attached.)

NEW PARTIES: aceordie, bf3he2rd5lm2h, byong550, chengjing78ww, dingzhongxiong78max, dsjosdids, emmanuelacheso, fengxueping007max, gaozuosji285, gonghegang, laiornntoaot412, lhaiu2, lifengying668shi, manbuo, PantryLane Collective, quamerla, sys8-92, taiyizhen12, World Wide Wonder Deals, wuhanshixingyoushus-48, zhangguanzhi312, zxzkwj, jessicalily3626, APPEARED, BIEBIE Stickers Shop, EAiship, fanyueduoS, JU BK ART, lonly Island, qiaofengchen, TianCi MX, UV meta, X Doctor Covers, zhaoyuetingSHOP and supremeespana.com added to case caption. (Text entry; no document attached.)

NEW PARTIES: NEW YEAR PHONE Case, lklkaa and ilovebong added to case caption. (Text entry; no document attached.)

Terminating lklkaa, NEW YEAR PHONE Case and ilovebong (Text entry; no document attached.)

MINUTE entry before the Honorable John J. Tharp, Jr: By 7/7/2025, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Chapter 4 Corp. against The Partnerships and Unincorporated Associations Identified on Schedule A

SEALED EXHIBIT by Plaintiff Chapter 4 Corp. Amended Schedule A regarding amended complaint 14

RESPONSE by Plaintiff Chapter 4 Corp. to text entry, 11

MOTION by Plaintiff Chapter 4 Corp. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Chapter 4 Corp. in support of motion for temporary restraining order 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

DECLARATION of Lisa M. Willis regarding memorandum in support of motion 18

SEALED EXHIBIT by Plaintiff Chapter 4 Corp. Exhibit 2 - Part 1 regarding declaration 20

MOTION by Plaintiff Chapter 4 Corp. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Chapter 4 Corp. in support of motion for miscellaneous relief 22

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 23

DOCUMENT Entered in error/Removed from docket.

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for a temporary restraining order 17 is taken under advisement. By 7/14/2025, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. Mailed notice

MOTION by Plaintiff Chapter 4 Corp. for leave to file under seal

SEALED DOCUMENT by Plaintiff Chapter 4 Corp. Supplement to Plaintiff's Motion for Entry of a Temporary Restraining Order [17]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [17] is granted. Plaintiff's motions for leave to file under seal [27] and for electronic service of process [22] are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 7/11/2025. Mailed notice

Registry Deposit Information Form by Chapter 4 Corp.

CORRECTED Sealed Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 7/11/2025.Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Chapter 4 Corp.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

MOTION by Plaintiff Chapter 4 Corp. for preliminary injunction

MEMORANDUM by Chapter 4 Corp. in support of motion for preliminary injunction[35]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[36]

SUMMONS Returned Executed by Chapter 4 Corp. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/22/2025, answer due 8/12/2025.

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [35] is taken under advisement. Any objection or response is due before 7/25/2025. Upon review of the certificate of service, the Court directs the plaintiff, by 7/24/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 7/25/2025. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by Plaintiff Chapter 4 Corp. regarding order on motion for leave to file, order on motion for temporary restraining order, order on motion for preliminary injunction, set motion and R&R deadlines/hearings, [39]

MINUTE entry before the Honorable John J. Tharp, Jr: On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [35] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 8/1/2025 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 7/30/2025. Mailed notice

MOTION by Plaintiff Chapter 4 Corp. for entry of default, MOTION by Plaintiff Chapter 4 Corp. for default judgment as to all Defendants

MEMORANDUM by Chapter 4 Corp. in support of motion for entry of default, motion for default judgment 43

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 44

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [43] is taken under advisement. Any objections or responses are due by 8/27/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 8/20/2025. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Chapter 4 Corp. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, [46]

MINUTE entry before the Honorable John J. Tharp, Jr: No defendant having objected, the plaintiff's motion for default judgment [43] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 8/29/2025. Mailed notice