2025-cv-07832

COMPLAINT filed by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., Zagtoon Sarl, ZAG America, LLC; Filing fee $ 405, receipt number AILNDC-23735352.

Exhibit 1

Exhibit 1

(Exhibit 1)

SEALED EXHIBIT by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl Schedule A regarding complaint, [1]

Exhibit 2

Exhibit 2

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl for Leave to File Certain Documents Under Seal

Exhibit 3

Exhibit 3

CIVIL Cover Sheet

Exhibit 4

Exhibit 4

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl

Exhibit 5

Exhibit 5

Notice of Claims Involving Trademarks by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiffs Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl by Alexander Whang

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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: [REDACTED] added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

Notice of Withdrawal of Plaintiff's Motion for Leave to File Under Seal by Miraculous Z.Part Bidco Inc. d/b/a Miraculous Corp., ZAG America, LLC, Zagtoon Sarl

MINUTE entry before the Honorable LaShonda A. Hunt: Based upon the filing of Plaintiff's Notice of Withdrawal [10], Plaintiff's Motion for Leave to File Under Seal [3] is withdrawn. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. Plaintiffs name 107 Defendants in this single case [2]. However, after reviewing the complaint [1] and other filings, the Court questions whether Plaintiffs have established sufficient grounds for joinder of all Defendants. See Fed. R. Civ. P. 20(a)(2); Viking Arm AS v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). In addition, because Plaintiffs filed a form complaint with generic allegations about "Defendants" allegedly violating federal trademark and copyright laws without any details whatsoever about the defendants identified in Schedule A, the Court doubts that the complaint satisfies the requirements of with Federal Rules of Civil Procedure 8 and 10. Accordingly, by 7/31/25, Plaintiffs must either (a) file an amended complaint and an amended Schedule A under seal with a subset of Defendants, and the amended complaint must set forth with specific allegations about each defendant identified in Plaintiffs' amended Schedule A, including allegations that explain how each defendant is properly joined with each other and labeled exhibits that contain screenshots or other information specific to Defendants listed on amended Schedule A only; or (b) file a supplemental memorandum that refers to specific facts alleged in its filings and provides citations to specific screenshots associated with each Schedule A Defendant to demonstrate that joinder is proper and the allegations are sufficient under Rules 8 and 10. Otherwise, this case will be dismissed. Counsel is admonished to review and comply with all court procedures and applicable rules. Finally, Plaintiffs withdrew their notice to seal on 7/11/25 [10]. The Clerk of Court is therefore directed, forthwith, to unseal Plaintiff's schedule A [2]. Mailed notice.

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for Leave to File Certain Documents Under Seal (Renewed)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[13] before Honorable LaShonda A. Hunt on 7/22/2025 at 10:00 AM.

AMENDED complaint by Miraculous Z.Part Bidco Inc., Zagtoon Sarl, ZAG America, LLC against [REDACTED]

SEALED EXHIBIT by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl Schedule A regarding amended complaint[15]

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for Leave to File Schedule A to the Amended Complaint Under Seal

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl to strike notice of motion[14] (Incorrectly Filed Document)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[13], motion for miscellaneous relief[17], motion to strike[18] before Honorable LaShonda A. Hunt on 7/23/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motions to seal [13] [17] are denied. Plaintiff filed a motion to seal [3] on 7/11/25, and withdrew the motion on 7/11/25. The Court has since ordered the Clerk of Court [12] to unseal Plaintiff's original Schedule A [2]. Plaintiff now files two motions to seal [13] [17] its Amended Schedule A [16]. However, because Plaintiff withdrew its motion to seal its original Schedule A, the Court has already ordered [12] the disclosure of the name of the Defendant Plaintiff wishes to seal in its new Schedule A. Plaintiff therefore has not established exceptional circumstances that would provide any basis for sealing the names of the associated defendant(s) listed in its Amended Schedule A [16]. See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000) ("Many a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing."). Thus, the requests to seal Plaintiff's Amended Schedule A [13] [17] are denied. The Clerk of Court is directed, forthwith, to unseal Plaintiff's Amended Schedule A [16]. The Court reiterates its directive to the Clerk of Court [12] to unseal the original Schedule A [2], forthwith. The motion hearing set for 7/22/25 [14] and 7/23/25 [19] are stricken. Plaintiff's motion to strike [18], requesting to strike Plaintiff's notice of motion [14], is therefore denied as moot. Finally, the Clerk's Office is directed, forthwith, to update the docket to reflect that Defendant's name is "GTYYHTRRTEE." If no other relief has been sought, Plaintiff is ordered to file a status report by 8/8/25 updating the Court on the proposed next steps in the case. Mailed notice.

MOTION by Plaintiffs Miraculous Z.Part Bidco Inc., ZAG America, LLC, Zagtoon Sarl for Expedited Discovery

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[21] before Honorable LaShonda A. Hunt on 8/7/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to conduct expedited discovery [21] is granted. The Court grants Plaintiff's request for expedited discovery as the Court finds that expedited discovery is warranted to obtain Defendant's contact information. Enter Order Authorizing Expedited Discovery. The motion hearing set for 8/7/25 [22] is stricken. If no other relief has been sought, Plaintiff is ordered to file a status report by 8/19/25 updating the Court on the progress of expedited discovery and proposed next steps in the case. Mailed notice (gel,)

ORDER AUTHORIZING EXPEDITED DISCOVERY Signed by the Honorable LaShonda A. Hunt on 7/29/2025. Mailed notice (gel,)

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil Procedure 41(a)(1) and the filing of the notice of voluntary dismissal [25], this case is dismissed without prejudice. Any pending deadlines or hearings are stricken. Civil case terminated. Mailed notice (gel,)