2025-cv-07929

COMPLAINT filed by Lisa Audit; Filing fee $ 405, receipt number AILNDC-23743494.

(Exhibit 1)

Declaration of Keith A. Vogt

Exhibit 2-1

Declaration of Keith A. Vogt

(Declaration of Service, Keith A. Vogt)

Exhibit Ex. 1 - Declaration of Chaofen LI in Support of Defendant's Opposition to Plaintiff's Motion for Preliminary Injunction

SCHEDULE A to Complaint by Plaintiff Lisa Audit Schedule A to Complaint 1 Modified on 8/25/2025.

Exhibit 1-2, of Keith A. Vogt's declaration

(Exhibit 2-2)

(Exhibit 1, Declaration of Keith Vogt)

Exhibit Ex. 2 - Declaration of Likun DENG in Support of Defendant's Opposition to Plaintiff's Motion for Preliminary Injunction

CIVIL Cover Sheet

Declaration of Lisa Audit

Exhibit Ex. 3 - Declaration of Mengyu LI in Support of Defendant's Opposition to Plaintiff's Motion for Preliminary Injunction

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category 3). (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.)

ATTORNEY Appearance for Plaintiff Lisa Audit by Keith A. Vogt

Exhibit 1, of Lisa Audit's declaration

(Exhibit Ex. 4 - Declaration of Zhuocan Zeng in Support of Defendant's Opposition to Plaintiff's Motion for Preliminary Injunction)

ORDER: Local Rule 3.1 requires at the time of filing a case, plaintiff's counsel, or if the case is filed pro se, the plaintiff shall file with the original papers a completed designation sheet (civil cover sheet). No civil cover sheet was submitted at the time of filing this matter. Lisa Audit is directed to file the Civil Cover Sheet within 14 days of this notification. Signed by the Executive Committee.

Exhibit 2-1, of Lisa Audit's declaration

ATTORNEY Appearance for Plaintiff Lisa Audit by Yanling Jiang

(Exhibit 2-2, of Lisa Audit's declaration)

ATTORNEY Appearance for Plaintiff Lisa Audit by Adam Grodman

ATTORNEY Appearance for Plaintiff Lisa Audit by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Lisa Audit by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Lisa Audit by Yi Bu

ATTORNEY Appearance for Plaintiff Lisa Audit by Christopher Romero

MAILED copyright report to Registrar, Washington DC.

MOTION by Plaintiff Lisa Audit for leave to file under seal

MOTION by Plaintiff Lisa Audit for leave to file excess pages

MEMORANDUM in support of 15 Exparte motion

EXHIBIT 2 by Plaintiff Lisa Audit to the Declaration of Lisa Audit in support of memorandum in support of Plaintiff's EX PARTE motion for entry of a Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, expedited discovery, and service of process by e-mail and/or electronic publication, 16 Modified on 8/25/2025.

Presentment for Exparte motion 15 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 14, motion for leave to file 13 before Honorable Jorge L. Alonso on 7/23/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 13 14 15 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 $180,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 7/23/25 is stricken. Notice mailed by Judge's staff

TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 7/23/2025. Notice mailed by Judge's staff Modified on 8/25/2025.

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

SURETY BOND in the amount of $180,000 posted by Lisa Audit (Document not scanned). (Main Document 23 replaced on 7/28/2025).

MOTION by Plaintiff Lisa Audit for extension of time of the Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time 24 before Honorable Sharon Johnson Coleman on 8/5/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 8/5/2025. Plaintiff's motion to extend the temporary restraining order 24 is granted. Enter Order. Mailed notice.

ORDER On Motion for Extension of Temporary Restraining Order. Signed by the Honorable Sharon Johnson Coleman on 8/5/2025. Mailed notice.

MOTION by Plaintiff Lisa Audit for preliminary injunction

MEMORANDUM by Lisa Audit in support of motion for preliminary injunction 28

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 28 before Honorable Jorge L. Alonso on 8/12/2025 at 09:30 AM.

SUMMONS Returned Executed by Lisa Audit as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/5/2025, answer due 8/26/2025.

MINUTE entry before the Honorable Jorge L. Alonso: Motion 28 hearing set for 8/12/25 is stricken and re-set for telephonic motion hearing on 8/21/25 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 Defendants QIANSHAN Co.Ltd, YUNJIN Co.Ltd, CHUONI Co. Ltd, WEIRUN Co. Ltd by He Cheng

RESPONSE by CHUONI Co. Ltd, QIANSHAN Co.Ltd, WEIRUN Co. Ltd, YUNJIN Co.Ltdin Opposition to MOTION by Plaintiff Lisa Audit for preliminary injunction 28

ATTORNEY Appearance for Defendant Orgrimmar Bags by Christopher Paul Keleher

MOTION by Defendant Orgrimmar Bags for extension of time to file answer regarding complaint 1 (UNOPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 36 before Honorable Jorge L. Alonso on 8/27/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held on 8/21/2025. Temporary Restraining Order will be extended as to the four represented/appearing Defendants. The plaintiff agrees to modify the asset freeze to no more than $5,000.00 as to each of the represented/appearing Defendants. A reply will be due on 9/17/2025 to the opposition 34 to the motion for preliminary injunction. A telephone status hearing will be set for 9/18/2025 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. The injunctive relief will remain in place under Rule 65 and the bond will remain with the Court. Motion by Plaintiff Lisa Audit for entry of a preliminary injunction 28 is granted in part as to all Defendants except for the represented/appearing defendants, Chuoni Co.Ltd. (No. 136), Weirun Co. Ltd. (No. 137), Yunjin Co. Ltd. (No. 138) and Qianshan Co. Ltd. (No. 158). The Preliminary Injunction is entered as to all of the other defendants. Enter Preliminary Injunction Order. Mailed notice. (jn,)

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 8/21/2025. Mailed notice. (jn,)

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

ATTORNEY Appearance for Defendants Doe 12 XiajiaPer, GreShonYT by Christopher Paul Keleher

MOTION by Defendants GreShonYT, Doe 12 XiajiaPer for extension of time to file answer regarding complaint 1 (UNOPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 42 before Honorable Jorge L. Alonso on 9/3/2025 at 09:30 AM.

ATTORNEY Appearance for Defendants Letaoleyuan, gewenjinggejidaobaihuodian by Timothy Tiewei Wang

MOTION by Defendants Letaoleyuan, gewenjinggejidaobaihuodian for extension of time to file answer regarding complaint 1 Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer 45 before Honorable Jorge L. Alonso on 9/4/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Defendants' Orgrimmar Bags First Motion for extension of time to answer or otherwise plead 36 is granted to 9/11/25. Defendants, XiajiaPer and GreShonYT's First Motion for extension of time to answer or otherwise plead 42 is granted to 9/16/25. Defendants Letaoleyuan and gewenjinggejidaobaihuodian Unopposed Motion to extend deadline to answer or otherwise respond 45 is granted to 9/16/25. Motion hearing dates of 8/27/25, 9/3/25 and 9/4/25 are stricken. Notice mailed by Judge's staff

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant Nos. 136 CHUONI Co.Ltd, 137 WEIRUN Co.Ltd, 138 YUNJIN Co.Ltd, and 158 QIANSHAN Co.Ltd

ATTORNEY Appearance for Defendants Kaywance, COOLgooee by Adam Edward Urbanczyk

MOTION by Defendants COOLgooee, Kaywance for extension of time

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time 50 before Honorable Jorge L. Alonso on 9/3/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 9/3/25 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. The injunctive relief will remain in place under Rule 65 and the bond will remain with the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Defendants' Motion for extension of time 50 is granted to 9/18/25. Status hearing remains set for 9/18/25. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants