2025-cv-08050

COMPLAINT filed by Hong Kong Leyuzhen Technology Co. Limited; JURY DEMAND. Filing fee $ 405, receipt number AILNDC-23754124.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

SEALED DOCUMENT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited UNREDACTED COMPLAINT AND EXHIBITS

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable M. David Weisman. 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.)

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal PLAINTIFFS MOTION FOR LEAVE TO FILE UNDER SEAL

Exhibit Declaration of Joshua H. Sheskin

Exhibit 1 to Declaration of Joshua H. Sheskin

(2 to Declaration of Joshua H. Sheskin)

SEALED DOCUMENT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited EXHIBITS IN SUPPORT

(Exhibit 2 to Declaration of Joshua H. Sheskin)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Gokalp Bayramoglu

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication PLAINTIFFS MOTION FOR ELECTRONIC SERVICE OF PROCESS PURSUANT TO FRCP 4(f)(3)

PLAINTIFFS MEMORANDUM IN SUPPORT OF MOTION FOR ELECTRONIC SERVICE OF PROCESS PU

Declaration of Joshua H. Sheskin

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order PLAINTIFFS EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER

MEMORANDUM IN SUPPORT OF PLAINTIFFS EX PARTE MOTION FOR ENTRY OF A TEMPORARY RE

Declaration of Joshua H. Sheskin

Exhibit 1 to Declaration of Joshua H. Sheskin

Exhibit 2 to Declaration of Joshua H. Sheskin

Exhibit 3 to Declaration of Joshua H. Sheskin

Exhibit 4 to Declaration of Joshua H. Sheskin

Exhibit 5 to Declaration of Joshua H. Sheskin

Declaration of Liangjie Li

MINUTE entry before the Honorable John Robert Blakey: Plaintiff seeks to sue 21 separate Defendants in this single copyright infringement suit, see [2], [2-2]. Joinder of multiple defendants in a single copyright infringement action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). In this regard, Plaintiff alleges that "Unique identifiers common to Defendants' internet stores, such as design elements and similarities in Defendants' unlawful use of the Copyright-Protected Images, establish a logical relationship between them and suggest that Defendants' illegal operations arise out of the same transaction, occurrence, or series of transactions or occurrences." [2] 3. Plaintiff also alleges that the "conclusion that the Defendants are interrelated, and their infringement comes from the same transaction or occurrence, is further bolstered by the fact that only large operations using similar supply chains, and manufacturers, can produce competing products at scale, which is why all of the Defendants are located in China, according to the address they have provided to Amazon." Id. 4. But these allegations remain conclusory and unsupported by Plaintiff's submissions. Plaintiff alleges that, in its "other copyright infringement enforcement actions commenced in this judicial district," it has discovered that "Defendants infringing the Copyright-Protected Images have access to these copyrighted works from the same or an interconnected source." Id. 19. But matters learned about other Defendants in other cases say nothing about the Defendants sued in this case. Because Plaintiff has failed to demonstrate the propriety of joining all Defendants in this single suit, the Court dismisses the complaint without prejudice, denies Plaintiff's motions for electronic service of process [11] and for a temporary restraining order [12]. To the extent Plaintiff can, consistent with its obligations under Rule 11, amend its complaint to allege facts to support the joinder of all Defendants in this single action, it may do so by 7/25/25. If Plaintiff fails to comply, the Court will dismiss this case. The Court grants Plaintiff's motion for leave to file under seal [4], and Plaintiff may file any amended complaint under seal as well. Mailed notice.

FIRST AMENDED complaint by Hong Kong Leyuzhen Technology Co. Limited against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

Exhibit 1 to the Amended Complaint

Exhibit 2 to the Amended Complaint

Exhibit 3 to the Amended Complaint

SEALED DOCUMENT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited UNREDACTED AMENDED COMPLAINT AND EXHIBITS

SEALED MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited AMENDED MOTION FOR ELECTRONIC SERVICE OF PROCESS

SEALED MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited PLAINTIFFS AMENDED EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER

MINUTE entry before the Honorable John Robert Blakey: Plaintiff's amended complaint names just one Defendant and thus avoids joinder issues. It appears, however, based upon Plaintiff's allegations, that Plaintiff claims infringement of multiple copyrighted photographs, but included in its submissions just one of the asserted photographs. As a result, the Court remains unable to assess Plaintiff's likelihood of success on the merits and thus denies Plaintiff's motion for a temporary restraining order [17]. The Court also denies Plaintiff's motion for electronic service of process [16] because Plaintiff combined the proposed order granting this motion with the proposed order submitted in connection with the TRO motion and also included dropped defendants in the order. In the future, Plaintiff must also notice all motions for presentment. Mailed notice.

NOTICE of Motion by Joshua Howard Sheskin for presentment of Sealed motion, [17], Sealed motion, [16] before Honorable John Robert Blakey on 8/13/2025 at 11:00 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication PLAINTIFFS CORRECTED MOTION FOR ELECTRONIC SERVICE OF PROCESS PURSUANT TO FRCP 4(f)(3)

PLAINTIFFS MEMORANDUM IN SUPPORT OF PLAINTIFFS CORRECTED MOTION FOR ELECTRONIC

Declaration of Joshua H. Sheskin

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order PLAINTIFFS CORRECTED EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND EXPEDITED DISCOVERY

MEMORANDUM IN SUPPORT OF PLAINTIFFS CORRECTED EX PARTE MOTION FOR ENTRY OF A TE

Declaration Declaration of Joshua H. Sheskin

Exhibit 1 to Declaration of Joshua H. Sheskin

Exhibit 2 to Declaration of Joshua H. Sheskin

Exhibit 3 to Declaration of Joshua H. Sheskin

Exhibit 4 to Declaration of Joshua H. Sheskin

Exhibit 5 to Declaration of Joshua H. Sheskin

Declaration of Liangjie Li

Exhibit 1 to Declaration of Liangjie Li

NOTICE of Motion by Joshua Howard Sheskin for presentment of motion for temporary restraining order, [21], motion for service by publication, [20] before Honorable John Robert Blakey on 8/20/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's submissions, the Court grants Plaintiff's motion for electronic service of process [20]. Enter Order. The Court denies without prejudice Plaintiff's motion for entry of a temporary restraining order [21] because the proposed order remains improper; in particular, the order references an attached copyright but neglects to attach the copyright. The 8/20/25 Notice of Motion date is stricken as to all motions. Mailed notice.

ORDER Granting Corrected Motion for Alternate Service of Process by E-mail and/or Electronic Publication. Signed by the Honorable John Robert Blakey on 8/19/2025. Mailed notice.

NOTICE by Hong Kong Leyuzhen Technology Co. Limited re order[24]

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order PLAINTIFFS SECOND CORRECTED EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND EXPEDITED DISCOVERY

MEMORANDUM IN SUPPORT OF PLAINTIFFS SECOND CORRECTED EX PARTE MOTION FOR ENTRY

Declaration of Joshua H. Sheskin

Exhibit 1 to Declaration of Joshua H. Sheskin

Exhibit 2 to Declaration of Joshua H. Sheskin

Exhibit 3 to Declaration of Joshua H. Sheskin

Exhibit 4 to Declaration of Joshua H. Sheskin

Exhibit 5 to Declaration of Joshua H. Sheskin

Declaration of Liangjie Li

NOTICE of Motion by Joshua Howard Sheskin for presentment of motion for temporary restraining order, [26] before Honorable John Robert Blakey on 9/17/2025 at 11:00 AM.