2025-cv-08165

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-23764128.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Rachel S. Miller

Declaration of Hannah A. Abes

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint[1]

Exhibit A

Exhibit 2-1

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

Exhibit 2-2

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Maria Valdez. 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: Creative World Company, Darlin Trading (shenyang) Co., Ltd., Dongguan Tinscen Tin Box Manufacture Co., Ltd., Fuzhou Guanling Trading Co., Ltd., Gansu Coolmanda Trading Company Ltd., Hanzhong Hantai Huqiao Trade City Lihua Cabinet Business Department, Henan Eila Arts & Crafts Co., Ltd, Henan Pushi Technology Co., Ltd., Huizhou Aoyu Paper Product Co., Ltd., Hunan Kaixin Industrial And Trading Co., Ltd., Hunan Splendid Culture Co., Ltd., Jinhua Darren Trading Co., Ltd., Ningbo Charron Trading Co., Ltd., Ningbo Uli Stationery Co., Ltd., Qinyang Huaizhi Toys Co., Ltd., Ruzhou Zhile Toys Co., Ltd., Shanghai Guanjun Gift Co., Ltd., Shantou Beilisi Toys Co., Ltd., Shantou Chaoyang Wenguang Weiqiu Toy Factory, Shantou Rongheqiang Trade Co. Ltd, Shantou Zhonghui Toys Co., Ltd., Shenzhen Azalea E-Commerce Co., Ltd., Shenzhen Egrow Technology Co., Limited, Shenzhen iStapromo Gifts Co.,Limited, Shenzhen Puluosi Industrial Co., Ltd., Shenzhen Ydistar Technology Co., Ltd., Wuhan Hanyang Nike Department Store Sales Department (individual Business), Xianju Answell Artware Co., Ltd., Yangzhou Yien Toy Co., Ltd., Yiwu City Card Toy Factory, Yiwu City Quanzhen E-Commerce Firm, Yiwu Guanlan Luggage Factory, Yiwu Lucky Star Crafts Co., Ltd., Yiwu Minrong E-Commerce Firm, Yiwu Rui Man Toy Co., Ltd., Yiwu Shilong Trading Co., Ltd., Yiwu Tianbian Technology Co., Ltd., A2ZBB5PYONGFDK, BEIYOUBUY, BingruiArt, COMBLUE, DailyHome Depot, DONGLI123, Estmy, gougouk044, Hangzhou Meng Yu Dian Zi Shang Wu You Xian Gong Si, jufengfuwu, JunYaDianZiShangWu, LEMILLE, LiuJi-us, luyisan, Nanning Yueyuan Culture Media Co., Ltd., Nationcog, PETUSI, qiowdbhasbujdia, shichen wang, Ure Tenk, wangsuran, WANGYUANSHENG123, wangzile, WISTAR WSD, yandongfeng, YinDingQi888, Youduomi, ZHANGXIAOLI123, fair5034, HY21-888, kun_6458, paly-22491, sz-collectible-dental, yfgyp-10, yuehu131, Bigbanban, Cute and brave, FreshTeeCo, FznTone, Innovative Customization, NOCT, PompomParadise, Charlodey, dunfeiwangluo, FrostyEcoShop, Guangdongzhongshengwangluokeji, jinanshuaiyinshangmao, JinYunMeiKeJi, Printee, Qiding, shanweixian, shiyoumaoyi, TaiYuanMoHuaiKeJiYouXianGongSi, TaiYuanShiSouShengXinXiKeJi, WuuusDay, xinyukeji, YOUNING and youqiaoshangmao added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

DECLARATION of Michael Moore regarding memorandum in support of motion[15]

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 2 regarding declaration[17]

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

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 7/23/2025. Mailed notice.

Registry Deposit Information Form by Mattel, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mattel, Inc.

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

SURETY BOND in the amount of $ 15,000 posted by Mattel, Inc. (Document not scanned)

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time[29]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[30]

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [29] is granted. The Temporary Restraining Order entered on 7/23/2025 is extended by a period of fourteen (14) days until 8/20/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction[34]

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/15/2025, answer due 9/5/2025.

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [34] is set for 8/20/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 8/20/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [34] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibits to the Declaration of Michael Moore [18], and the TRO [24]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 9/19/2025 at 9:30 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 he2arings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 8/20/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/19/2025 is reset for 9/18/2025 at 9:15 a.m. Mailed notice.

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment[44]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]