2025-cv-08314

COMPLAINT filed by Dongguan Fangde Network Technology Co., Ltd.; Filing fee $ 405, receipt number AILNDC-23776933.

Exhibit 4

Exhibit 1

Declaration of Abby Neu

Exhibit 4

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Schedule A

Exhibit 5

Exhibit 2

(Exhibit 1)

Exhibit 5

SEALED EXHIBIT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Exhibit 1 regarding complaint 1

(Exhibit 6)

Exhibit 3

Exhibit 6

SEALED EXHIBIT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Exhibit 2 regarding complaint 1

Exhibit 4

SEALED EXHIBIT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Exhibit 3 regarding complaint 1

Exhibit 5

MOTION by Plaintiff Dongguan Fangde Network Technology Co., Ltd. for leave to file UNDER SEAL

Exhibit 6

CIVIL Cover Sheet

(Schedule A)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dongguan Fangde Network Technology Co., Ltd.

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Notice of Claims Involving Patents

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Abby Marie Neu

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Shengmao Mu

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Keaton David Smith

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Michael Mitchell

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Ryan Evan Carreon

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Sealed Complaint

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 1). (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.)

MAILED patent report to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff Dongguan Fangde Network Technology Co., Ltd. to seal

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Memorandum Establishing that Joinder is Proper

MINUTE entry before the Honorable John Robert Blakey: Plaintiff, a Chinese company, sues 28 other Chinese companies, alleging patent infringement, [1], [2], [15]. Parties accused of patent infringement "may be joined in one action as defendants. only if-- (1) any right to relief is asserted against the parties jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences relating to the making, using, importing into the United States, offering for sale, or selling of the same accused product or process; and (2) questions of fact common to all defendants or counterclaim defendants will arise in the action." 35 U.S.C. § 299(a). Accused infringers "may not be joined in one action as defendants. based solely on allegations that they each have infringed the patent or patents in suit." Id. § 299(b). Here, Plaintiff submitted a memorandum seeking to justify joinder under Rule 20. Plaintiff asserts that its "well-pled allegations establish that Defendants are operating in the same transaction, occurrence, or series of transactions or occurrences, rendering joinder proper." [18] at 6. But the allegations and arguments emphasize that Defendants all use fictitious names and storefronts, see [18-1] 2, and "share unique identifiers." [15] 21, 22. These allegations remain conclusory. Moreover, at most, Plaintiff's allegations suggest Defendants are infringing, not that they are related. As a result, the Court finds that Plaintiff has failed to demonstrate the propriety of joining all 28 Defendants in this single suit and dismisses Plaintiff's complaint. The Court also denies Plaintiff's motions for leave to file under seal [6], [17], because Plaintiff failed to comply with this Court's standing orders, which require, among other things, that all motions be noticed for presentment. Finally, if counsel wish to appear in this case, they must file appearance forms disclosing whether they are members of this court's trial bar and general bar, see L.R. 83.12, 83.16; the current forms do not so specify, see [10], [11], [12], [13], [14]. Mailed notice.

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Abby Marie Neu Corrected form

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Keaton David Smith Corrected Form

ATTORNEY Appearance for Plaintiff Dongguan Fangde Network Technology Co., Ltd. by Ryan Evan Carreon Corrected Notice of Appearance

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Amended Complaint

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Exhibit 1: to Amended Complaint

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Exhibit 2: to Amended Complaint

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Exhibit 3: to Amended Complaint

AMENDED complaint by Dongguan Fangde Network Technology Co., Ltd. against The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A

SEALED DOCUMENT by Plaintiff Dongguan Fangde Network Technology Co., Ltd. Schedule A

MOTION by Plaintiff Dongguan Fangde Network Technology Co., Ltd. to seal document sealed document[25], sealed document[24], sealed document[23], sealed document[28], sealed document[26]

NOTICE of Motion by Michael Mitchell for presentment of motion to seal document[29] before Honorable John Robert Blakey on 8/13/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Plaintiff has filed an amended complaint 27, 28, which names just one defendant and thus avoids any joinder issues. The complaint, however, remains drafted as if it still targets multiple Defendants. Given the disconnect and ambiguity, the Court dismisses Plaintiff's amended complaint 27, denies without prejudice Plaintiff's motion 29, and strikes the 8/13/25 Notice of Motion date. If Plaintiff wishes to proceed, it must conform its allegations to the current Schedule A to make its allegations clear. Finally, counsel's most recent appearance forms indicate that Plaintiff's attorneys are members of the Court's general bar, but not the trial bar; thus, counsel must also ensure strict compliance with LR 83.12. Mailed notice.