2025-cv-08557

COMPLAINT filed by Universal City Studios LLC ; Filing fee $ 405, receipt number AILNDC-23792984.

Exhibit 1

Exhibit 1

(Exhibit 3)

Exhibit A

Declaration of Berel Y. Lakovitsky

Declaration of Luana Faria de Souza

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiff Universal City Studios LLC Schedule A regarding complaint 1

(Exhibit 2)

(Exhibit 2)

Exhibit A

Exhibit 2-1

MOTION by Plaintiff Universal City Studios LLC for leave to file under seal

Exhibit 2-2

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Universal City Studios LLC

Notice of Claims Involving Trademarks by Universal City Studios LLC

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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.)

BOND in the amount of $ 2,000 check, Receipt No. 100022911 posted by Universal City Studios LLC (Text entry; no document attached.)

NEW PARTIES: PHUONG BELLA TORO SHOP8888, Rifflex Art, ShanDongAnZhengJianZhuGongChengYouXianGongSi, MR ZI guang, Nanagogoo, PENGDIAO, pingfanr, PJD Clothing, PLAGUE AND SIGN, Poetic Pavilion, Printique, PXKJYA, QIUHHZD, Qotton, QR Art painting, QYLMR, RDSZQC, Round European Selection, RSDZQA, RSDZQC, RusticGleam Mall, RusticLume Rooms, Sanamu Art, SCKGNLEKK, SHIEESHIRT, shirt twelve, Siyuan Poster, SL Starlight, SLENGJCLL, Small group costume customization, Smart casual wear, SMENYXY, Smit, SOFT HAVEN ONE, soiff, songjingxiaopu, songsuhuadianpu, SOOFDL, Sparkling Mugs, Splyth Dwox, SPPsrtwelve, Spring lris, Star language art, starfashionoutlet, STARRYSHEIF, Stashly, Stayed wu, Stellar Art L, StitchStory, Street fashion B, Style CollectionA, StyleCrafted Shop, StyleOasis, StyleStudioer, Stylish Print Boutique A, SUMMER POCKET Shop, Sunset DIY, SunSpray Studio, Super personalized clothes, Super PPJ, Superior Beauty Local local, SWSC, SXZJM Nine, SYBHA Online, TailorBloom, TailoredElegance, Tee Boutigue, Tee Shirts Home, Tee ZX, TeeHarbor, TeeHustle, TeesEmpire, Ten cats, TG GraphicTee Haven, The Cats Pajamas, The Printed Story TEE, Threaded Horizon, ThurTing, TJ Yoric, Tongduo, Tongpin Householdl local, TPH GOOD, Tremdy, Trend hat Custom Shopper local, TrendMakersDen, TrendTrack Emporium, Trendy fashion hats AAA, TroveDash, UCGVJH, UNICOTEX, VBUSDYHH, WenW Clothing Shop local, XIANZHANBAIHUO, XINBODIE, ShanYouCUP and Trend Titan 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

MAILED copyright report to Registrar, Washington DC

MOTION by Plaintiff Universal City Studios LLC for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Universal City Studios LLC in support of motion for temporary restraining order 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

DECLARATION of Monique Cheng Joe regarding memorandum in support of motion 16

SEALED EXHIBIT by Plaintiff Universal City Studios LLC Exhibit 3 regarding declaration 18

MOTION by Plaintiff Universal City Studios LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Universal City Studios LLC in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

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 15 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 20 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 7/29/2025. Mailed notice.

Registry Deposit Information Form by Universal City Studios LLC

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

MOTION by Plaintiff Universal City Studios LLC for preliminary injunction

MEMORANDUM by Universal City Studios LLC in support of motion for preliminary injunction[29]

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [29] is set for 8/11/2025 at 9:00 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.

SUMMONS Returned Executed by Universal City Studios LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/7/2025, answer due 8/28/2025.

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Thomas Joseph Juettner

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 8/11/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 29 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 Monique Cheng Joe 19, and the TRO 25. 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 hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 8/11/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Universal City Studios LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Universal City Studios LLC by Kahlia Roe Halpern

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 Universal City Studios LLC for entry of default, MOTION by Plaintiff Universal City Studios LLC for default judgment as to all Defendants

MEMORANDUM by Universal City Studios LLC in support of motion for entry of default, motion for default judgment[39]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[40]

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/18/2025 at 9:15 a.m. is converted to a telephone hearing as to the motion for entry of default and default judgment [39]. Mailed notice.