2025-cv-10110

COMPLAINT filed by Laika, LLC; Filing fee $ 405, receipt number AILNDC-23938293.

Exhibit Exhibit 1

Declaration Declaration of Plaintiff

Declaration Declaration of Plaintiff

SEALED DOCUMENT by Plaintiff Laika, LLC Schedule A to Complaint

Exhibit Exhibit 2

Declaration Declaration of David Gulbransen

Declaration Declaration of David Gulbransen

CIVIL Cover Sheet

Exhibit Exhibit 2

Exhibit Exhibit 2

USPTO Cover Sheet by Laika, LLC

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Laika, LLC

ATTORNEY Appearance for Plaintiff Laika, LLC by David Lee Gulbransen, Jr

MOTION by Plaintiff Laika, LLC to seal document sealed document[2]

CASE ASSIGNED to the Honorable April M. Perry. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

MINUTE entry before the Honorable April M. Perry: Plaintiff's Motion to Seal [7] is granted in part. The Schedule A may be filed under seal, but Plaintiff's request to proceed under a pseudonym is denied. The Court finds that sealing the Schedule A is proper at this stage to avoid destruction of evidence and transferring of assets. Conversely, there are no exceptional circumstances that would justify allowing Plaintiff to conceal its own identity. As the Seventh Circuit has explained, "[w]e have repeatedly voiced our disfavor of parties proceeding anonymously, as anonymous litigation runs contrary to the rights of the public to have open judicial proceedings and to know who is using court facilities and procedures funded by public taxes. To proceed anonymously, a party must demonstrate exceptional circumstances that outweigh both the public policy in favor of identified parties and the prejudice to the opposing party that would result from anonymity." Doe v. Village of Deerfield, 819 F.3d 372, 376-77 (7th Cir. 2016); see also Doe v. Loyola Univ. Chicago, 100 F.4th 910, 913 (7th Cir. 2024). Plaintiff's motion identifies circumstances that are common to all "Schedule A" cases, meaning that the circumstances are, by definition, not exceptional. It appearing that the case filed is a "Schedule A" case, Plaintiff is directed to the Court's standing order on its website directing the filing of the Court's Schedule A Template within 14 days. Upon review of the complaint, the Court sua sponte raises the propriety under Federal Rule of Civil Procedure 20(a)(2) of joining 962 defendants to this action. See, e.g, Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). Plaintiff is reminded that "[c]ourts in this district generally agree that alleging that multiple defendants have infringed on the same copyright in the same way does not create the substantial evidentiary overlap required to find a similar transaction or occurrence." See Roadget Bus. Pte. Ltd. v. Individuals, Corps, Ltd. Liab. Companies, Partnerships & Unincorporated Associations Identified on Schedule A, No. 23-cv-17036, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) (collecting cases). Plaintiff should also reference this Court's opinion in Zaful v. Schedule A Defs., 24-cv-11111, Doc. 12 (N.D. Ill. Jan. 10, 2025), where the Court expressed its views on joinder. By 9/9/2025, Plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the principles described above with respect to each proposed defendant separately. In the alternative, Plaintiff has leave to file an amended complaint by 9/9/2025 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Mailed notice. (jcc,)

SEALED DOCUMENT by Plaintiff Laika, LLC Amended Schedule A

MOTION by Plaintiff Laika, LLC for temporary restraining order

MEMORANDUM by Laika, LLC in support of motion for temporary restraining order[10]

SEALED DOCUMENT by Plaintiff Laika, LLC Exhibit 1 to Delcaration of David Gulbransen

MOTION by Plaintiff Laika, LLC for leave to file excess pages

MOTION by Plaintiff Laika, LLC to seal document sealed document[12]

MINUTE entry before the Honorable April M. Perry: Plaintiff's motions to file excess pages [13] and to seal [14] are granted. Plaintiff's motion for an ex parte temporary restraining order [10] is denied without prejudice. In order to be entitled to equitable relief like a TRO, the plaintiff must show (among other things) that there is ongoing or impending harm. Swanigan v. City of Chicago, 881 F.3d 577, 583 n. 2 (7th Cir. 2018). "Past injury alone is insufficient." Simic v. City of Chicago, 851 F.3d 734, 738 (7th Cir. 2017). Plaintiff's exhibits in support of its argument of ongoing harm in this case are from 5/15/2025. Should Plaintiff re-file for a TRO, it is encouraged to submit live weblinks along with recent screenshots of the alleged infringement. Plaintiff is asked to re-file as separate motions its requests for expedited discovery and service of process via email so that each may be addressed separately. Mailed notice. (jcc,)

MOTION by Plaintiff Laika, LLC for temporary restraining order

MEMORANDUM by Laika, LLC in support of motion for temporary restraining order[16]

SEALED DOCUMENT by Plaintiff Laika, LLC Exhibit 1 to Delcaration of David Gulbransen

MOTION by Plaintiff Laika, LLC to seal document sealed document[18]