2025-cv-12661

COMPLAINT filed by XYZ Corporation; JURY DEMAND. Filing fee $ 405, receipt number AILNDC-24209291.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

SEALED EXHIBIT by Plaintiff XYZ Corporation EXHIBITS IN SUPPORT regarding complaint 1

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

MOTION by Plaintiff XYZ Corporation to seal PLAINTIFFS MOTION FOR LEAVE TO FILE UNDER SEAL AND PROCEED UNDER PSEUDONYM

(Declaration of Joshua H. Sheskin)

ATTORNEY Appearance for Plaintiff XYZ Corporation by Joshua Howard Sheskin

ATTORNEY Appearance for Plaintiff XYZ Corporation by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff XYZ Corporation by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff XYZ Corporation by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff XYZ Corporation by Nazly Aileen Bayramoglu

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category 3).

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.

MINUTE entry before the Honorable Manish S. Shah: The motion to file under seal and proceed under a pseudonym [4] is denied. The court does not agree that the risk that defendants will move assets overrides the public right to know who is filing lawsuits and using the court system. Moreover, based on Exhibit 3 to the complaint, the court is not likely to grant ex parte relief that depends on preliminary merits issues. Many of the accused images do not appear to be infringing of the copyrighted image and the court will likely benefit from adversarial presentation before assessing any likelihood of success on the merits. Early discovery and electronic service of process may be appropriate if defendants are unknown and cannot be served, but ex parte substantive injunctive relief is not likely. Even assuming copyright infringement, the products sold are not infringing of plaintiff's copyright, so the sales are not direct profits from infringement and the extraordinary remedy of an asset restraint is even less likely to be appropriate. Notices Mailed.

FIRST AMENDED complaint by Wumei Lin against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

Exhibit 1 to the First Amended Complaint

Exhibit 2 to the First Amended Complaint

Exhibit 3 to the First Amended Complaint

SEALED EXHIBIT by Plaintiff Wumei Lin IN SUPPORT regarding amended complaint, [11]

MOTION by Plaintiff Wumei Lin to seal /LEAVE TO FILE UNDER SEAL

Declaration of Joseph W. Droter

MOTION by Plaintiff Wumei Lin for service by publication FOR ELECTRONIC SERVICE OF PROCESS PURSUANT TO FRCP 4(f)(3) AND EXPEDITED DISCOVERY FRCP 45

Declaration MEMORANDUM IN SUPPORT

Declaration OF JOSEPH W. DROTER

NOTICE of Motion by Joseph Wendell Droter for presentment of motion for service by publication, [14], motion to seal[13] before Honorable Manish S. Shah on 11/4/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's motions to file under seal, for alternative service of process, and expedited discovery [13][14] are granted in part, and no appearance is necessary. The court does not agree that sealing plaintiff's copyright is appropriate, but will allow the sealing of the list of defendants' storefronts (to aid in the steps necessary to properly identify defendants). The clerk shall unseal [12] and [12-1]. Docket entries [12-2] and [12-3] may remain under seal, for now. Plaintiff has good cause to conduct early discovery to identify defendants, but the court declines to authorize merits discovery, including sales data, before adversarial presentation. Enter Order. Notices Mailed.

ORDER GRANTING MOTION TO SEAL AND ELECTRONIC SERVICE AND EXPEDITED DISCOVERY. Signed by the Honorable Manish S. Shah on 11/3/2025. Notices Mailed.

SUMMONS Submitted (Court Participant) for defendant(s) THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A by Plaintiff Wumei Lin

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto