2023-cv-00774

COMPLAINT against THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A TO THE COMPLAINT. (Filing Fee $ 402.00, Receipt Number ANYSDC-27270084)Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

Exhibit 1 to Complaint (Part 1 of 2)

Exhibit 1 to Complaint (Part 2 of 2)

Exhibit 2 to Complaint (Part 1 of 2)

Exhibit 2 to Complaint (Part 2 of 2)

CIVIL COVER SHEET filed.

NOTICE OF APPEARANCE by Christopher Tom on behalf of RUN-TIGER LLC, d/b/a RUN-CHICKEN.

NOTICE OF APPEARANCE by Anna Iskikian on behalf of RUN-TIGER LLC, d/b/a RUN-CHICKEN.

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

AO 120 FORM TRADEMARK - NOTICE OF SUBMISSION BY ATTORNEY. AO 120 Form Patent/Trademark for case opening submitted to court for review.

AO 121 FORM COPYRIGHT - NOTICE OF SUBMISSION BY ATTORNEY. AO 121 Form Copyright for case opening submitted to court for review.

PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN. Related Document Number: [1]. Proposed Order to Show Cause to be reviewed by Clerk's Office staff.

MEMORANDUM OF LAW in Support re: [8] Proposed Order to Show Cause With Emergency Relief, [1] Complaint. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

DECLARATION of Christopher Tom in Support re: [8] Proposed Order to Show Cause With Emergency Relief. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

Exhibit 1 (Jan 2011 Mark Monitor)

Exhibit 2 (2020 IP Rights Seizures Stat Report)

Exhibit 3 (BASCAP Report)

Exhibit 4 (ICANN Registrar Accreditation Agreement)

Exhibit 5 (Hague Convention on Service Abroad)

Exhibit 6 (Translation of Civil Procedure Law of the People's Republic of C

DECLARATION of Jure Markic in Support re: [8] Proposed Order to Show Cause With Emergency Relief. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

Exhibit 1 to Jure Markic's Declaration

Exhibit 2 to Jure Markic's Declaration

Exhibit 3 to Jure Markic's Declaration (Provisionally Filed Under Seal)

MOTION to Seal Schedule A to Complaint and Exhibit 3 to the Declaration of Jure Markic. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

***EX-PARTE***REDACTION to [1] Complaint, Schedule A to Complaint by RUN-TIGER LLC, d/b/a RUN-CHICKENMotion or Order to File Under Seal: [12].

***EX-PARTE***REDACTION to [12] MOTION to Seal Schedule A to Complaint and Exhibit 3 to the Declaration of Jure Markic., [8] Proposed Order to Show Cause With Emergency Relief, [11] Declaration in Support, by RUN-TIGER LLC, d/b/a RUN-CHICKEN (Attachments: # (1) Exhibit 3 (Part 1 of 63), # (2) Exhibit 3 (Part 2 of 63), # (3) Exhibit 3 (Part 3 of 63), # (4) Exhibit 3 (Part 4 of 63), # (5) Exhibit 3 (Part 5 of 63), # (6) Exhibit 3 (Part 6 of 63), # (7) Exhibit 3 (Part 7 of 63), # (8) Exhibit 3 (Part 8 of 63), # (9) Exhibit 3 (Part 9 of 63), # (10) Exhibit 3 (Part 10 of 63), # (11) Exhibit 3 (Part 11 of 63), # (12) Exhibit 3 (Part 12 of 63), # (13) Exhibit 3 (Part 13 of 63), # (14) Exhibit 3 (Part 14 of 63), # (15) Exhibit 3 (Part 15 of 63), # (16) Exhibit 3 (Part 16 of 63), # (17) Exhibit 3 (Part 17 of 63), # (18) Exhibit 3 (Part 18 of 63), # (19) Exhibit 3 (Part 19 of 63), # (20) Exhibit 3 (Part 20 of 63), # (21) Exhibit 3 (Part 21 of 63), # (22) Exhibit 3 (Part 22 of 63), # (23) Exhibit 3 (Part 23 of 63), # (24) Exhibit 3 (Part 24 of 63), # (25) Exhibit 3 (Part 25 of 63), # (26) Exhibit 3 (Part 26 of 63), # (27) Exhibit 3 (Part 27 of 63), # (28) Exhibit 3 (Part 28 of 63), # (29) Exhibit 3 (Part 29 of 63), # (30) Exhibit 3 (Part 30 of 63), # (31) Exhibit 3 (Part 31 of 63))Motion or Order to File Under Seal: [12].

***EX-PARTE***REDACTION to [12] MOTION to Seal Schedule A to Complaint and Exhibit 3 to the Declaration of Jure Markic., [8] Proposed Order to Show Cause With Emergency Relief, [11] Declaration in Support, by RUN-TIGER LLC, d/b/a RUN-CHICKEN (Attachments: # (1) Exhibit 3 (Part 32 of 63), # (2) Exhibit 3 (Part 33 of 63), # (3) Exhibit 3 (Part 34 of 63), # (4) Exhibit 3 (Part 35 of 63), # (5) Exhibit 3 (Part 36 of 63), # (6) Exhibit 3 (Part 37 of 63), # (7) Exhibit 3 (Part 38 of 63), # (8) Exhibit 3 (Part 39 of 63), # (9) Exhibit 3 (Part 40 of 63), # (10) Exhibit 3 (Part 41 of 63), # (11) Exhibit 3 (Part 42 of 63), # (12) Exhibit 3 (Part 43 of 63), # (13) Exhibit 3 (Part 44 of 63), # (14) Exhibit 3 (Part 45 of 63), # (15) Exhibit 3 (Part 46 of 63), # (16) Exhibit 3 (Part 47 of 63), # (17) Exhibit 3 (Part 48 of 63), # (18) Exhibit 3 (Part 49 of 63), # (19) Exhibit 3 (Part 50 of 63), # (20) Exhibit 3 (Part 51 of 63), # (21) Exhibit 3 (Part 52 of 63), # (22) Exhibit 3 (Part 53 of 63), # (23) Exhibit 3 (Part 54 of 63), # (24) Exhibit 3 (Part 55 of 63), # (25) Exhibit 3 (Part 56 of 63), # (26) Exhibit 3 (Part 57 of 63), # (27) Exhibit 3 (Part 58 of 63), # (28) Exhibit 3 (Part 59 of 63), # (29) Exhibit 3 (Part 60 of 63), # (30) Exhibit 3 (Part 61 of 63), # (31) Exhibit 3 (Part 62 of 63), # (32) Exhibit 3 (Part 63 of 63))Motion or Order to File Under Seal: [12].

MOTION for Leave to File Excess Pages (Application for Entry of Temporary Restraining Order. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN.

PROPOSED ORDER. Document filed by RUN-TIGER LLC, d/b/a RUN-CHICKEN. Related Document Number: [16]. Proposed Order to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. [8] Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED ORDER. Notice to attorney Christopher Tom to RE-FILE Document No. [17] Proposed Order. The filing is deficient for the following reason(s): The case number is missing on the document. Re-file the document using the event type Proposed Order found under the event list Proposed Orders. (Text entry; no document attached.)

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Paul G. Gardephe. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Christopher Tom. The party information for the following party/parties has been modified: RUN-TIGER LLC, d/b/a RUN-CHICKEN, THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A TO THE COMPLAINT. The information for the party/parties has been modified for the following reason/reasons: party name was entered in all caps; alias party name was omitted; DO NOT ENTER ALL PARTIES IN ALL CAPS. (Text entry; no document attached.)

***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Christopher Tom. The following case opening statistical information was erroneously selected/entered: Cause of Action code 17:501; County code New York;. The following correction(s) have been made to your case entry: the Cause of Action code has been modified to 17:101; the County code has been modified to XX Out of U.S.;. (Text entry; no document attached.)

PROPOSED ORDER. Document filed by Run-Tiger LLC. Related Document Number: [16 and 17]. Proposed Order to be reviewed by Clerk's Office staff.

AO 121 FORM COPYRIGHT - CASE OPENING - SUBMITTED. In compliance with the provisions of 17 U.S.C. 508, the Register of Copyrights is hereby advised that a court action has been filed on the following copyright(s) in the U.S. District Court Southern District of New York. Form e-mailed to Register of Copyrights.

AO 120 FORM TRADEMARK - CASE OPENING - SUBMITTED. In compliance with the provisions of 15 U.S.C. 1116, the Director of the U.S. Patent and Trademark Office is hereby advised that a court action has been filed on the following trademark(s) in the U.S. District Court Southern District of New York. Director of the U.S. Patent and Trademark Office electronically notified via Notice of Electronic Filing (NEF).

***NOTICE TO ATTORNEY REGARDING PDF ERROR. Notice to Attorney Christopher Tom to regarding Document [18] Proposed Order. Document filed in the wrong case. (Text entry; no document attached.)

PROPOSED ORDER. Document filed by Run-Tiger LLC. Related Document Number: [16 and 17]. Proposed Order to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. [21] Proposed Order was reviewed and approved as to form. (Text entry; no document attached.)

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, against the defendant(s) Dezhou Jifeng Cnc Equipment Co., Ltd. (1), Guigang Qingyun Pingtianshan Wood Industry Co., Ltd. (2), Hangzhou Hony Technology Co., Ltd. (3), Ningbo Qingyun Leisure Products Co., Ltd. (5), Ningbo Youzhi International Trade Co., Ltd. (6), Shanghai Vking Laser Beauty Co., Ltd. (7), 11-11 WeHome&Tools Store (8), 4Homie Store (9), Abow Store (10), ART HOME Store (11), ATE Home Decor Store (12), Barry Tools Store (13), BerryBaby Store (14), Best wishes Store (15), CC 1314 Store (17), China kitchen factory Store (18), Cosy Zone House Store (19), CreativeLifeHomeFurnishing Store (20), Crysting Store (21), DIYWORK Tools Gather Store (22), Doraemon-s pocket Store (23), DreamCoco Store (24), Dropshipping-POD-FBA Professional Service Store (25), elenine21 Store (26), Filed Store (27), First Choices Store (28), flowerherd handmade Store (29), Forest Club Store (30), Freely-Deer Store (31), Grandma Store (32), Handmade Time Store (33), HILIFE HappyHome Store (34), HILIFE-Direct Store (35), Home Storage 123 Store (36), HomeCraftss Store (37), Homes Decor Store (38), HOOMIN Franchise Store (39), Hoppy House Store (40), HX-Good Life Store (41), Ingenuity Store (42), Isfriday Dropshopping Store (43), iTimo Houseware Store (44), iTimo Warm Life Store (45), JACKAU Store (46), JANEYI Store (47), Jurong Store (48), kidsandtoys Store (49), LAIDEYI-Dropshipping Store (50), LHJ House Store (51), Life Possible Dropship Store (52), LXH Intelligent Store (53), Minigo Store (54), MODERN HOME STORE Store (55), MOFINE life Store (56), My WarmHome Store (57), NICEYARD Global Store (58), NICEYARD House Object Store (59), NICEYARD Life-Discover Store (60), NICEYARD Online Store (61), NICEYARD sweethome Store (62), NingDing Store (63), nonewmoon Store (64), Pet Club Store (65), Ready for Homeeee Store (66), Sanitary House Store (67), Shen zhen sunshine Technology Co,ltd (68), Shop1102056386 Store (69), Shop1102112424 Store (70), Shop1102194254 Store (71), Shop1102198072 Store (72), Shop1102313325 Store (73), Shop1102347254 Store (74), Shop1102372450 Store (75), Shop1102375413 Store (76), Shop1102375876 Store (77), Shop1102378451 Store (78), Shop1102410952 Store (79), Shop1102422141 Store (80), Shop1102459721 Store (81), Shop5588141 Store (82), Shop5592149 Store (83), Shop912493732 Store (84), Shop912625694 Store (85), SIKADING Store (86), sikadingone Store (87), Simple Life Household Store (88), Small animals Store (89), SmartFamily Store (90), South ding Store (91), SZJN Varied Life Store (92), UZZDSS Beautiful-House Store (93), VAE life Home-Supply Store (94), WAKYME Direct Store (95), Worry-free grocery Store (96), xiaotaifeng970729 Store (97), Your Car Dent Repair Store (98), YUAN-FANG Store (99), zhouzhou ya Store (100), alkaid 7 (103), Aufee (105), Autdoor-us (106), Bstars US (107), Caitrune (108), Chicoop Direct (109), CKGUARDER (110), Codesfir (111), Comdry (112), Cunliwaa (113), Danbirdn (114), deptok (115), fastUU (116), fegayu-US (117), Folanda-US (118), Fuzzy-Bird (119), HHXRISE (122), HOGM (123), HOMIER Store (124), Hongzer (125), Ichiias (126), Keyren (127), LIAOSELLER (128), mbyyeye100 (130), MU-RONG (133), Nancong (134), Nikaro direct (135), Panhupo-US (136), PIngAnXLe (137), Pliwier (138), PROMOTOR USA LLC (139), Pulamuse-US (140), Sheens us (142), Soar Up (143), SuchinmL (145), Suhuare (146), Super Focus Store (147), Usaozak (149), Wadiue-US (151), Weiput-US (152), Winddin (153), Xiaozhoukeji (154), YanXuan9314 (155), Yaoprind-US (156), ZDFHZDF-US (157), Zuliner (158), chickendoor-mixmun (159), agqb (160), bysc (161), cdwc (162), cuel (163), frhd (167), ftyg (168), gfyj (169), gp0b (171), lyouyip0(173), omzs (178), uygm (182), v6qp (184), vkdw (185), wwsk (187), admiral-shop (191), atragroup (194), backpackintravel (195), boldandsocial (196), buy-extreme (197), doitmiracle (203), dotaqqa (204), draweater (205), fasttobuy2012 (206), jhjygh (209), mu2ff7in (213), nourana (214), omyp1741 (216), poggal (218), smaak-62 (219), t-everydaygadget (220), t-happycenters (221), vipwindows_139 (222), weimotorshop (225), ysemil_ebike (226), ys-outdoorlife (227), Gifty Garage (228), glitzhouzz (229), helkayshop (230), implicitm (231), HOME LOVER (233), lemon tree-7 (234), rosewi (235), Tina girl Handmade Paradise (236), nueby (237), sandalsbox (238), supergoldy (239), unusuadoing (240), vipdn.cn (241), BSL Store Co. Ltd (242), hangzhoushuanghongbaozhuangyouxiangongsi (247), Heilongjiang Yingshan Dianzishangwu Youxiangongsi (248), NiceCo (251), SLD (253), Statint (254), gbtlt7shop (259), Jim Store (260), RuthStore (266), SHDY official store (267), Xebirredex (272), Your Cozy corner (273). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [22] Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Run-Tiger LLC. Related Document Number: [1]. Proposed Order to Show Cause to be reviewed by Clerk's Office staff.

AMENDED MEMORANDUM OF LAW in Support re: [23] Proposed Order to Show Cause With Emergency Relief. Document filed by Run-Tiger LLC.

DECLARATION of Christopher Tom in Support re: [23] Proposed Order to Show Cause With Emergency Relief. Document filed by Run-Tiger LLC.

AMENDED MOTION to Seal Exhibits 1 and 2 to the Declaration of Christopher Tom. Document filed by Run-Tiger LLC.

***EX-PARTE***REDACTION to [25] Declaration in Support Exhibit 1 (Amended Schedule A) by Run-Tiger LLCMotion or Order to File Under Seal: [26].

***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. 23 Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 22 Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

***EX-PARTE***REDACTION to [25] Declaration in Support Exhibit 2 (Purchase Evidence) by Run-Tiger LLC (Attachments: # (1) Exhibit Def 4, # (2) Exhibit Def 101, # (3) Exhibit Def 102, # (4) Exhibit Def 104, # (5) Exhibit Def 120, # (6) Exhibit Def 121, # (7) Exhibit Def 129, # (8) Exhibit Def 131, # (9) Exhibit Def 132, # (10) Exhibit Def 141, # (11) Exhibit Def 144, # (12) Exhibit Def 148, # (13) Exhibit Def 150, # (14) Exhibit Def 164, # (15) Exhibit Def 165, # (16) Exhibit Def 166, # (17) Exhibit Def 170, # (18) Exhibit Def 172, # (19) Exhibit Def 174, # (20) Exhibit Def 175, # (21) Exhibit Def 176, # (22) Exhibit Def 177, # (23) Exhibit Def 179, # (24) Exhibit Def 180, # (25) Exhibit Def 181, # (26) Exhibit Def 183, # (27) Exhibit Def 186, # (28) Exhibit Def 188, # (29) Exhibit Def 189, # (30) Exhibit Def 190, # (31) Exhibit Def 192, # (32) Exhibit Def 193, # (33) Exhibit Def 198, # (34) Exhibit Def 199, # (35) Exhibit Def 200, # (36) Exhibit Def 201, # (37) Exhibit Def 202, # (38) Exhibit Def 207, # (39) Exhibit Def 208, # (40) Exhibit Def 210)Motion or Order to File Under Seal: [26].

***EX-PARTE***REDACTION to [25] Declaration in Support Exhibit 2 (Purchase Evidence) by Run-Tiger LLC (Attachments: # (1) Exhibit Def 211, # (2) Exhibit Def 212, # (3) Exhibit Def 215, # (4) Exhibit Def 217, # (5) Exhibit Def 223, # (6) Exhibit Def 224, # (7) Exhibit Def 232, # (8) Exhibit Def 243, # (9) Exhibit Def 244, # (10) Exhibit Def 245, # (11) Exhibit Def 246, # (12) Exhibit Def 249, # (13) Exhibit Def 250, # (14) Exhibit Def 252, # (15) Exhibit Def 255, # (16) Exhibit Def 256, # (17) Exhibit Def 257, # (18) Exhibit Def 258, # (19) Exhibit Def 261, # (20) Exhibit Def 262, # (21) Exhibit Def 263, # (22) Exhibit Def 264, # (23) Exhibit Def 265, # (24) Exhibit Def 268, # (25) Exhibit Def 269, # (26) Exhibit Def 270, # (27) Exhibit Def 271)Motion or Order to File Under Seal: [26].

***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. [23] Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (Text entry; no document attached.)

PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Run-Tiger LLC. Proposed Order to Show Cause to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. 30 Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (Text entry; no document attached.)

ORDER TO SHOW CAUSE FOR PRELIMINARY INJUNCTION AND TEMPORARY RESTRAINING ORDER: Based on the foregoing findings of fact and conclusions of law, Plaintiff's Application is hereby GRANTED and it is ORDERED as follows: As sufficient causes has been shown, Defendants are temporarily enjoined and restrained from engaging in any of the following conduct pending the return date of the Application as referenced below: Using the RUN-CHICKEN IMAGES Copyrights and/or the RUNCHICKEN Trademarks or any reproductions, counterfeit copies, or colorable imitations thereof in any manner in connection with the distribution, marketing, advertising, offering for sale, or sale of any Counterfeit Products; Passing off, inducing, or enabling others to sell or pass off any product as a genuine RUN-CHICKEN Product that is not, in fact, Plaintiff's RUN-CHICKEN Product and/or not produced under the authorization, control, or supervision of Plaintiff and approved by Plaintiff for sale under the RUN-CHICKEN IMAGES Copyrights and/or the RUNCHICKEN Trademarks and further set forth in this Order. The Clerk of Court is directed to issue a single original summons in the name of "THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A TO THE COMPLAINT" that shall apply to all Defendants. Plaintiff shall deposit with the Court Five Thousand Dollars ($5,000.00), either cash, company check, cashier's check, or surety bond, as security, which amount was determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Amended Schedule A to the Complaint, Exhibit 3 to the Declaration of Jure Markie (Dkt. Nos. 14-15), and Exhibit 2 to the Declaration of Christopher Tom, dated February 10, 2023 (Dkt. Nos. 28-29) shall be sealed and remain sealed until Defendants' Accounts and Defendants' Assets are restrained. Plaintiff shall file unsealed versions of Amended Schedule A to the Complaint, Exhibit 3 to the Declaration of Jure Markie (Dkt. Nos. 14-15), and Exhibit 2 to the Declaration of Christopher Tom, dated February 10, 2023 (Dkt. Nos. 28-29) using the CM/ECF system prior to the expiration of this Order. Any Defendants that are subject to this Order may appear and move to dissolve or modify the Order on two (2) days' notice to Plaintiff or on shorter notice as set by this Court. IT IS FURTHER ORDERED that a hearing shall be held on 5/1/2023 at 10:00 a.m. which Plaintiff may present their arguments in support of their request for issuance of a preliminary injunction. At such time, any Defendants may also be heard as to opposition to Plaintiffs Application. IT IS FURTHER ORDERED that opposing papers, if any, shall be filed and served on or before 4/27/2023 at 5:00 p.m. This Temporary Restraining Order without notice is entered at 12:15 p.m. on April 18, 2023 and shall remain in effect for fourteen (14) days and further set forth in this Order. Show Cause Hearing set for 5/1/2023 at 10:00 AM before Judge Paul G. Gardephe. Show Cause Response due by 4/27/2023. (Signed by Judge Paul G. Gardephe on 4/18/2023) (rro) Transmission to Civil Case Openings Clerk for processing. Transmission to Finance Unit (Cashiers) for processing.

LETTER MOTION to Continue Preliminary Injunction Hearing to a later date addressed to Judge Paul G. Gardephe from Christopher Tom dated April 25, 2023. Document filed by Run-Tiger LLC.

SUMMONS ISSUED. (Text entry; no document attached.)

ORDER granting 32 Letter Motion to Continue. The hearing is adjourned to May 15, 2023 at 11:00 AM. The Application is granted. SO ORDERED. (Signed by Judge Paul G. Gardephe on 4/28/2023) Show Cause Hearing set for 5/15/2023 at 11:00 AM before Judge Paul G. Gardephe.

SUMMONS RETURNED EXECUTED. The individuals, corporations, limited liability companies, partnerships, and unincorporated associations identified on Schedule A to the Complaint served on 5/9/2023, answer due 5/30/2023. Document filed by Run-Tiger LLC.

PROPOSED ORDER. Document filed by Run-Tiger LLC. Proposed Order to be reviewed by Clerk's Office staff.

Exhibit Ex. 1 (Part 1 of 2) to Proposed Preliminary Injunction Order (trademark

Exhibit Ex. 1 (Part 2 of 2) to Proposed Preliminary Injunction Order (trademark

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANTS: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff Run-Tiger LLC, d/b/a/ Run-Chicken, voluntarily dismiss the following Defendants listed on Schedule A to the Complaint without prejudice: and further set forth in this Order. SO ORDERED. (Signed by Judge Paul G. Gardephe on 5/14/2023)

LETTER addressed to Judge Paul G. Gardephe from Christopher Tom dated May 15, 2023 re: Alibaba Defendants. Document filed by Run-Tiger LLC.

***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. 35 Proposed Order, was reviewed and approved as to form. (Text entry; no document attached.)

Minute Entry for proceedings held before Judge Paul G. Gardephe: Show Cause Hearing held on 5/15/2023. (Court Reporter George Malinoski) (Text entry; no document attached.)

ORDER: The Court therefore determines that a preliminary injunction is warranted under Federal Rule of Civil Procedure 65. NOW THEREFORE, on this 18th day of May, 2023, this Court ORDERS that: 1. The Remaining Defendants, their affiliates, officers, agents, servants, employees, attorneys, confederates, and all persons acting for, with, by, through, under, or in active concert with them be temporarily enjoined and restrained from: a. using the RUN-CHICKEN Copyrights and RUN-CHICKEN Trademarks or any reproductions, counterfeit copies, or colorable imitations thereof in any manner in connection with the distribution, marketing, advertising, offering for sale, or sale of any product that is not a genuine Run-Chicken product or not authorized by Plaintiff to be sold in connection with the RUN-CHICKEN Copyrights and RUN-CHICKEN Trademarks; as further set forth in this Order. All Remaining Defendants in this action having been served (Dkt. No. 34), the Clerk of Court is directed to unseal Amended Schedule A to the Complaint (Dkt. No. 27) and Exhibit 2 to the Declaration of Christopher Tom. (Dkt. Nos. 28, 28-1 - 28-40, 29, 29-1 -29-27) Any Remaining Defendants that are subject to this Order may appear and move to dissolve or modify the Order on two days' notice to Plaintiff or on shorter notice as set by this Court. The five-thousand-dollar ($5,000.00) bond posted by Plaintiff shall remain with the Court until a final disposition of this case or until this Preliminary Injunction is terminated. SO ORDERED (Signed by Judge Paul G. Gardephe on 5/18/2023) (ks) Transmission to Finance Unit (Cashiers) for processing.

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) wangbowen8899-1 (223), Guanyanyi (121), abcdqqa (189), df19-qdiwlmec (202), odfc55 (215), panda_of_china (217). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [39] Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 39 Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANTS: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff Run-Tiger LLC, d/b/a/ Run-Chicken, voluntarily dismiss the following Defendants listedon the Second Amended Schedule A to the Complaint without prejudice: panda_of_china (217) and wangbowen8899-1 (223) terminated. SO ORDERED. (Signed by Judge Paul G. Gardephe on 6/06/2023)

ADD PARTY FOR PLEADING. Defendants/Respondents capricor-2916 (198), cheer-905622 (199), green-design (207), jakic16 (208), mensame-63 (211), pinkwing (265) added. Party added pursuant to [1] Complaint.Document filed by Run-Tiger LLC. Related document: [1] Complaint. (Text entry; no document attached.)

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) capricor-2916 (198), cheer-905622 (199), green-design (207), jakic16 (208), mensame-63 (211), pinkwing (265). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [41] Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 41 Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

Notice of Voluntary Dismissal

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [42] Notice of Voluntary Dismissal, was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 42 Notice of Voluntary Dismissal, was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANTS TO THE COURT AND ALL INTERESTED PARTIES: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff Run-Tiger LLC, d/b/a/ Run-Chicken, voluntarily dismiss the following Defendants listed on the Second Amended Schedule A to the Complaint without prejudice: capricor-2916, cheer-905622, green-design, jakic16, mensame-63, pinkwing. SO ORDERED. (Signed by Judge Paul G. Gardephe on 6/15/2023)

MOTION for Anna Iskikian to Withdraw as Attorney. Document filed by Run-Tiger LLC.

Affidavit Affidavit in support of Motion for Withdrawal of Attorney of Record (Anna Iskikian)

(Text of Proposed Order Proposed Order for Withdrawal of Attorney of Record (Anna Iskikian))

ORDER granting 44 Motion to Withdraw as Attorney. IT IS HEREBY ORDERED the removal of Anna Iskikian as attorney for Plaintiff Run-Tiger d/b/a Run Chicken. Attorney Anna Iskikian terminated(Signed by Judge Paul G. Gardephe on 6/26/2023)

ADD PARTY FOR PLEADING. Defendants/Respondents Ningbo General Union Co., Ltd. (4), A_AIFAMY (101), Allwin Radios (104), Golger (120), MIXUNSHOP (131), Ramwans Direct (141), Guangzhou Zhimei Trading Co., LTD (245) added. Party added pursuant to 1 Complaint.Document filed by Run-Tiger LLC. Related document: 1 Complaint. (Text entry; no document attached.)

ADD PARTY FOR PLEADING. Defendants/Respondents Ningbo General Union Co., Ltd. (4), A_AIFAMY (101), Allwin Radios (104), Golger (120), MIXUNSHOP (131), Ramwans Direct (141), Guangzhou Zhimei Trading Co., LTD (245) added. Party added pursuant to [1] Complaint.Document filed by Run-Tiger LLC. Related document: [1] Complaint. (Text entry; no document attached.)

PROPOSED CONSENT ORDER. Document filed by Run-Tiger LLC.

NOTICE OF APPEARANCE by Shannon Joyce Prince on behalf of Run-Tiger LLC.

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) Guangzhou Zhimei Trading Co., LTD (245). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [48] Notice of Voluntary Dismissal, was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety;. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 48 Notice of Voluntary Dismissal, was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety;. (Text entry; no document attached.)

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANT TO THE COURT AND ALL INTERESTED PARTIES: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff Run-Tiger LLC, d/b/a/ Run-Chicken, voluntarily dismiss the following Defendant listed on the Second Amended Schedule A to the Complaint without prejudice: Guangzhou Zhimei Trading Co., LTD (245). SO ORDERED. Guangzhou Zhimei Trading Co., LTD (245) terminated. (Signed by Judge Paul G. Gardephe on 7/10/2023)

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) Ningbo General Union Co., Ltd. (4), A_AIFAMY (101), Allwin Radios (104), Golger (120), MIXUNSHOP (131), Ramwans Direct (141). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [50] Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 50 Notice of Voluntary Dismissal was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

MOTION for Christopher Tom to Withdraw as Attorney. Document filed by Run-Tiger LLC.

Affidavit in support of Motion for Withdrawal of Attorney of Record

(Text of Proposed Order for Withdrawal of Attorney of Record)

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANTS: TO THE COURT AND ALL INTERESTED PARTIES: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff Run- Tiger LLC, d/b/a/ Run-Chicken, voluntarily dismiss the following Defendants listed on the Second Amended Schedule A to the Complaint without prejudice: Golger (120), MIXUNSHOP (131), Ningbo General Union Co., Ltd. (4), Ramwans Direct (141), A_AIFAMY (101) and Allwin Radios (104). SO ORDERED. (Signed by Judge Paul G. Gardephe on 7/14/2023) Golger (120), MIXUNSHOP (131), Ningbo General Union Co., Ltd. (4), Ramwans Direct (141), A_AIFAMY (101) and Allwin Radios (104) terminated.

ORDER FOR WITHDRAWAL OF ATTORNEY OF RECORD granting 51 Motion to Withdraw as Attorney. Plaintiff's motion for withdrawal of Christopher Tom of Thoits Law as attorney of record in the above- captioned action is granted. IT IS HEREBY ORDERED the removal of Christopher Tom of Thoits Law as attorney for Plaintiff Run-Tiger d/b/a Run-Chicken. (Signed by Judge Paul G. Gardephe on 7/14/2023) Attorney Christopher Tom terminated

NOTICE OF APPEARANCE by Brittany Celia Zoll on behalf of Run-Tiger LLC.

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) Weiltestore (224). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [55] Notice of Voluntary Dismissal, was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 55 Notice of Voluntary Dismissal, was reviewed and referred to Judge Paul G. Gardephe for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANTS: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff Run-Tiger LLC, d/b/a/ Run-Chicken, voluntarily dismiss the following Defendants listed on the Second Amended Schedule A to the Complaint without prejudice: As further set forth by this Order. SO ORDERED. Weiltestore (224) terminated. (Signed by Judge Paul G. Gardephe on 8/9/2023)

NOTICE OF APPEARANCE by Christopher Tom on behalf of Run-Tiger LLC.

NOTICE OF CASE REASSIGNMENT to Judge Arun Subramanian. Judge Paul G. Gardephe is no longer assigned to the case. (Text entry; no document attached.)

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice against the defendant(s) MM Craft (132). Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [58] Notice of Voluntary Dismissal, was reviewed and referred to Judge Arun Subramanian for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANT TO THE COURT AND ALL INTERESTED PARTIES: PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. Pro. 41(a)(1)(A)(i), Plaintiff RUN-TIGER LLC, d/b/a/ RUN- CHICKEN voluntarily dismisses the following Defendant listed on Schedule A to the Complaint without prejudice: MM Craft (132) terminated. The Clerk of Court is respectfully directed to terminate defendant MM Craft from this case. SO ORDERED. (Signed by Judge Arun Subramanian on 8/31/2023)

NOTICE OF REASSIGNMENT: This case has been reassigned to the undersigned. All counsel must familiarize themselves with the Court's Individual Practices, which are available at https://nysd.uscourts.gov/hon-arun-subramanian. Unless and until the Court orders otherwise, all prior orders, dates, and deadlines shall remain in effect notwithstanding the case's reassignment. Additionally, by September 14, 2023, plaintiff is hereby ORDERED to file on ECF a letter updating the Court on the status of the case. The letter shall not exceed five (5) pages, and shall provide the following information, to the extent it is relevant, in separate paragraphs. (Signed by Judge Arun Subramanian on 8/31/2023)

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. 58 Notice of Voluntary Dismissal, was reviewed and referred to Judge Arun Subramanian for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (Text entry; no document attached.)

ORDER denying as moot [26] Motion to Seal; denying as moot [12] Motion to Seal; denying as moot [16] Motion for Leave to File Excess Pages. The motion for leave to file excess pages is DENIED AS MOOT. See ECF No. 16. The motion to seal at ECF No. 12 is also DENIED AS MOOT. The Clerk of Court is respectfully directed to terminate ECF Nos. 12, 16, and 26. SO ORDERED. (Signed by Judge Arun Subramanian on 9/11/2023)

LETTER addressed to Judge Arun Subramanian from Christopher Tom dated September 14, 2023 re: Response to the Court's August 31st Notice of Reassignment Dkt. 60. Document filed by Run-Tiger LLC.

ADD PARTY FOR PLEADING. Defendants/Respondents CHADESIEL AwesomeHome Store 17, Aiwan E-commerce Co., Ltd 102, mansor shop 129, STGH Direct 144, tdyzbao 148, usvery 150, dblt 164, dbpi 165, detu 166, gm4l 170, h0p7 172, lzx7p 174, n0uj 175, nvni 176, ok6i 177, phs1 179, pyouyig2 180, qi4q 181, v2d8 183, w9ro 186, xklv 188, anmde7769 193, dangers14 200, magic_zone 210, moli-store 212, AoZoA09 232, CHENGDUWEIYUEZHENY USHANGMAOYOUXIANGO NGSI 243, G-CHEN 244, Haikou 246, Mian yang bo yuan lai ke ji you xian gong 250, XuanMing 255, 2020WIN 256, cesar jos quijad 257, eshop1 258, liuhaijiao 261, Meng Laite trading company in Shenzhen, China 262, MUMU_WIND 263, Newtonchen 264, tangrui 269, we call it hope 270, wilkmeet 271 added. Party added pursuant to 1 Complaint.Document filed by Run-Tiger LLC. Related document: 1 Complaint. (Text entry; no document attached.)

MOTION for Shannon J. Prince to Withdraw as Attorney for Run-Tiger LLC. Document filed by Run-Tiger LLC.

Affidavit in support of Motion for Withdrawal of Attorney of Record

(Proposed Order for Withdrawal of Attorney of Record)

ORDER FOR WITHDRAWAL OF ATTORNEY OF RECORD granting 63 Motion to Withdraw as Attorney. Plaintiff's motion for withdrawal of Shannon J. Prince as attorney of record in the above-captioned action is granted. IT IS HEREBY ORDERED the removal of Shannon J. Prince as attorney for Plaintiff Run-Tiger LLC. Attorney Shannon Joyce Prince terminated. (Signed by Judge Arun Subramanian on 9/19/2023)

PROPOSED CLERK'S CERTIFICATE OF DEFAULT. Document filed by Run-Tiger LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

DECLARATION of Christopher Tom re: 65 Proposed Clerk's Certificate of Default. Document filed by Run-Tiger LLC.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

CLERK'S CERTIFICATE OF DEFAULT as to the parties listed on the attached Third Amended Schedule A. (tp) (Main Document 67 replaced on 9/29/2023)

MOTION for Default Judgment as to the Defendants identified on the Third Amended Schedule A. Document filed by Run-Tiger LLC.

MEMORANDUM OF LAW in Support re: [68] MOTION for Default Judgment as to the Defendants identified on the Third Amended Schedule A. Document filed by Run-Tiger LLC.

DECLARATION of Christopher Tom in Support re: [68] MOTION for Default Judgment as to the Defendants identified on the Third Amended Schedule A. Document filed by Run-Tiger LLC.

Exhibit 1 - Schedule A

Exhibit 2 - Complaint

Exhibit 3 - TRO

Exhibit 4 - Order Extending TRO

Exhibit 5 - Preliminary Injunction Order

Exhibit 6 - Summons Executed

Exhibit 7 - Service Emails

Exhibit 8 - Site Down Website

Exhibit 9 - Clerk's Certificate of Default

PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by Run-Tiger LLC. Proposed Default Judgment to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. [71] Proposed Default Judgment was reviewed and approved as to form. (Text entry; no document attached.)

***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. 71 Proposed Default Judgment was reviewed and approved as to form. (Text entry; no document attached.)

MOTION for Brittany Zoll to Withdraw as Attorney. Document filed by Run-Tiger LLC.

Affidavit in Support of Motion to Withdraw

Proposed Order on Withdrawal of Attorney of Record

ORDER FOR WITHDRAWAL OF ATTORNEY OF RECORD granting 72 Motion to Withdraw as Attorney. IT IS HEREBY ORDERED that Brittany Zoll is removed as attorney of record for Plaintiff RUN-TIGER LLC. Attorney Brittany Celia Zoll terminated. (Signed by Judge Arun Subramanian on 12/18/2023)

ORDER SCHEDULING DEFAULT JUDGMENT BRIEFING AND SHOW CAUSE HEARING: On October 13, 2023, Plaintiff filed a motion for a default judgment as to the Defendants identified on the Third Amended Schedule A under Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2(b). See ECF No. 68. It is hereby ORDERED that Defendants identified on the Third Amended Schedule A (hereafter "Defendants") shall file any opposition to the motion for default judgment by January 16, 2024. It is further ORDERED that Defendants appear and show cause before this Court on January 22, 2024, at 12:30 PM, why an order should not be issued granting a default judgment against Defendants. Unless and until the Court orders otherwise, the conference will be held remotely by telephone in accordance with Paragraph 3.B of the Court's Individual Rules and Practices in Civil Cases. The parties should join the conference by calling +1 646-453-4442, 67779380#. In the event that any Defendant appears or opposes the motion for default judgment prior to that date, the parties shall prepare to treat that conference as the initial pretrial conference with respect to any such appearing Defendant. It is further ORDERED that Plaintiff serve Defendants with (1) a copy of the motion for default judgment and all supporting papers; and (2) a copy of this Order by January 4, 2024. In each case, within two business days of service, Plaintiffs must file proof of such service on the docket. SO ORDERED., (Responses due by 1/16/2024)Telephonic Show Cause Hearing set for 1/22/2024 at 12:30 PM before Judge Arun Subramanian. (Signed by Judge Arun Subramanian on 1/03/2024)

AFFIDAVIT OF SERVICE of the Court's January 3, 2024 Order Scheduling Default Judgment Briefing and Show Cause Hearing (Dkt. 74) and Plaintiff's Default Motion Papers (Dkts. 68-71) served on Defaulting Defendants as identified in the Third Amended Schedule A on January 3, 2024. Service was made by Email. Document filed by Run-Tiger LLC.

Minute Entry for proceedings held before Judge Arun Subramanian: Default Hearing held on 1/22/2024. Christopher Tom present for Plaintiff. (Court Reporter Kristen Carannante) (Text entry; no document attached.)

PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by Run-Tiger LLC. Proposed Default Judgment to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. 76 Proposed Default Judgment was reviewed and approved as to form. (Text entry; no document attached.)

LETTER addressed to Judge Arun Subramanian from Christopher Tom dated February 2, 2024 re: Amended Proposed Default Judgment [Dkt. 76]. Document filed by Run-Tiger LLC.

MEMO ENDORSEMENT on re: 77 Letter filed by Run-Tiger LLC. ENDORSEMENT: The proposed judgment still has the Court order non-parties, like Amazon, to take certain actions. See, e.g., Paragraphs 3-30. By Wednesday, February 14, 2024, plaintiff should submit a letter explaining to the Court how it has jurisdiction to order these non-parties to take the actions detailed in the judgment. SO ORDERED. (Signed by Judge Arun Subramanian on 2/2/2024)

PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by Run-Tiger LLC. Proposed Default Judgment to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. [79] Proposed Default Judgment was reviewed and approved as to form. (Text entry; no document attached.)

LETTER addressed to Judge Arun Subramanian from Christopher Tom dated February 13, 2024 re: Second Amended Proposed Default Judgment [Dkt. 79]. Document filed by Run-Tiger LLC.

MEMO ENDORSEMENT on re: [80] Letter filed by Run-Tiger LLC. ENDORSEMENT: The second amended proposed judgment still has the Court order non-parties, like VeriSign, Inc., to take certain actions. See Paragraph 2. By Friday, February 16, 2024, plaintiff should submit a letter explaining to the Court how it has jurisdiction to order non-parties to take the actions detailed in the judgment. Or the paragraph can be removed and the Court will execute the judgment. SO ORDERED. (Signed by Judge Arun Subramanian on 2/13/2024)

PROPOSED DEFAULT JUDGMENT pursuant to FRCP 55(b)(2). Document filed by Run-Tiger LLC. Proposed Default Judgment to be reviewed by Clerk's Office staff.

***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. [82] Proposed Default Judgment was reviewed and approved as to form. (Text entry; no document attached.)

DEFAULT JUDGMENT: THIS COURT FURTHER FINDS that Defaulting Defendants are liable for willful federal trademark infringement and counterfeiting (15 U.S.C. § 1114), false designation of origin (15 U.S.C. § 1125(a)), copyright infringement (17 U.S.C. § 101 et seq.), and/or violation of unfair competition under New York common law. IT IS HEREBY ORDERED that Plaintiffs Motion for Entry of Default and Default Judgment is GRANTED in its entirety, that Defaulting Defendants are deemed in default and that this Default Judgment is entered against Defaulting Defendants. The five thousand-dollar ($5,000) bond posted by Plaintiff, including any interest minus the registry fee, will be released to Plaintiff or their counsel upon notice to the Court that all non-defaulting defendants have been dismissed from the case. The Clerk of the Court is directed to return the bond previously deposited with the Clerk of the Court to Plaintiff or its counsel once such notice is provided., Motions terminated: 68 MOTION for Default Judgment as to the Defendants identified on the Third Amended Schedule A filed by Run-Tiger LLC. (Signed by Judge Arun Subramanian on 2/15/2024) (ama) Transmission to Finance Unit (Cashiers) for processing.

AO 121 FORM COPYRIGHT - CASE TERMINATED- SUBMITTED. In compliance with the provisions of 17 U.S.C. 508, the Register of Copyrights is hereby advised that a final decision was rendered on 2/15/2024 in a court action filed on the following copyright(s) in the U.S. District Court Southern District of New York. Form e-mailed to Register of Copyrights.

***NOTICE TO COURT REGARDING PROPOSED DEFAULT JUDGMENT. Document No. 82 Proposed Default Judgment was reviewed and approved as to form. (Text entry; no document attached.)

NOTICE of Satisfaction of Judgment of Defendant No. 270 (we call it hope) re: 83 Default Judgment, Add and Terminate Parties, Terminate Motions. Document filed by Run-Tiger LLC.

MOTION for Disbursement of Funds / Request for Entry of Disbursement Order Releasing Bond. Document filed by Run-Tiger LLC.

Proposed Order (Proposed Disbursement Order)