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1
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2025-04-04 |
COMPLAINT filed by TV Tokyo Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-23303233. |
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Exhibit 1 |
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(Exhibit 2) |
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2
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2025-04-04 |
CIVIL Cover Sheet |
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3
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2025-04-04 |
ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Michael A. Hierl |
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4
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2025-04-04 |
ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by William Benjamin Kalbac |
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5
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2025-04-04 |
ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Robert Payton Mcmurray |
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6
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2025-04-04 |
ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by John Wilson |
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7
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2025-04-04 |
MOTION by Plaintiff TV Tokyo Corporation to seal document Plaintiff's Motion for Leave to File Under Seal |
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8
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2025-04-04 |
SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Sealed Schedule A |
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9
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2025-04-04 |
NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation |
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10
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2025-04-04 |
Notice of Claims Involving Trademarks by TV Tokyo Corporation |
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CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2). |
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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. |
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11
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2025-04-07 |
MAILED trademark report to Patent Trademark Office, Alexandria VA. |
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12
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2025-04-07 |
MAILED to plaintiff(s) counsel Lanham Mediation Program materials. |
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13
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2025-04-07 |
MAILED copyright report to Registrar, Washington DC. |
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[+]
14
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2025-04-08 |
MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 05/02/2025 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the ***ATTACHED*** status report requirements (do ***not*** use templates from other cases) by 05/23/2025. Plaintiff must still file the report even if Defendants have not responded to requests to craft a joint report. If not all Defendants have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel (or the parties, if proceeding pro se) must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel (or the party, if proceeding pro se) must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice |
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(Status Report Requirements) |
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15
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2025-05-01 |
MINUTE entry before the Honorable Edmond E. Chang: The Court accelerates the joint initial status report deadline to 05/09/2025. Also, on review of the complaint and Schedule A, the Court raises the propriety of joinder of the 66 Defendants. The Plaintiff shall review the opinion in Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182, 18789 (N.D. Ill. 2020), and file a supplemental memorandum addressing the propriety of joinder by 05/09/2025. In lieu of the supplemental memorandum, by the same deadline, Plaintiff may file an amended complaint with (a) one defendant or (b) a subset of the defendants along with a memo explaining why joinder of those defendants is proper. The tracking status hearing of 05/02/2025 is reset to 05/16/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice |
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16
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2025-05-09 |
AMENDED complaint by TV Tokyo Corporation against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto |
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Exhibit 1 |
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(Exhibit 2) |
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17
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2025-05-09 |
SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Amended Schedule A |
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18
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2025-05-09 |
STATUS Report Initial Status Report by TV Tokyo Corporation |
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19
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2025-05-12 |
MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff filed an Amended Complaint with one Defendant. R. 16, 17. On review of the status report, R. 18, the Plaintiff shall file the TRO motion referred to in the report by 05/14/2025. The tracking status hearing of 05/16/2025 for Judge Chang is reset to 05/23/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice |
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20
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2025-05-14 |
MOTION by Plaintiff TV Tokyo Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation |
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21
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2025-05-14 |
MOTION by Plaintiff TV Tokyo Corporation for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication |
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22
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2025-05-14 |
MEMORANDUM by TV Tokyo Corporation in support of motion for temporary restraining order, 21 |
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Declaration Saiki Declaration |
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Exhibit 1 |
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Exhibit 2 |
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Declaration Hierl Declaration |
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Exhibit Hierl Exhibit 1 |
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Exhibit Hierl Exhibit 2 |
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Exhibit Hierl Exhibit 3 |
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(Exhibit Hierl Exhibit 4) |
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23
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2025-05-14 |
SEALED EXHIBIT by Plaintiff TV Tokyo Corporation Exhibit 3 to Saiki Declaration regarding memorandum in support of motion, 22 |
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24
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2025-05-22 |
MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion 21 for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 15 U.S.C. § 1117(a), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint (the same goes for copyright claims). Indeed, trademark owners need only "prove defendant's sales only; defendant must prove all elements of costs or deduction claimed." 15 U.S.C. § 1117(a). (Again, the same principle applies in copyright cases. 17 U.S.C. §504(b).) To the extent that the restraint might be too broad, the Defendant may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion 7 for leave to file under seal is granted in light of the asset-restraint goal. By 05/29/2025, The Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the names of Defendants and omitting Amended Schedule A). The Plaintiff's motion 20 for extra pages is granted. The tracking status hearing of 05/23/2025 is reset to 06/06/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 05/30/2025. Emailed notice |
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25
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2025-05-22 |
SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 05/22/2025. Emailed notice |
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27
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2025-05-29 |
Surety BOND in the amount of $ 1,000 posted by TV Tokyo Corporation. (Document not Imaged) |
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26
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2025-05-30 |
MOTION by Plaintiff TV Tokyo Corporation for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order |
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28
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2025-06-02 |
MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the initial TRO, the extension motion 26 is granted through 06/19/2025. The tracking status hearing of 06/06/2025 is reset to 06/20/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the Plaintiff shall file a status report by 06/13/2025 and, if appropriate, the preliminary injunction motion by 06/13/2025. Emailed notice |
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30
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2025-06-13 |
SUMMONS Issued (Court Participant) as to chenshufang06. |
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31
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2025-06-13 |
ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Elizabeth Aubree Miller |
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32
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2025-06-13 |
MOTION by Plaintiff TV Tokyo Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction |
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33
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2025-06-13 |
MEMORANDUM by TV Tokyo Corporation in support of motion for preliminary injunction 32 |
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34
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2025-06-13 |
DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 32 |
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35
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2025-06-13 |
SUMMONS Returned Executed by TV Tokyo Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 6/13/2025, answer due 7/4/2025. |
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36
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2025-06-13 |
CERTIFICATE of Service by Elizabeth Aubree Miller on behalf of TV Tokyo Corporation |
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37
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2025-06-13 |
STATUS Report by TV Tokyo Corporation |
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38
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2025-06-16 |
SUMMONS Returned Executed by TV Tokyo Corporation |
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39
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2025-06-16 |
MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction is granted. Given the answer deadline of 07/07/2025, R. 35, the tracking status hearing of 06/20/2025 is reset to 07/25/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 07/16/2025. If the Defendant does not answer by the response deadline, then the Defendant shall be deemed in default as of 07/08/2025, and the Plaintiffs shall file the motion for default judgment by 07/16/2025. Mailed notice. |
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40
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2025-06-16 |
PRELIMINARY INJUNCTION Order Signed by the Honorable Edmond E. Chang on 6/16/2025. Mailed notice. |
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41
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2025-07-15 |
MOTION by Plaintiff TV Tokyo Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A |
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(Exhibit A) |
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42
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2025-07-15 |
MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment 41 |
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Exhibit 1 |
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(Exhibit 2) |
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[+]
43
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2025-07-15 |
DECLARATION of Michael A. Hierl regarding motion for default judgment 41 |
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(Exhibit Hierl Exhibit 1) |
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44
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2025-07-15 |
NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment 41 before Honorable Edmond E. Chang on 7/22/2025 at 08:30 AM. |
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45
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2025-07-17 |
MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely response to the amended complaint, the motion for default judgment 41 is granted. Judgment shall be entered in favor of the Plaintiff and against the Defendant in the amount of one-hundred thousand dollars ($100,000). Given the finding of willfulness established by the default, a permanent injunction will be entered. The status hearing of 07/25/2025 is vacated. The one thousand dollar ($1,000) surety bond posted by Plaintiff is hereby released via certified mail to counsel of record for Plaintiff, Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602. Civil case terminated. Emailed notice |
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46
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2025-07-17 |
FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 07/17/2025. Emailed notice |
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47
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2025-07-17 |
ENTERED JUDGMENT Signed by the courtroom deputy on 07/17/2025. Emailed notice |
