ENTERED JUDGMENT Signed by the courtroom deputy on 04/01/2022. Emailed notice

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 04/01/2022. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: On review of the Plaintiffs' motion for default judgment 27, the motion is granted in light of the absence of a timely answer. With the facts established by the default, willfulness is proven and a permanent injunction will be entered. The statutory damages request of $15,000 is appropriate. A separate AO-450 final judgment will be entered. The tracking status hearing of 04/08/2022 is vacated. Civil case terminated. Emailed notice

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for entry of default 27

附件：

1:(Declaration of Keith A. Vogt)
2:Exhibit 2
3:Exhibit 1

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for entry of default and Default Judgment Against the Defendants Identified in Schedule A

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 03/07/2022. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion 23 for preliminary injunction is granted, given the continued circumstances that justified entry of the TRO. The answer deadline is 03/24/2022, R. 24, so the parties shall file the joint initial status report by 03/31/2022. If the Defendant has not answered or responded as of 03/25/2022, then the Court deems the Defendant in default and the Plaintiff shall file a motion for default judgment on 03/31/2022. The tracking status hearing of 03/18/2022 is reset to 04/08/2022 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

SUMMONS Returned Executed by Khara Inc., Ground Works Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 3/3/2022, answer due 3/24/2022.

附件：

1:(Declaration of Service)

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for preliminary injunction 22

附件：

1:(Exhibit 1, Declaration of Keith Vogt)
2:Declaration of Keith A. Vogt

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for preliminary injunction

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the facts that warranted entry of the initial TRO, the Plaintiffs' extension motion on the TRO [20] is granted to 03/18/2022. The tracking status hearing of 03/04/2022 is reset to 03/18/2022 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 the joint initial status report by 03/11/2022, or the Plaintiffs shall file a preliminary-injunction motion or other motion for appropriate relief. Emailed notice

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for extension of time for Temporary Restraining Order

SURETY BOND in the amount of $ 10,000.00 posted by Ground Works Co., Ltd., Khara Inc (Document not scanned).

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A"

REDACTED SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 02/18/2022. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 02/18/2022. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion 13 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. 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). 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 10 for leave to file under seal is granted in light of the asset-restraint goal. The Plaintiff emailed a redacted version of the TRO, which will be entered publicly. The Plaintiff's motion 13 for electronic service of process is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 03/04/2022 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion), if appropriate, no later than 02/28/2022. Emailed notice

SEALED EXHIBIT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Sealed Exhibit 2, Declaration of Yasuhiro Kamimura regarding memorandum in support of motion, 14

附件：

1:Exhibit 2-2
2:Exhibit 2-1

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for leave to file 10, motion for leave to file excess pages 12 in support of 13 Exparte Motion

附件：

1:Exhibit 1, of Yasuhiro Kamimura's declaration
2:Declaration of Yasuhiro Kamimura
3:Exhibit 1-4, of Keith A. Vogt's declaration
4:Declaration of Keith A. Vogt

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file excess pages

SEALED DOCUMENT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Amended Schedule A to Complaint (1)

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file under seal

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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.

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yi Bu

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Keith A. Vogt

CIVIL Cover Sheet

SEALED DOCUMENT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Schedule A to Complaint [1]

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 402, receipt number 0752-19154226.

附件：

1:Exhibit 3
2:Exhibit 2
3:Exhibit 1
4:Exhibit 4