STATEMENT by Akamatsu Takayoshi Plaintiff's Statement Relating to the October 7, 2022 Minute Order [Dkt. No. 35]

MINUTE entry before the Honorable Steven C. Seeger: On August 4, 2022, Plaintiff filed a complaint against a list of 210 defendants on an accompanying Schedule A. (Dckt. No. 7) Then, five days later, on August 9, 2022, Plaintiff filed an amended complaint against only 3 defendants, and dropped the other 207 defendants. By October 11, 2022, Plaintiff's counsel must file a statement explaining that maneuver. Why did you sue 210 defendants, and then dismiss 207 of the 210 defendants five days later? Did Plaintiff later sue those other 207 defendants in another lawsuit? If so, in what lawsuit (meaning what case and case number)? The Court expects candor from counsel. The filing must be signed by all counsel of record, and thus must certify that the response is accurate within the meaning of the Federal Rules. The closure of this case does not impair counsel's obligation to comply with this Order. Mailed notice

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff filed a notice of dismissal of the claims against all remaining defendants, which is self-effectuating under Rule 41(a)(1)(A)(i). (Dckt. No. 33) The case is closed. Civil case terminated. Mailed notice.

NOTICE of Voluntary Dismissal by Akamatsu Takayoshi Plaintiff's Notice of Voluntary Dismissal Without Prejudice of All Remaining Defendants

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion to seal (Dckt. No. 6) is hereby granted. Plaintiff's motion for excess pages (Dckt. No. 9) is hereby granted. Plaintiff's motion for a temporary restraining order (Dckt. No. 10) is hereby granted in part as stated in the accompanying order. Temporary Restraining Order to follow. For now, the Court is granting an asset freeze. But this Court is inclined to lift the asset freeze at a later time unless Plaintiff later seeks equitable monetary relief (like an accounting of profits) or unless Plaintiff can point this Court to a statute that expressly authorizes an asset freeze in connection with statutory damages. Plaintiff must effectuate service of process by October 7, 2022. Responses to the complaint are due by October 21, 2022. Motions for default and default judgment are due by October 24, 2022. Responses are due by October 27, 2022. A failure to comply will lead to dismissal. The Court directs counsel to serve a copy of this Order and any forthcoming motion on Defendants, and file a certificate of service. Mailed notice.

MEMORANDUM by Akamatsu Takayoshi Plaintiff's Supplemental Memorandum in Support of a Pre-Judgment Asset Restraint

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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1:(Trademarks)

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's motion for an ex parte temporary restraining order (Dckt. No. 10). The proposed minute order includes a request for an asset freeze. By August 19, 2022, Plaintiff must file a statement and point to the statutory provision that gives this Court the power to impose an asset freeze at the outset of the case. If Plaintiff cannot point to a specific statutory provision, then Plaintiff must address how its request for an asset freeze is consistent with Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999). In its memo, Plaintiff argues that "[c]ourts have the inherent authority to issue a prejudgment asset restraint when plaintiff's complaint seeks relief in equity." See Mem., at 27. In Grupo Mexicano, the Supreme Court held that a district court has "no authority to issue a preliminary injunction preventing [a defendant] from disposing of their assets pending adjudication of [plaintiff's] contract claim for money damages." Id. at 333. The Supreme Court adhered to the long-standing rule that "a judgment establishing the debt was necessary before a court of equity would interfere with the debtor's use of his property." Id. at 321. "However, the [Grupo] [C]ourt specifically noted that a restraint on assets was still proper if a suit sought equitable relief." See CSC Holdings, Inc. v. Redisi, 309 F.3d 988, 996 (7th Cir. 2002) (citing Grupo, 527 U.S. at 333; Deckert v. Independence Shares Corp., 311 U.S. 282, 288 (1940)). "[A]s a general matter [] prejudgment asset restraints are not proper simply to establish a fund from which a later award of money damages can be satisfied." See Banister v. Firestone, 2018 WL 4224444, at *9 (N.D. Ill. 2018). An equitable restraint at the outset of the case might be doable if Plaintiff obtained equitable monetary relief at the end of the day, like an accounting of profits. See Deckers Outdoor Corp. v. Unincorporated Associations Identified on Schedule A, 2013 WL 12314399 (N.D. Ill. 2013). But as a practical matter, in Schedule A cases, that recovery almost never happens, if at all. Instead, plaintiffs rush into court, seek and obtain an asset freeze, obtain a default judgment, and then ask district courts to unfreeze the money and award statutory damages, not equitable relief. In that scenario, it is not clear to this Court that it would be appropriate to use any frozen funds for any recovery of statutory damages, because statutory damages are a remedy at law, not a remedy in equity. If Plaintiff believes that it is appropriate for this Court to freeze funds at the outset of the case, and then use those funds to recover statutory damages (not equitable monetary relief) at the end of the case, then Plaintiff must explain why. Mailed notice

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Amended Schedule A

AMENDED complaint by Akamatsu Takayoshi against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

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1:(Exhibit 1-3)

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Steven C. Seeger for all further proceedings pursuant to 28 USC 294(b). Honorable Joan H. Lefkow no longer assigned to the case. Signed by Executive Committee on 8/4/2022.

Notice of Claims Involving Trademarks by Akamatsu Takayoshi

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 13 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 12 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 11 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 10 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 9 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 8 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 7 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 6 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 5 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 4 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 3 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 2 of Takayoshi Declaration

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Exhibit 4 Part 1 of Takayoshi Declaration

MEMORANDUM by Akamatsu Takayoshi in support of motion for temporary restraining order, 10

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1:Declaration Takayoshi Declaration
2:Exhibit 1-3
3:Declaration Hierl Declaration
4:Exhibit Hierl Exhibit 1
5:Exhibit Hierl Exhibit 2
6:(Exhibit Hierl Exhibit 3)

MOTION by Plaintiff Akamatsu Takayoshi for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Domain Names, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MOTION by Plaintiff Akamatsu Takayoshi for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

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.

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Akamatsu Takayoshi

SEALED DOCUMENT by Plaintiff Akamatsu Takayoshi Sealed Schedule A

MOTION by Plaintiff Akamatsu Takayoshi to seal document Plaintiff's Motion for Leave to File Under Seal

ATTORNEY Appearance for Plaintiff Akamatsu Takayoshi by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Akamatsu Takayoshi by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Akamatsu Takayoshi by Michael A. Hierl

CIVIL Cover Sheet

COMPLAINT filed by Akamatsu Takayoshi; Jury Demand. Filing fee $ 402, receipt number AILNDC-19711317.

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1:(Exhibit 1-3)