RESPONSE TO ORDER TO SHOW CAUSE re [16] Order, by Dana Doe.

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1:Exhibit 1

PAPERLESS ORDER TO SHOW CAUSE. In the Amended Complaint, Plaintiff alleges that the 32 Individuals, Partnerships, and Unincorporated Associations Identified in the Schedule "A" ("Defendants") have engaged in trademark infringement in this district through the use of the e-commerce stores identified in the Schedule A. [ECF Nos. 12, 12-1]. However, Plaintiff's conclusory allegations that the claims against Defendants arise "out of the same transaction, occurrence, or series of transactions or occurrences" and "are all transactionally related" without further explanation is not sufficient. [ECF No. 12 ¶¶ 37, 42 ]. Federal Rule of Civil Procedure 20(a) permits joinder of defendants in the same action where the plaintiff's claims against the defendants arise "out of the same transaction, occurrence, or series of transactions or occurrences," and "any question of law or fact common to all defendants will arise in the action." Fed. R. Civ. P. 20(a)(2)(A)-(B). The Eleventh Circuit has defined "transaction or occurrence" as "all logically related events entitling a person to institute a legal action against another." Alexander v. Fulton Cnty., Ga., 207 F.3d 1303, 1323 (11th Cir. 2000) (internal citations omitted), overruled on other grounds by Manders v. Lee, 338 F.3d 1304 (11th Cir. 2003). In intellectual property cases, a plaintiff cannot satisfy Rule 20's requirements by merely alleging that multiple defendants have infringed the same patent or trademark. Omega, SA v. Individuals, Bus. Entities, & Unincorporated Associations Identified on Schedule "A", 650 F. Supp. 3d 1349, 1352 (S.D. Fla. 2023). Accordingly, on or before May 20, 2025, Plaintiff shall file a memorandum showing why joinder of these 32 Defendants is proper. Signed by Judge Darrin P. Gayles on 5/6/2025. (mp02)

SYSTEM ENTRY - Docket Entry 15 [motion] restricted/sealed until further notice. (745753)

SYSTEM ENTRY - Docket Entry 14 [misc] restricted/sealed until further notice.

SYSTEM ENTRY - Docket Entry 13 [misc] restricted/sealed until further notice. (745753)

SYSTEM ENTRY - Docket Entry 12 [misc] restricted/sealed until further notice. (745753)

Motions terminated per Order DE 10 : 7 MOTION to Seal per Local Rule 5.4 filed by Dana Doe.

PAPERLESS ORDER denying Plaintiff's Motion for Leave to Temporarily Proceed Under a Pseudonym [6]. Plaintiff has not established "a substantial privacy right which outweighs the customary and constitutionally-embedded presumption of openness in judicial proceedings." In re: Chiquita Brands Int'l, Inc., 965 F.3d 1238, 1247 (11th Cir. 2020). Moreover, without knowing Plaintiff's identity, the Court cannot determine whether it has a conflict in adjudicating this action. However, Plaintiff may file under seal an amended complaint which includes Plaintiff's identity. At that time, Plaintiff may also file under seal its Schedule A and its proposed summonses pending service and the resolution of Plaintiff's forthcoming request for ex parte relief. Within seven (7) days of the Court ruling on Plaintiff's request for ex parte relief, Plaintiff shall (1) move to unseal Schedule A and (2) add all Defendants as parties through CM-ECF. Signed by Judge Darrin P. Gayles on 4/10/2025. (mp02)

MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Incorporated Memorandum of Law by Dana Doe.

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1:Text of Proposed Order
2:Exhibit 1
3:Declaration of Joel B. Rothman

NOTICE OF COURT PRACTICE. Unless otherwise specified by the Court, every motion shall be double-spaced in Times New Roman 12-point typeface. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Failure to comply with ANY of these procedures may result in the imposition of appropriate sanctions, including but not limited to, the striking of the motion or dismissal of this action. Signed by Judge Darrin P. Gayles on 4/2/2025. (mp02)

MOTION to Seal per Local Rule 5.4 by Dana Doe.

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1:Text of Proposed Order

MOTION for Leave to Proceed Under Pseudonym Temporarily and Incorporated Memorandum of Law by Dana Doe.

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1:Declaration of Joel B. Rothman
2:Exhibit 1
3:Exhibit 2
4:Exhibit 3
5:Exhibit 4
6:Exhibit 5
7:Exhibit 6
8:Exhibit 7
9:Exhibit 8
10:Exhibit 9
11:Text of Proposed Order

Amended Complaint/Amended Notice of Removal

NOTICE OF COURT PRACTICE. Unless otherwise specified by the Court, every motion shall be double-spaced in Times New Roman 12-point typeface. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Failure to comply with ANY of these procedures may result in the imposition of appropriate sanctions, including but not limited to, the striking of the motion or dismissal of this action. Signed by Judge Darrin P. Gayles on 3/24/2025. (mp02)

FORM AO 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE

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1:Complaint

Clerks Notice of Judge Assignment to Judge Darrin P. Gayles. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (ar24)

COMPLAINT against The Individuals, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18300311, filed by Dana Doe.

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1:(Civil Cover Sheet)