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08/21/25 Page 1 of 32 PageID \\#:1  \nIN THE UNITED STATES DISTRICT COURT  \nFOR THE NORTHERN DISTRICT OF ILLINOIS  \nEASTERN DIVISION  \nCase No. 25-cv-10020  \nCOMPLAINT  \nMob Entertainment, Inc. (“Plaintiff” or “Poppy Playtime”) hereby brings the present action against the Partnerships and Unincorporated Associations identified on Schedule A attached hereto (collectively,“Defendants”) and alleges as follows:  \nI. JURISDICTION AND VENUE  \n1. This Court has original subject matter jurisdiction over the claims in this action pursuant to the provisions of the Lanham Act, 15 U.S.C. § 1051, et seq., the Copyright Act 17  \nU.S.C. § 501, et seq., 28 U.S.C. § 1338(a)–(b) and 28 U.S.C. § 1331.  \n2. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, and this Court may properly exercise personal jurisdiction over Defendants since each of the Defendants directly targets business activities toward consumers in the United States, including Illinois, through at least the fully interactive e-commerce stores 1 operating under the seller aliases identified in Schedule A attached hereto (the “Seller Aliases”) . Specifically, Defendants have targeted sales to  \n1 The e-commerce store URLs are listed on Schedule A hereto under the Online Marketplaces.  \nCase: 1:25-cv-10020 Document \\#: 1 Filed: 08/21/25 Page 2 of 32 PageID \\#:2  \nIllinois residents by setting up and operating e-commerce stores that target United States consumers using one or more Seller Aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars and/or funds from U.S. bank accounts and, on information and belief, have sold products using infringing and counterfeit versions of Plaintiff’s federally registered trademarks and/or unauthorized copies of Plaintiff’s federally registered copyrighted works (collectively, the “Unauthorized Poppy Playtime Products”) to residents of Illinois. Each of the Defendants is committing tortious acts in Illinois, is engaging in interstate commerce, and has wrongfully caused Plaintiff substantial injury in the State of Illinois.  \nII. INTRODUCTION  \n3. This action has been filed by Plaintiff to combat e-commerce store operators who trade upon Plaintiff’s reputation and goodwill by selling and/or offering for sale Unauthorized Poppy Playtime Products. Defendants create e-commerce stores operating under one or more Seller Aliases that are advertising, offering for sale, and selling Unauthorized Poppy Playtime Products to unknowing consumers. Defendants’ activities, occurring at the same time and in the same retail space and manner as one another, blend together to create a single negative impression on consumers such that they constitute the same occurrence or series of occurrences. Defendants attempt to avoid and mitigate liability by operating under one or more Seller Aliases to conceal both their identities and the full scope and interworking of their counterfeiting operation. Plaintiff is forced to file this action to combat Defendants’ counterfeiting of its registered trademarks and infringement of its registered copyrighted works, as well as to protect unknowing consumers from purchasing Unauthorized Poppy Playtime Products over the internet. Plaintiff has been and continues to be irreparably damaged through consumer confusion, dilution, and tarnishment ofits  \nCase: 1:25-cv-10020 Document \\#: 1 Filed: 08/21/25 Page 3 of 32 PageID \\#:3  \nvaluable trademarks and infringement of its copyrighted works as a result of Defendants’ actions and seeks injunctive and monetary relief.  \nIII. THE PARTIES  \nPlaintiff  \n4. Mob Entertainment, Inc. is a corporation organized and existing under the laws of the State of Delaware, having its principal place of business in St. Louis, Missouri.  \n5. Plaintiff is a digital entertainment company that creates and distributes high quality animated content across multiple platforms. Plaintiff’s focus is on the production and distribution o","cbCaig4NQMq5zSwH","https://ap.wps.com/l/cbCaig4NQMq5zSwH","pdf",1549291,32,"English","# Jurisdiction and Venue\n# Introduction\n# The Parties","[{\"question\":\"What is the main legal purpose of the complaint?\",\"answer\":\"Mob Entertainment, Inc. brings the action to combat e-commerce operators selling or offering for sale unauthorized Poppy Playtime products that allegedly counterfeit trademarks and infringe copyrighted works.\"},{\"question\":\"Why does the court venue in Illinois appear to be proper?\",\"answer\":\"The complaint alleges defendants target business activities toward U.S. consumers, including Illinois, through interactive e-commerce stores that ship to Illinois and sell unauthorized products to residents.\"},{\"question\":\"What relief is the plaintiff seeking?\",\"answer\":\"The plaintiff seeks injunctive relief and monetary damages based on alleged irreparable harm through consumer confusion, dilution, and tarnishment.\"}]","Mob Entertainment, Inc. - Complaint (Case No. 25-cv-10020) | PDF",81]