Alibaba Group Holding Limited v. Alibabacoin Foundation et al
| Alibaba Group Holding Limited |
| Jason Daniel Paul Philip, Alibabacoin Foundation LLC, Alibabacoin Foundation a/k/a ABBC Foundation, Hasan Abbas, ABBC Block Chain IT Solutions LLC, Alibabacoin General Trading FZE, Alibabacoin Foundation and ABBC Foundation |
| 1:2018cv02897 |
| April 2, 2018 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| New York |
| J Paul Oetken |
| Trademark |
| 15 U.S.C. § 1114 |
| Plaintiff |
Docket Report
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This docket was last retrieved on December 12, 2018. A more recent docket listing may be available from PACER.
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| Filing 146 CASE MANAGEMENT PLAN: All parties do not consent to conducting all further proceedings before a United States Magistrate Judge, including motions and trial. The parties have conferred pursuant to Fed. R. Civ P. 26(f). This case is to be tried to a jury. Counsel for the parties have conferred and their present best estimate of the length of trial is five days. Deposition due by 5/31/2019. Fact Discovery due by 5/31/2019. Expert Discovery due by 7/31/2019. Case Management Conference set for 6/4/2019 at 11:30 AM before Judge J. Paul Oetken. Ready for Trial by 10/21/2019. (Signed by Judge J. Paul Oetken on 12/11/2018) (kv) |
| Filing 145 NOTICE OF APPEARANCE by Colin James Steele on behalf of Alibaba Group Holding Limited. (Steele, Colin) |
| Minute Entry for proceedings held before Judge J. Paul Oetken: Initial Pretrial Conference held on 12/11/2018. Next conference scheduled for 6/4/2019 at 11:30 am. (bh) |
| Filing 144 PROPOSED CASE MANAGEMENT PLAN. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
Filing 143
ORDER: Initial Conference set for 12/11/2018 at 12:15 PM in Courtroom 706, 40 Centre Street, New York, NY 10007 before Judge J. Paul Oetken. (Signed by Judge J. Paul Oetken on 11/26/2018) (rro)
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| Filing 142 ANSWER to #1 Complaint,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Dabney, James) |
| Filing 141 NOTICE OF INTERLOCUTORY APPEAL from #137 Memorandum & Opinion,,,,,,,, #140 Memorandum & Opinion,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. Filing fee $ 505.00, receipt number ANYSDC-15932812. Form C and Form D are due within 14 days to the Court of Appeals, Second Circuit. (Dabney, James) |
| Transmission of Notice of Appeal and Certified Copy of Docket Sheet to US Court of Appeals re: #141 Notice of Interlocutory Appeal. (tp) |
| Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files for #141 Notice of Interlocutory Appeal, filed by Alibabacoin Foundation LLC, ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Jason Daniel Paul Philip, Alibabacoin General Trading FZE were transmitted to the U.S. Court of Appeals. (tp) |
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Filing 140
OPINION AND ORDER: re: #33 MOTION to Dismiss Plaintiff's Complaint filed by Alibabacoin Foundation LLC, ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Jason Daniel Paul Philip, Alibabacoin General Trading FZE. Accordingly, Defendants' motion to dismiss is DENIED. The Clerk of Court is directed to close the motion at Docket Number 33. SO ORDERED. (Signed by Judge J. Paul Oetken on 11/07/2018) (ama)
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| Filing 139 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a conference proceeding held on 10/5/18 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) |
| Filing 138 TRANSCRIPT of Proceedings re: conference held on 10/5/2018 before Judge J. Paul Oetken. Court Reporter/Transcriber: Carol Ganley, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 11/15/2018. Redacted Transcript Deadline set for 11/26/2018. Release of Transcript Restriction set for 1/23/2019.(McGuirk, Kelly) |
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Filing 137
OPINION AND ORDER: re: #121 LETTER MOTION to Compel Defendants to Produce Documents addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 10, 2018 filed by Alibaba Group Holding Limited. For the foregoing reasons, Alibaba's renewed application for a preliminary injunction is GRANTED, and its motion to compel discovery is DENIED as moot. Accordingly, this Court hereby (1) enjoins Defendants from using the ALIBABA Marks, as Alibaba has defined that term in its application for a preliminary injunction, alone or in combination with any words, terms, designations, marks, or designsas well as any mark, image, or depiction that is confusingly similar to or likely to impair the distinctiveness of the ALIBABA Marks-anywhere in the United States, including in connection with the provision of products or services to internet users located in the United States, and enjoins Defendants' employees, owners, agents, officers, directors, attorneys, representatives, affiliates, subsidiaries, successors, and assignsand all those in active concert or participation with them or having knowledge of the causes of action-from enabling or assisting Defendants in such uses, and (2) enjoins Defendants from making false or misleading statements concerning the ALIBABA Marks in the sale, advertising, or promotion of Defendants' goods and services to any parties located in the United States, alone or in combination with any words, terms, designations, marks, or designs, as well as any mark, image, or depiction that is confusingly similar or likely to impair the ALIBABA Marks, and enjoins Defendants' employees, owners, agents, officers, directors, attorneys, representatives, affiliates, subsidiaries, successors, and assignsand all those in active concert or participation with them or having knowledge of the causes of action-from making or assisting Defendants in making such statements. The Clerk of Court is directed to close the motion at Docket Number 121. SO ORDERED. (Signed by Judge J. Paul Oetken on 10/22/2018) (ama)
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| Filing 136 LETTER addressed to Judge J. Paul Oetken from Lucas V.M. Bento dated October 10, 2018 re: Company Announcement. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 Company Announcement)(Bento, Lucas) |
| Minute Entry for proceedings held before Judge J. Paul Oetken: Status Conference held on 10/5/2018. Order to follow. (bh) |
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Filing 135
ENDORSED LETTER: addressed to Judge J. Paul Oetken from James W. Dabney dated 9/21/2018 re: We have filed today a redaction version of this declaration (Dkt. 133) and request that the original, unredacted version be removed from the public record. ENDORSEMENT: Defendants' request that the unredacted declaration of Jason Daniel Paul Philip be placed under seal is granted. The Clerk of Court is directed to place the entry at Docket Number 131 under seal. SO ORDERED. (Signed by Judge J. Paul Oetken on 9/21/2018) (ama) Transmission to Sealed Records Clerk for processing.
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Filing 134
ORDER: The Court is in receipt of Plaintiffs renewed application for a preliminary injunction (Dkt. No. 119), Defendants opposition thereto (Dkt. No. 130), and Plaintiffs reply (Dkt. No. 132), as well as Plaintiffs motion to compel production (Dkt. No. 121), Defendants response in opposition (Dkt. No. 125), and Plaintiffs reply (Dkt. No. 127). The parties are directed to appear for a conference on these filings on October 5, 2018, at 3:15 p.m. in Courtroom 706 of the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007. SO ORDERED. (Status Conference set for 10/5/2018 at 03:15 PM in Courtroom 706, 40 Centre Street, New York, NY 10007 before Judge J. Paul Oetken.) (Signed by Judge J. Paul Oetken on 9/21/2018) (jca)
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| Filing 133 DECLARATION of Jason Daniel Paul Philip (Redacted) in Opposition re: #119 Letter,,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Dabney, James) |
| Filing 132 REPLY re: #119 Letter,, #130 Letter, / Plaintiff's Motion to Renew Preliminary Injunction Application. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 131 DECLARATION of Jason Daniel Paul Philip in Opposition re: #119 Letter,,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit, #2 Exhibit)(Dabney, James) |
| Filing 130 LETTER addressed to Judge J. Paul Oetken from James W. Dabney dated 9/19/18 re: Dkt. 119 Plaintiff's Motion for a Preliminary Injunction. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Dabney, James) |
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Filing 129
ORDER granting in part and denying in part #122 Letter Motion for Extension of Time to File Response/Reply. DEFENDANTS' MOTION FOR AN EXTENSION OF TIME IS GRANTED IN PART. DEFENDANTS SHALL FILE A RESPONSE TO PLAINTIFF'S LETTER RENEWING THE REQUEST FOR A PRELIMINARY INJUNCTION ON OR BEFORE SEPTEMBER 19, 2018. DEFENDANTS' MOTION FOR LEAVE TO FILE EXCESS PAGES IS DENIED. THE PRELIMINARY INJUNCTION QUESTION HAS ALREADY BEEN EXTENSIVELY BRIEFED. DEFENDANTS' RESPONSE NEED ONLY ADDRESS THE POINTS RAISED IN PLAINTIFF'S LETTER OF SEPTEMBER 10, 2018. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.)
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| Filing 128 NOTICE of Exhibit 8 re: #127 Reply to Response to Motion,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 127 LETTER REPLY to Response to Motion addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 13, 2018 re: #121 LETTER MOTION to Compel Defendants to Produce Documents addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 10, 2018. . Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(Ramos, Carey) |
| Filing 126 DECLARATION of Philip C. Hodgkins in Opposition re: #121 LETTER MOTION to Compel Defendants to Produce Documents addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 10, 2018.. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Dabney, James) |
| Filing 125 LETTER RESPONSE in Opposition to Motion addressed to Judge J. Paul Oetken from James W. Dabney dated 9/12/18 re: #121 LETTER MOTION to Compel Defendants to Produce Documents addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 10, 2018. . Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Dabney, James) |
| Filing 124 LETTER RESPONSE in Opposition to Motion addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 12, 2018 re: #122 LETTER MOTION for Extension of Time to File Response/Reply as to #119 Letter,, addressed to Judge J. Paul Oetken from James W. Dabney dated September 12, 2018. . Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 123 DECLARATION of Mohammed Mousa . Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8)(Dabney, James) |
| Filing 122 LETTER MOTION for Extension of Time to File Response/Reply as to #119 Letter,, addressed to Judge J. Paul Oetken from James W. Dabney dated September 12, 2018. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Dabney, James) |
| Filing 121 LETTER MOTION to Compel Defendants to Produce Documents addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 10, 2018. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Ramos, Carey) |
| Filing 120 DECLARATION of Madeleine McCartney in Support re: #119 Letter,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31, #32 Exhibit 32, #33 Exhibit 33, #34 Exhibit 34, #35 Exhibit 35, #36 Exhibit 36, #37 Exhibit 37, #38 Exhibit 38, #39 Exhibit 39, #40 Exhibit 40, #41 Exhibit 41, #42 Exhibit 42, #43 Exhibit 43, #44 Exhibit 44, #45 Exhibit 45, #46 Exhibit 46, #47 Exhibit 47, #48 Exhibit 48, #49 Exhibit 49, #50 Exhibit 50, #51 Exhibit 51, #52 Exhibit 52, #53 Exhibit 53, #54 Exhibit 54, #55 Exhibit 55, #56 Exhibit 56, #57 Exhibit 57, #58 Exhibit 58, #59 Exhibit 59, #60 Exhibit 60, #61 Exhibit 61, #62 Exhibit 62, #63 Exhibit 63, #64 Exhibit 64, #65 Exhibit 65, #66 Exhibit 66, #67 Exhibit 67, #68 Exhibit 68, #69 Exhibit 69, #70 Exhibit 70, #71 Exhibit 71)(Ramos, Carey) |
| Filing 119 LETTER addressed to Judge J. Paul Oetken from Carey R. Ramos dated September 10, 2018 re: Renew Plaintiff's Prior Application for a Preliminary Injunction {Dkt. No 17]. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24)(Ramos, Carey) |
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Filing 118
PROTECTIVE ORDER GOVERNING JURISDICTIONAL DISCOVERY...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge J. Paul Oetken on 7/31/2018) (rro)
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Filing 117
ORDER: The parties filed letters regarding three disputes over the terms of a potential protective order. The Court resolves those disputes as follows: (1) Disclosure of Alibabacoin Foundation's investor list shall be limited to Plaintiff's counsel of record, and any experts, vendors, or investigators retained for purposes of this action. (2)The contents of any communication with the investors on Alibabacoin Foundation's investor list shall be mutually agreed upon by the parties. If the parties cannot reach an agreement as to the contents of the communication, then the communication in question shall be submitted to the Court for approval. (3)The terms of the protective order shall not apply to any documents or information previously produced to an opposing party or filed publicly. SO ORDERED. (Signed by Judge J. Paul Oetken on 7/26/2018) (ama)
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| Filing 116 LETTER addressed to Judge J. Paul Oetken from Carey R. Ramos dated July 23, 2018 re: in Response to Defendants' July 20, 2018 Letter (ECF No. 115). Document filed by Alibaba Group Holding Limited.(Ramos, Carey) |
| Filing 115 LETTER addressed to Judge J. Paul Oetken from James W. Dabney dated 07/20/2018 re: In response to Plaintiffs letter application for issuance of a protective order. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Dabney, James) |
| Filing 114 AO 120 FORM TRADEMARK - CASE OPENING - SUBMITTED. In compliance with the provisions of 15 U.S.C. 1116, the Director of the U.S. Patent and Trademark Office is hereby advised that a court action has been filed on the following trademark(s) in the U.S. District Court Southern District of New York. Director of the U.S. Patent and Trademark Office electronically notified via Notice of Electronic Filing (NEF). (jgo) |
| Filing 113 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a motion proceeding held on 6/19/18 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) |
| Filing 112 TRANSCRIPT of Proceedings re: motion held on 6/19/2018 before Judge J. Paul Oetken. Court Reporter/Transcriber: Thomas Murray, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/8/2018. Redacted Transcript Deadline set for 8/20/2018. Release of Transcript Restriction set for 10/16/2018.(McGuirk, Kelly) |
| Filing 111 LETTER addressed to Judge J. Paul Oetken from Carey R. Ramos dated July 16, 2018 re: Protective Order. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A - Draft Order, #2 Exhibit B - Draft Order, #3 Exhibit C - Letter, #4 Exhibit D - Draft Order, #5 Exhibit E - Proposed Order, #6 Exhibit F - Redline)(Ramos, Carey) |
| Filing 110 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a argument proceeding held on 6/7/18 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(Siwik, Christine) |
| Filing 109 TRANSCRIPT of Proceedings re: argument held on 6/7/2018 before Judge J. Paul Oetken. Court Reporter/Transcriber: Michael McDaniel, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/2/2018. Redacted Transcript Deadline set for 8/13/2018. Release of Transcript Restriction set for 10/10/2018.(Siwik, Christine) |
| Filing 108 INTERNET CITATION NOTE: Material from decision with Internet citation re: #59 Memorandum & Opinion. (Attachments: #1 Internet Citation) (dnh) |
| Filing 107 LETTER addressed to Judge J. Paul Oetken from James W. Dabney dated June 20, 2018 re: Submission of an unredacted copy of Docket Item 93-4 bearing Bates numbers ACF-000272-276. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Dabney, James) |
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Filing 106
ORDER granting #105 Letter Motion for Leave to File Document. GRANTED. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.)
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| Filing 105 LETTER MOTION for Leave to File Corrected Exhibit 3 (Dkt. No. 95-3) addressed to Judge J. Paul Oetken from Carey Ramos dated June 19, 2018. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit Corrected Exhibit 3 (Dkt. No. 95-3))(Ramos, Carey) |
| Filing 104 DECLARATION of Anne C. Lefever re: #79 Order on Motion to Withdraw,,, #80 Declaration, /Supplemental Declaration of Anne C. Lefever regarding Withdrawal Conditions. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit A)(Lefever, Anne) |
| Minute Entry for proceedings held before Judge J. Paul Oetken: Show Cause Hearing held on 6/19/2018. (See transcript for complete details of rulings and conference minutes.) (bh) |
| Filing 103 DECLARATION of Lucas V.M. Bento, Second Declaration in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Ramos, Carey) |
| Filing 102 REPLY MEMORANDUM OF LAW in Support re: #84 Order to Show Cause,,,,, . Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 101 DECLARATION of Patricia Mooneyham in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 100 DECLARATION of Madeleine McCartney in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(Ramos, Carey) |
| Filing 99 DECLARATION of Saranya Kapur in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Ramos, Carey) |
| Filing 98 DECLARATION of Lydia Dallett in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Ramos, Carey) |
| Filing 97 DECLARATION of Sean Anderson in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Ramos, Carey) |
| Filing 96 DECLARATION of David Aktary in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(Ramos, Carey) |
| Filing 95 DECLARATION of Lucas V.M. Bento in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19)(Ramos, Carey) |
| Filing 94 DECLARATION of James W. Dabney in Opposition re: #84 Order to Show Cause,,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8a, #9 Exhibit 8b, #10 Exhibit 8c, #11 Exhibit 8d, #12 Exhibit 9a, #13 Exhibit 9b)(Dabney, James) |
| Filing 93 DECLARATION of Jason Daniel Paul Philip in Opposition re: #84 Order to Show Cause,,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5a, #6 Exhibit 5b, #7 Exhibit 5c)(Dabney, James) |
| Filing 92 MEMORANDUM OF LAW in Opposition re: #84 Order to Show Cause,,,,, . Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Dabney, James) |
| Filing 91 DECLARATION of David J. White in Opposition re: #84 Order to Show Cause,,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Dabney, James) |
| Filing 90 NOTICE OF APPEARANCE by Michael M Polka on behalf of ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Polka, Michael) |
| Filing 89 NOTICE OF APPEARANCE by Stefanie Lopatkin on behalf of ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lopatkin, Stefanie) |
| Filing 88 NOTICE OF APPEARANCE by Deanne Cevasco on behalf of ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Cevasco, Deanne) |
| Filing 87 DECLARATION of Muhammad Tehseen in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 86 DECLARATION of Lucas V.M. Bento in Support re: #84 Order to Show Cause,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 - Screenshot taken June 6, 2018, #2 Exhibit 2 - June 5, 2018 Email from James W. Dabney, Defendants' Counsel, #3 Exhibit 3 - June 5, 2018 Email from James W. Dabney, Defendants' Counsel, #4 Exhibit 4 - May 31, 2018 Email from Anne C. Lefever, Defendants' Former Counsel, #5 Exhibit 5 - Article titled "Initial Coin Scams", #6 Exhibit 6 - Article titled "Buyer Beware: Hundreds of Bitcoin Wannabes Show Hallmarks of Fraud", #7 Exhibit 7 - Article titled "SEC Shows Investors What a Cryptocurrency Scam Looks Like")(Ramos, Carey) |
| Filing 85 MEMORANDUM OF LAW in Support re: #84 Order to Show Cause,,,,, Memorandum of Law in Support of Plaintiff's Renewed Application for a Preliminary Injunction. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
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Filing 84
ORDER TO SHOW CAUSE FOR A PRELIMINARY INJUNCTION: ORDERED, that Defendants ALIBABACOIN Foundation a/k/a ABBC Foundation ("ABBC"), ABBC Block Chain IT Solutions LLC, Alibabacoin General Trading FZE, Alibabacoin Foundation LLC, Jason Daniel Paul Philip, and Hasan Abbas (collectively, "Defendants") show cause before a motion term of this Court to be held, at the U.S. Courthouse, 500 Pearl Street, New York, New York, 10007, at 2:30 p.m. on June 19, 2018, why the Court should not draw an adverse inference that there is a reasonable probability the Court has personal jurisdiction over Defendants, and why an order should not be issued granting a preliminary injunction. AND IT IS FURTHER ORDERED that any papers responding to the Renewed Application and Motion be served and filed on or before June 14, 2018, and that any reply papers in further support of the Renewed Application and Motion be served and filed on or before June 18, 2018. AND IT IS FURTHER ORDERED that Defendants must file a sworn affidavit confirming that Defendants have preserved all documents relevant to this dispute that are in their possession, custody, or control, including documents responsive to Plaintiff's First Requests for Production of Documents, since the commencement of this action on or before June 14, 2018. Show Cause Hearing set for 6/19/2018 at 02:30 PM before Judge J. Paul Oetken. (Signed by Judge J. Paul Oetken on 6/07/2018) (ama)
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| Set/Reset Deadlines: Responses due by 6/14/2018 Replies due by 6/18/2018. (ama) |
| Minute Entry for proceedings held before Judge J. Paul Oetken: Scheduling Conference for Order to Show Cause held on 6/7/2018. Hearing scheduled for 6/19/2018 at 2:30 p.m. TRO is orally denied. (See transcript for complete details of rulings and conference minutes.) (bh) |
| Filing 83 NOTICE OF APPEARANCE by James Wilson Dabney on behalf of ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Dabney, James) |
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Filing 82
ORDER: The Court previously granted former defense counsel Pillsbury Winthrop Shaw Pittman LLP's ("Pillsbury") motion to withdraw (Dkt. No. 79), on the condition that it serve a copy of that order on all defendants. Pillsbury's request to serve Defendant Hasan Abbas by e-mail (Dkt. No. 80) is hereby GRANTED. SO ORDERED. (Signed by Judge J. Paul Oetken on 6/01/2018) (ama)
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| Filing 81 CERTIFICATE OF SERVICE. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 80 DECLARATION of Anne C. Lefever re: #79 Order on Motion to Withdraw,,, . Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
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Filing 79
ORDER granting in part and denying in part #73 Motion to Withdraw: The motion to withdraw is GRANTED, subject to the following conditions: (1) defense counsel shall produce to Plaintiff all documents in defense counsel's possession, custody, or control that are responsive to Plaintiff's discovery requests; and (2) defense counsel shall serve a copy of this order upon all Defendants. Defendants must retain counsel within one week of the date of this order. If the corporate defendants fail to timely retain counsel, they are at risk of defaulting in this litigation. Plaintiffs are hereby authorized to serve Defendants via e-mail, following defense counsel's withdrawal. Defendants request for an extension of the deadline to complete expedited jurisdictional discovery is DENIED. (Signed by Judge J. Paul Oetken on 5/30/2018) (tn)
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| Filing 78 RESPONSE to Motion re: #73 MOTION to Withdraw as counsel. Declaration of Lucas V.M. Bento in Response to Motion to Withdraw and in Opposition to Motion to Extend Deadlines for Expedited Jurisdictional Discovery. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 - Plaintiff Counsel Email dated May 14, 2018, #2 Exhibit 2 - Plaintiff Counsel Email dated May 17, 2018, #3 Exhibit 3 - Pillsbury Email dated May 19, 2018, #4 Exhibit 4 - Email re: Meet and Confer, #5 Exhibit 5 - Email re: Agreement and Outstanding Issues, #6 Exhibit 6 - Email re: Collection Efforts, #7 Exhibit 7 - Screenshot of Email Address)(Ramos, Carey) |
| Filing 77 RESPONSE to Motion re: #73 MOTION to Withdraw as counsel. and in Opposition to Motion to Extend Deadlines for Expedited Jurisdictional Discovery. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 76 CERTIFICATE OF SERVICE. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 75 MEMORANDUM OF LAW in Support re: #73 MOTION to Withdraw as counsel. . Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 74 DECLARATION of Anne C. Lefever in Support re: #73 MOTION to Withdraw as counsel.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit A)(Lefever, Anne) |
| Filing 73 MOTION to Withdraw as counsel. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Lefever, Anne) |
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Filing 72
ORDER granting #54 Motion to Appear Pro Hac Vice. GRANTED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.)
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Filing 71
ORDER granting #68 Letter Motion to Expedite. PLAINTIFF'S REQUEST FOR EXPEDITED JURISDICTIONAL DISCOVERY IS GRANTED. DEFENDANTS SHALL COMPLY WITH PLAINTIFF'S REQUESTS FOR PRODUCTION BY MAY 31, 2018, AND SHALL PRODUCE THE REQUESTED WITNESSES FOR DEPOSITIONS BY JUNE 7, 2018. IF A DISPUTE ARISES AS TO THE SCOPE OF PARTICULAR REQUESTS, THE PARTIES SHALL MEET AND CONFER BEFORE SEEKING RESOLUTION OF THE DISPUTE BEFORE THE COURT. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (Oetken, J.)
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| Filing 70 LETTER addressed to Judge J. Paul Oetken from Carey R. Ramos dated May 8, 2018 re: in reply to Defendants' letter of May 7, 2018. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A Webpage, #2 Exhibit B Webpage)(Ramos, Carey) |
| Filing 69 LETTER RESPONSE in Opposition to Motion addressed to Judge J. Paul Oetken from Anne C. Lefever dated May 7, 2018 re: #68 LETTER MOTION to Expedite Limited Jurisdictional Discovery addressed to Judge J. Paul Oetken from Carey R. Ramos dated May 2, 2018. . Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 68 LETTER MOTION to Expedite Limited Jurisdictional Discovery addressed to Judge J. Paul Oetken from Carey R. Ramos dated May 2, 2018. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A-Request for Production, #2 Exhibit B-Deposition Notice, #3 Exhibit C-Deposition Notice)(Ramos, Carey) |
| Filing 67 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 4/13/18 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) |
| Filing 66 TRANSCRIPT of Proceedings re: CONFERENCE held on 4/13/2018 before Judge J. Paul Oetken. Court Reporter/Transcriber: Thomas Murray, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/23/2018. Redacted Transcript Deadline set for 6/4/2018. Release of Transcript Restriction set for 7/31/2018.(McGuirk, Kelly) |
| Filing 65 LETTER addressed to Judge J. Paul Oetken from Anne C. Lefever dated May 1, 2018 re: Enclosing Proposed Order Granting Motion to Dimiss Plaintiff's Complaint. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Text of Proposed Order Granting Motion to Dismiss Complaint)(Lefever, Anne) |
| Filing 64 AFFIRMATION of William P. Atkins in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 63 DECLARATION of Anne C. Lefever in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 62 DECLARATION of Jason Daniel Paul Philip in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit A - Russian Language Lease Agreement, #2 Exhibit B - Russian Language Lease Termination Agreement, #3 Exhibit C - Screenshot from Google Maps, #4 Exhibit D - Photographs taken of the ABBC LLC Office)(Lefever, Anne) |
| Filing 61 DECLARATION of Hasan Abbas in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 60 REPLY MEMORANDUM OF LAW in Support re: #33 MOTION to Dismiss Plaintiff's Complaint. . Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
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Filing 59
OPINION AND ORDER: For the foregoing reasons, Plaintiff's motion for a preliminary injunction is denied, without prejudice to renewal upon an adequate showing of personal jurisdiction, and the temporary restraining order is dissolved. SO ORDERED. (Signed by Judge J. Paul Oetken on 4/30/2018) (ama)
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| Filing 58 AFFIDAVIT OF SERVICE of Plaintiff's memorandum of law in opposition to the motion to dismiss, declaration of Lucas V.M. Bento and accompanying exhibits and the declaration of Muhammed Tehseen served on Hasan Abbas on April 25, 2018. Service was made by Electronic mail and Fedex. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 57 DECLARATION of Muhammed Tehseen in Opposition re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 Profile)(Ramos, Carey) |
| Filing 56 DECLARATION of Lucas V.M. Bento in Opposition re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 Article, #2 Exhibit 2 Certified Translation of Exhibit 1, #3 Exhibit 3 Terms of Service, #4 Exhibit 4 Agreement, #5 Exhibit 5 Agreement, #6 Exhibit 6 Error page, #7 Exhibit 7 Profile, #8 Exhibit 8 Agreement, #9 Exhibit 9 Program, #10 Exhibit 10 Distribution, #11 Exhibit 11 Terms of Service, #12 Exhibit 12 User Agreement, #13 Exhibit 13 Terms of Service, #14 Exhibit 14 User Agreement, #15 Exhibit 15 Profile page, #16 Exhibit 16 MX Lookup, #17 Exhibit 17 IP adress location, #18 Exhibit 18 First video, #19 Exhibit 19 Second video, #20 Exhibit 20 Policy page, #21 Exhibit 21 Certified Translation of Exhibit 20, #22 Exhibit 22 Login page, #23 Exhibit 23 WHOIS hosting information, #24 Exhibit 24 Policy page, #25 Exhibit 25 Certified Translation of Exhibit 24, #26 Exhibit 26 Policy page, #27 Exhibit 27 Certified Translation of Exhibit 26, #28 Exhibit 28 Terms of use, #29 Exhibit 29 ICO, #30 Exhibit 30 abbcfoundation.com website, #31 Exhibit 31 Accessing www.alibabacoinwallet.com, #32 Exhibit 32 Accessing www.alibabacoinwallet.com, #33 Exhibit 33 Report, #34 Exhibit 34 Original white paper, #35 Exhibit 35 Original white paper, #36 Exhibit 36 Facebook page, #37 Exhibit 37 Youtube page, #38 Exhibit 38 Twitter page, #39 Exhibit 39 Instragram page, #40 Exhibit 40 Search results, #41 Exhibit 41 Raw data, #42 Exhibit 42 Traffic analysis, #43 Exhibit 43 Email, #44 Exhibit 44 Excerpt, #45 Exhibit 45 Blacklist, #46 Exhibit 46 Full Transcript, #47 Exhibit 47 Errata sheet)(Ramos, Carey) |
| Filing 55 MEMORANDUM OF LAW in Opposition re: #33 MOTION to Dismiss Plaintiff's Complaint. . Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 54 MOTION for William P. Atkins to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-14956637. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Affidavit Declaration in Support of Motion for Pro Hac Vice, #2 Exhibit A - Certificate of Good Standing from DC, #3 Exhibit B - Certificate of Good Standing from Maryland, #4 Exhibit C - Certificate of Good Standing from Virginia, #5 Text of Proposed Order)(Atkins, William) |
| >>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #54 MOTION for William P. Atkins to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number 0208-14956637. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (jc) |
| Filing 53 AFFIDAVIT OF SERVICE of (1) Plaintiff's Reply Memorandum of Law in Support of Plaintiff's Application for a Preliminary Injunction, and all supporting materials appended thereto, and (2) a copy of the letter from Carey R. Ramos dated April 12, 2018 served on Hasan Abbas on April 13, 2018. Service was made by Mail (Fedex International). Document filed by Alibaba Group Holding Limited. (Bento, Lucas) |
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Filing 52
ORDER: For the reasons given at the hearing on April 13, 2018, the temporary restraining order entered on April 3, 2018, shall remain in effect through April 30, 2018. SO ORDERED. (Signed by Judge J. Paul Oetken on 4/16/2018) (ama)
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| Filing 51 LETTER addressed to Judge J. Paul Oetken from Anne C. Lefever dated April 13, 2018 re: Update of the Additional Measures Taken by Defendants in Connection with the Temporary Restraining Order and Order to Show Cause for Preliminary Injunction. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit 1 - Removal of Mr. Abbas's profile, #2 Exhibit 2 - Disclaimer on White Paper, #3 Exhibit 3 - Link to Press Release, #4 Exhibit 4 - Pop-Up Notice on website)(Lefever, Anne) |
| Minute Entry for proceedings held before Judge J. Paul Oetken: Oral Argument held on 4/13/2018 re: #10 Order to Show Cause. Decision reserved. The TRO is extended by 14 days. (bh) |
| Filing 50 LETTER addressed to Judge J. Paul Oetken from Anne C. Lefever dated April 12, 2018 re: Request Permission to Have a Live Telephone Line Opened in the Courtroom During the Hearing Scheduled for April 13, 2018. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Lefever, Anne) |
| Filing 49 REPLY MEMORANDUM OF LAW in Support re: #10 Order to Show Cause,,,,,,, . Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 48 DECLARATION of Patricia Mooneyham in Support re: #10 Order to Show Cause,,,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A Google results page)(Ramos, Carey) |
| Filing 47 DECLARATION of Kevin Lee in Support re: #10 Order to Show Cause,,,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 Ex F to Plaintiffs Letter Dated April 5 2018, #2 Exhibit 2 SEMrush report, #3 Exhibit 3 Alexa.com report, #4 Exhibit 4 BuiltWith report)(Ramos, Carey) |
| Filing 46 DECLARATION of Liza Baron in Support re: #10 Order to Show Cause,,,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A Photographs of office building (interior), #2 Exhibit B Photograph of buildings mailbox)(Ramos, Carey) |
| Filing 45 DECLARATION of Lucas V.M. Bento in Support re: #10 Order to Show Cause,,,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1 Screenshots of AlibabaCoin Websites, #2 Exhibit 2 Screenshot of alibabacoinwallet.com website, #3 Exhibit 3 IAB Study Says 26% of Desktop Users Turn On Ad Blockers Adweek, #4 Exhibit 4 Screenshots of registration process, #5 Exhibit 5 DigitalOcean LLCs Terms of Agreement, #6 Exhibit 6 ALIPAY Trademark Registration (USPTO), #7 Exhibit 7 Ant Financial entry on Crunchbase, #8 Exhibit 8 Alibaba debuts smile to pay facial recognition payments at KFC in China _ TechCrunch, #9 Exhibit 9 AlibabaCoins Original White Paper, #10 Exhibit 10 Alibabacoin on ICO News Desk, #11 Exhibit 11 Alibaba Launches Cryptocurrency Mining Platform _ Investopedia, #12 Exhibit 12 World Reading Festival Dubai - Alibabacoin Foundation - YouTube, #13 Exhibit 13 WHOIS registry for alibabacoinico.com, #14 Exhibit 14 alibabacoin (AlibabaCoin) GitHub profile, #15 Exhibit 15 Drawing - 3d render golden chinese dragon. Clipart Drawing, #16 Exhibit 16 Alibaba Coin Download AlibabaCoin App article (Korean), #17 Exhibit 17 Translation of Exhibit 16, #18 Exhibit 18 Alibaba Coin Download AlibabaCoin article (Korean), #19 Exhibit 19 Translation of Exhibit 18, #20 Exhibit 20 Alibaba Coin What made you different? Article (Korean), #21 Exhibit 21 Translation of Exhibit 20, #22 Exhibit 22 Alibabacoins profile on Band.us (Korean), #23 Exhibit 23 Translation of Exhibit 22, #24 Exhibit 24 Mr. Hassan Abbas profile on LinkedinIn.com, #25 Exhibit 25 Team page of Reactive Space, #26 Exhibit 26 Screenshot of AlibabaCoins original white paper)(Ramos, Carey) |
| Filing 44 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits, Declaration of David Ho, the electronic case filing rules and instructions and the notice, consent, and reference of a civil action to a magistrate judge form served on Alibabacoin Foundation LLC on April 3, 2018. Service was made by Mail and Email. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 43 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits, Declaration of David Ho, the electronic case filing rules and instructions and the notice, consent, and reference of a civil action to a magistrate judge form served on ALIBABACOIN Foundation on April 3, 2018. Service was made by Mail and Email. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 42 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits, Declaration of David Ho, the electronic case filing rules and instructions and the notice, consent, and reference of a civil action to a magistrate judge form served on Jason Daniel Paul Philip on April 3, 2018. Service was made by Mail and Email. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 41 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits, Declaration of David Ho, the electronic case filing rules and instructions and the notice, consent, and reference of a civil action to a magistrate judge form served on ABBC Block Chain IT Solutions LLC on April 3, 2018. Service was made by Mail and Email. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 40 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits, Declaration of David Ho, the electronic case filing rules and instructions, and the notice, consent, and reference of a civil action to a magistrate judge form served on Alibabacoin General Trading FZE on April 3, 2018. Service was made by Mail and Email. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 39 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits. Declaration of David Ho, the electronic case filing rules and instructions and the notice, consent and reference of a civil action to a magistrate judge form served on Hasan Abbas on April 3, 2018. Service was accepted by Hasan Abbas. Service was made by Mail and Email. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 38 AFFIDAVIT OF SERVICE of Summons, Complaint, Court's Order, Declaration of Lucas V.M. Bento with exhibits, Declaration of David Ho, electronic case filing rules and instructions, and the notice, consent, and reference of a civil action to a magistrate judge form served on ALIBABACOIN Foundation, ABBC Block Chain IT Solutions LLC, Alibabacoin General Trading FZE, Alibabacoin Foundation LLC, Jason Daniel Paul Philip and Hasan Abbas on April 3, 2018. Service was made by Mail and Email upon Hamdan Al-Shamsi, counsel for Defendants. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 37 MEMORANDUM OF LAW in Support re: #33 MOTION to Dismiss Plaintiff's Complaint. . Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 36 DECLARATION of Anne C. Lefever in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit B - News article from Investopedia.com, #2 Exhibit C - News article from Forbes.com, #3 Exhibit D - News article from RT.com, #4 Exhibit O - News article from digitalcommerce360.com, #5 Exhibit P - News article from technode.com, #6 Exhibit Q - Editorial from cointelegraph.com, #7 Exhibit R - News article from theVerge.com, #8 Exhibit S - News article from fortune.com, #9 Exhibit T - Twitter feed of one (Lee Young-Jae), #10 Exhibit U - Tweet posted by one (Lee Young-Jae), #11 Exhibit V - Courts Temporary Restraining Order and Order to Show Cause for a Preliminary Injunction)(Lefever, Anne) |
| Filing 35 DECLARATION of Jason Daniel Paul Philip in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit E - Confirmation of the Registration Process, #2 Exhibit F - ABBC Foundation registration of various website domain names, #3 Exhibit G - March 27, 2018 Press Release, #4 Exhibit H - Amended White Paper, #5 Exhibit I - ABBC FZE's License And Certificate of Incorporation, #6 Exhibit J - ABBC FZE's License And Certificate of Incorporation, #7 Exhibit K - ABBC Block Chain IT's Professional License and Commercial Register, #8 Exhibit L - ABBC Block Chain IT's Professional License and Commercial Register, #9 Exhibit M - ABBC LLC's Certificate as a Legal Entity, #10 Exhibit N - ABBC LLC's Certificate as a Legal Entity)(Lefever, Anne) |
| Filing 34 DECLARATION of Hamdan AlShamsi in Support re: #33 MOTION to Dismiss Plaintiff's Complaint.. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit A - Extracts of the search results obtained from the DED website)(Lefever, Anne) |
| Filing 33 MOTION to Dismiss Plaintiff's Complaint. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Lefever, Anne) |
| Filing 32 AMENDED MEMORANDUM OF LAW in Opposition re: #19 Declaration in Support, #17 Memorandum of Law in Support, #18 Declaration in Support,,, #10 Order to Show Cause,,,,,,, #1 Complaint,,,, (Corrected). Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 31 DECLARATION of Anne C. Lefever in Opposition re: #17 Memorandum of Law in Support, #18 Declaration in Support,,, #1 Complaint,,,, #19 Declaration in Support, #10 Order to Show Cause,,,,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit B - News article from Investopedia.com, #2 Exhibit C - News article from Forbes.com, #3 Exhibit D - News article from RT.com, #4 Exhibit O - News article from digitalcommerce360.com, #5 Exhibit P - News article from technode.com, #6 Exhibit Q - Editorial from cointelegraph.com, #7 Exhibit R - News article from theVerge.com, #8 Exhibit S - News article from fortune.com, #9 Exhibit T - Twitter feed of one (Lee Young-Jae), #10 Exhibit U - Tweet posted by one (Lee Young-Jae), #11 Exhibit V - Courts Temporary Restraining Order and Order to Show Cause for a Preliminary Injunction)(Lefever, Anne) |
| Filing 30 MEMORANDUM OF LAW in Opposition re: #19 Declaration in Support, #17 Memorandum of Law in Support, #18 Declaration in Support,,, #10 Order to Show Cause,,,,,,, #1 Complaint,,,, . Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
| Filing 29 DECLARATION of Jason Daniel Paul Philip in Opposition re: #18 Declaration in Support,,, #1 Complaint,,,, #19 Declaration in Support, #10 Order to Show Cause,,,,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit E - Confirmation of the Registration Process, #2 Exhibit F - ABBC Foundation registration of various website domain names, #3 Exhibit G - March 27, 2018 Press Release, #4 Exhibit H - Amended White Paper, #5 Exhibit I - ABBC FZE's License And Certificate of Incorporation, #6 Exhibit J - ABBC FZE's License And Certificate of Incorporation, #7 Exhibit K - ABBC Block Chain IT's Professional License and Commercial Register, #8 Exhibit L - ABBC Block Chain IT's Professional License and Commercial Register, #9 Exhibit M - ABBC LLC's Certificate as a Legal Entity, #10 Exhibit nN - ABBC LLC's Certificate as a Legal Entity)(Lefever, Anne) |
| Filing 28 DECLARATION of Hamdan AlShamsi in Opposition re: #19 Declaration in Support, #18 Declaration in Support,,, #10 Order to Show Cause,,,,,,, #1 Complaint,,,,. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Attachments: #1 Exhibit A - Extracts of the search results obtained from the DED website)(Lefever, Anne) |
| Filing 27 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip.(Lefever, Anne) |
| Filing 26 NOTICE OF APPEARANCE by Anne Catharine Lefever on behalf of ABBC Block Chain IT Solutions LLC, Alibabacoin Foundation, Alibabacoin Foundation LLC, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Lefever, Anne) |
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Filing 25
ORDER: The briefing schedule on Plaintiff's application for a preliminary injunction is modified as follows: Any brief in opposition shall be due before 12:00 a.m. on Tuesday, April 10, 2018. Plaintiff's reply shall be due before 12:00 a.m. on Thursday, April 12, 2018.SO ORDERED., ( Responses due by 4/10/2018, Replies due by 4/12/2018.) (Signed by Judge J. Paul Oetken on 4/06/2018) (ama)
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| Filing 24 NOTICE OF APPEARANCE by Lucas Bento on behalf of Alibaba Group Holding Limited. (Bento, Lucas) |
| CASHIERS OFFICE REGISTRY DEPOSIT as per #10 Order to Show Cause, dated 4/2/2018, from Judge Kimba M. Wood, received $1,000.00 from Alibaba Group Holding Limited Receipt Number 465401206245 on 4/9/2018. (nm) |
| Filing 23 LETTER addressed to Judge J. Paul Oetken from Carey R. Ramos dated April 6, 2018 Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Declaration of Service, #11 Declaration of Service, #12 Declaration of Service, #13 Declaration of Service, #14 Declaration of Service, #15 Declaration of Service, #16 Declaration of Service)(Ramos, Carey) |
| Filing 22 LETTER addressed to Judge J. Paul Oetken from Carey Ramos dated April 5, 2018 re: newly-discovered facts. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Affirmation of Service, #11 Affirmation of Service, #12 Affirmation of Service, #13 Affirmation of Service, #14 Affirmation of Service, #15 Affirmation of Service, #16 Affirmation of Service)(Ramos, Carey) |
| Filing 21 AO 120 FORM TRADEMARK - NOTICE OF SUBMISSION BY ATTORNEY. AO 120 Form Patent/Trademark for case opening submitted to court for review.(Ramos, Carey) |
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Filing 20
ORDER: The hearing on Plaintiff's application for a preliminary injunction, previously scheduled for April 11, 2018, is hereby adjourned to April 13, 2018, at 4:00 p.m. The hearing will take place in Courtroom 706 of the Thurgood Marshall United States Court House, 40 Foley Square, New York, New York. Plaintiff shall serve via e-mail and FedEx of a copy of this order on the Defendants or their counsel on or before April 6, 2018. (Show Cause Hearing set for 4/13/2018 at 4:00 PM in Courtroom 706, 40 Centre Street, New York, NY 10007 before Judge J. Paul Oetken.) (Signed by Judge J. Paul Oetken on 4/4/2018) (ap)
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| Filing 19 DECLARATION of Ho Lok Che in Support re: #10 Order to Show Cause,,,,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 18 DECLARATION of Lucas V.M. Bento in Support re: #10 Order to Show Cause,,,,,,,. Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31, #32 Exhibit 32, #33 Exhibit 33, #34 Exhibit 34, #35 Exhibit 35, #36 Exhibit 36, #37 Exhibit 37)(Ramos, Carey) |
| Filing 17 MEMORANDUM OF LAW in Support re: #10 Order to Show Cause,,,,,,, for a Temporary Restraining Order and Preliminary Injunction. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 16 ELECTRONIC SUMMONS ISSUED as to Jason Daniel Paul Philip. (jgo) |
| Filing 15 ELECTRONIC SUMMONS ISSUED as to Hasan Abbas. (jgo) |
| Filing 14 ELECTRONIC SUMMONS ISSUED as to Alibabacoin General Trading FZE. (jgo) |
| Filing 13 ELECTRONIC SUMMONS ISSUED as to Alibabacoin Foundation. (jgo) |
| Filing 12 ELECTRONIC SUMMONS ISSUED as to Alibabacoin Foundation LLC. (jgo) |
| Filing 11 ELECTRONIC SUMMONS ISSUED as to ABBC Block Chain IT Solutions LLC. (jgo) |
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Filing 10
TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE FOR A PRELIMINARY INJUNCTION: It is hereby ORDERED, that Defendants ALIBABACOIN Foundation a/k/a ABBC Foundation ("ABBC"), ABBC Block Chain IT Solutions LLC, Alibabacoin General Trading FZE, Alibabacoin Foundation LLC, Jason Daniel Paul Philip, and Hasan Abbas (collectively, "Defendants") show cause before a motion term of this Court to be held, at the U.S. Courthouse, 500 Pearl Street, New York, New York, 10007, at 11 a.m. on April 11, 2018, why an order should not be issued granting a preliminary injunction that (1) enjoins Defendants from using the ALIBABA Marks, as that term is defined in the Application, alone or in combination with any word(s), term(s), designation(s), marks(s), or design(s), as well as any mark, image, or depiction that is confusingly similar to or likely to impair the distinctiveness of the ALIBABA Marks anywhere in the United States...AND IT IS FURTHER ORDERED that any papers responding to the Application and Motion be served and filed on or before April 6, 2018, and that any reply papers in further support of the Application and Motion be served and filed on or before April 9, 2018; AND IT IS FURTHER ORDERED that security in the amount of $1,000.00 be posted by Alibaba Group Holding prior to April 11, 2018; AND IT IS FURTHER ORDERED that, pursuant to Rule 4(f)(3) of the Federal Rules of Civil Procedure, service via e-mail and FedEx of a copy of this order and the papers upon which it is granted made on the Defendants or their counsel on or before April 5, 2018, shall be deemed good and sufficient service and notice thereof. (Show Cause Hearing set for 4/11/2018 at 11:00 AM before Judge Kimba M. Wood.) (Signed by Judge Kimba M. Wood on 4/2/2018) (ras) Modified on 4/4/2018 (ras).
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| ***NOTICE TO ATTORNEY REGARDING CIVIL CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Carey Richard Ramos. The following case opening statistical information was erroneously selected/entered: County code XX Out of U.S.;. The following correction(s) have been made to your case entry: the County code has been modified to New York;. (jgo) |
| ***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Carey Richard Ramos. The party information for the following party/parties has been modified: Alibabacoin Foundation. The information for the party/parties has been modified for the following reason/reasons: alias was entered incorrectly. (jgo) |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge J. Paul Oetken. Please download and review the Individual Practices of the assigned District Judge, located at #http://nysd.uscourts.gov/judges/District. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #http://nysd.uscourts.gov/ecf_filing.php. (jgo) |
| Case Designated ECF. (jgo) |
| Magistrate Judge Debra C. Freeman is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #http://nysd.uscourts.gov/forms.php. (jgo) |
| Filing 9 REQUEST FOR ISSUANCE OF SUMMONS as to Hasan Abbas, re: #1 Complaint,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 8 REQUEST FOR ISSUANCE OF SUMMONS as to Jason Daniel Paul Philip, re: #1 Complaint,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 7 REQUEST FOR ISSUANCE OF SUMMONS as to Alibabacoin Foundation LLC, re: #1 Complaint,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 6 REQUEST FOR ISSUANCE OF SUMMONS as to Alibabacoin General Trading FZE, re: #1 Complaint,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 5 REQUEST FOR ISSUANCE OF SUMMONS as to ABBC Block Chain IT Solutions LLC, re: #1 Complaint,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 4 REQUEST FOR ISSUANCE OF SUMMONS as to Alibabacoin Foundation a/k/a ABBC Foundation, re: #1 Complaint,,,,. Document filed by Alibaba Group Holding Limited. (Ramos, Carey) |
| Filing 3 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Alibaba Group Holding Limited.(Ramos, Carey) |
| Filing 2 CIVIL COVER SHEET filed. (Ramos, Carey) |
| Filing 1 COMPLAINT against ABBC Block Chain IT Solutions LLC, Hasan Abbas, Alibabacoin Foundation LLC, Alibabacoin Foundation a/k/a ABBC Foundation, Alibabacoin General Trading FZE, Jason Daniel Paul Philip. (Filing Fee $ 400.00, Receipt Number 0208-14885994)Document filed by Alibaba Group Holding Limited. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31, #32 Exhibit 32, #33 Exhibit 33, #34 Exhibit 34, #35 Exhibit 35, #36 Exhibit 36, #37 Exhibit 37, #38 Exhibit 38, #39 Exhibit 39, #40 Exhibit 40, #41 Exhibit 41, #42 Exhibit 42, #43 Exhibit 43, #44 Exhibit 44, #45 Exhibit 45)(Ramos, Carey) |
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