Anagram International, LLC v. Adeyoo Store, 1:25-cv-04622

Plaintiff Anagram International, LLC owns numerous registered U.S. copyrights for designs (the “Anagram Works”) and alleges Defendants sell products bearing unauthorized reproductions or colorable imitations of those works.
Defendants are dozens of largely foreign, marketplace-based sellers operating under various seller aliases on platforms (e.g., Amazon, TikTok, Walmart, PayPal) and accepting U.S. customers and U.S. dollar payments.
Plaintiff moved ex parte for a temporary restraining order (TRO) seeking: immediate takedowns/disablement of seller aliases, an asset freeze against funds held by Marketplaces and Financial Institutions, expedited discovery, and an order to show cause re: a preliminary injunction and disgorgement under 17 U.S.C. § 502.
The court found Plaintiff established ownership of valid registrations, that listed products are identical or substantially similar to the Anagram Works, and that Defendants’ activities are causing irreparable harm to goodwill and sales.
The court concluded ex parte relief was justified because notice would likely prompt foreign sellers to destroy evidence, transfer proceeds, and disappear; accordingly it granted the TRO with broad remedies (asset freeze, preservation, expedited discovery, marketplace disabling) and set a show-cause hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Likelihood of success on copyright claim	Plaintiff owns valid registrations and infringing listings are identical/substantially similar to Anagram Works	(Not articulated in TRO; presumed denial of infringement or lack of territorial reach)	Court found Plaintiff substantially likely to succeed and satisfied the first TRO factor
Irreparable harm	Continued sales of inferior counterfeits will damage goodwill, reputation, and future sales — harm not compensable by money alone	Harm to defendants is monetary and compensable	Court found irreparable injury likely and that balance of harms favors Plaintiff
Ex parte relief (notice)	Notice would allow Defendants to delete aliases, hide identities, destroy evidence, and transfer assets	(Implicit) Notice could be appropriate if defendants reachable; but risk of flight/obfuscation high	Court authorized ex parte TRO given risk of evidence destruction and international defendants
Asset freeze and expedited discovery	Asset restraint necessary to preserve funds for potential equitable relief; expedited discovery needed to identify defendants and accounts	Freezing assets harms defendants; bond could protect defendants	Court ordered asset freeze, expedited discovery, and marketplace cooperation; temporarily waived bond requirement but allowed defendants to seek modification

Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1223 (11th Cir.) (sets four-factor standard for preliminary injunctive relief)
AT&T Broadband v. Tech Communications, Inc., 381 F.3d 1309 (11th Cir.) (supports ex parte seizure in counterfeiting contexts when notice would render action futile)
U.S. S.E.C. v. Carrillo, 115 F.3d 1540 (11th Cir.) (jurisdiction over foreign parties where contacts reasonably put them on notice of U.S. litigation)
Louis Vuitton Malletier, S.A. v. Mosseri, 736 F.3d 1339 (11th Cir.) (jurisdiction upheld for non-resident selling counterfeit goods via interactive website)
Levi Strauss & Co. v. Sunrise Intern. Trading Inc., 51 F.3d 982 (11th Cir.) (courts may enter preliminary asset restraints to preserve equitable relief)
Reebok Int’l Ltd. v. Marnatech Enterprises, Inc., 970 F.2d 552 (9th Cir.) (asset freezes appropriate against counterfeit sellers likely to dissipate proceeds)