BACKGROUND As previously discussed, Atari sued RageOn.com for facilitating the sale of counterfeit Atari merch on its platform. After RageOn failed to respond to Atari’s Complaint, Atari obtained a default judgment and had the U.S. Marshal seize $882,000 from RageOn’s bank account. RageOn then fired its counsel (Betty Tufariello), and hired new counsel (Arash Beral of Freeman Freeman and Smiley LLP) and applied,