2023-cv-02965

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 402, receipt number AILNDC-20628581.

Exhibit 1

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Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Peanuts Worldwide LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Peanuts Worldwide LLC

Notice of Claims Involving Trademarks by Peanuts Worldwide LLC

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Text entry; no document attached.)

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MAILED copyright report to Registrar, Washington DC.

MOTION by Plaintiff Peanuts Worldwide LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Peanuts Worldwide LLC in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

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Exhibit 4

DECLARATION of Carrie J. Dumont regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 4 - Parts 1 - 5 regarding declaration[17]

MOTION by Plaintiff Peanuts Worldwide LLCfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Peanuts Worldwide LLC in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for leave to file under seal 3 is granted. Plaintiff's Ex Parte Motion for entry of a temporary restraining order 14 is granted. Plaintiff's motion for electronic service of process 19 is granted. Order to enter. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Rebecca R. Pallmeyer on 5/16/2023

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ 50,000.00 posted by Peanuts Worldwide LLC (Document not scanned).

MOTION by Plaintiff Peanuts Worldwide LLC for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for preliminary injunction[25]

Declaration of Marcella D. Slay

Exhibit 1

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/24/2023, answer due 6/14/2023.

Declaration of Trevor C. Talhami

Exhibit A

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion for preliminary injunction 25 is granted. Enter order. The Clerk is directed to unseal Schedule A to the Complaint 2, Exhibit 4 to the Declaration of Carrie J. Dumont 18, and the Temporary Restraining Order 23. The Law Firm of Greer, Burns & Crain, Ltd. is ordered to add all defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Rebecca R. Pallmeyer on 5/26/2023. Mailed notice

NEW PARTIES: Shenzhen Xin Rui Si Chuang Technology Co., Ltd., An Attitude Store, Beautiful World Toy Store, Cartoon Backpack Store, Castle Store, DISNEY OFFlCAL Store, LRGY Store, Nice To Meet You Plush Store, Pretty Girls biubiubiu Store, Riccu1000 Store, Shop1100390497 Store, Shop1102235066 Store, Shop1102269198 Store, Shop1102298440 Store, Shop1102680442 Store, Shop1102683332 Store, TongLing Metal Tin Store, W-AKL Store, Wholesale Small items Store, A13OMHVJLL1X8B, A13T0TYBK2XTJK, A3ASBOPFT71WGM, A3H2VRMAN978L8, AJDLMR90OUTD1, AMUTUR US, ANYONGBO, Bo Yuan Chuang, Chengshikekaoxiaolanjun, chentongslakxiecjer, CHuang'T'ou, CJIANQQ1818, Ckaodiog, daerzichichi, favorandy, FLASNAKE, fusyida, gongguipingijyu, GuozxSHOP, HGHZZ8978, huanlanshanghang, jiaaixuan-shop, KIRIN-7 DAYS-15DAYS DELIVERY, KTDBD, lanshanquxuanboshipinjinxiaobu, LiPeng ShiJiuJie, LJWYKF, Lxhdy, mi du mao yi, mound island, PbLoveHome, qqkdedianoo, Rfvbnsx, Spencer Colleen, SSHIZ, SUOSAN, TangKun, tianshengxiandedian, TREUTRIWRHW, tsGAcn, vfdsjsabfasf, wangshilongdedian, watre, WEIJIAJCAI, WIRJN25, woroom101, wuwenhongbaihuo, WwSsYy2319, XiaMenShiHuLiQuYiHuaZhiMingHuaHuiDian, xiaotong-shop, XINFUZHIJIA, XUNJINGWANGLUO, xushaok, yidian-shop, Yiyongxiang, You yi, yuhuiming7333, yujiangqushaofanbaihuoshanghang, yunchengshiyunchengjingjijishukaifaqucuilangongyi, yunhengshanghang, Yunxiaoxiancuifeibaihuodian, yunxiaoxianshuoroubaihuodian, ZBINM, ZHANG ERPENG, zhijiangshinatingshangmaoyouxiangongsi, Zhou XJ, zinuocat, zumL, hfove_76, multi-goldtechnolog0, pian-1329, traceabilitymedicalbea-0, yanyanw, Electrician Guy, HaiMai Technology (Shenzhen) Co., Ltd., LuckFlower Shop, One Click Co., Ltd, shanghaimengqiwangluokejiyouxiangongsi, yuanjiesm, carpet_plus, chulinzhen223, dongzi2, e4uuzd, feizhongzhishang, Gendigu, guodandan2b, Headings51, Huamei Jewelry World, huanglongkun, huangshufang123123, Juxiantange, Kawa e-Store, kozzcbhhh, lubowitzwilber, luoxiaolong19950408, My Goal - Football, qingshengshishi, renhong66058, shenzhenfeisipucoltd, VGDH456FGH, wangqia, xiaoyaojing5566, xingdongpai, yjudkcjkfyli, zengjian999 and zhaozhiwenfang added to case caption. (Text entry; no document attached.)

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/6/2023, answer due 6/27/2023.

Declaration of Trevor C. Talhami

Exhibit A

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to all Defendants with the exception of a Certain Defendant

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment, [32]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[33]

Exhibit 1

MOTION by Plaintiff Peanuts Worldwide LLC to approve consent judgment as to a Certain Defendant

Exhibit A

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of default and default judgment against the defendants identified on schedule A, with the exception of Defendant No. 97 32 is granted; Plaintiff's motion for a consent judgment as to Defendant No. 97 35 is granted. Civil case terminated. Orders to enter. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 6/30/2023. Mailed notice.

CONSENT JUDGMENT as to defendant hanghaimengqiwangluokejiyouxiangongsi (Defendant No. 97): Signed by the Honorable Rebecca R. Pallmeyer on 6/30/2023. Mailed notice.

MAILED trademark report with certified copy of minute order dated 6/30/2023 to Patent Trademark Office, Alexandria VA.

NOTICE of withdrawal of bond 24 by John Summerfield

ATTORNEY Appearance for Defendant Electrician Guy by Baruch Simcha Gottesman

MOTION by Defendant Electrician Guy to vacate order[37] Vacate Entry of Default and extend Electrician Guy's time to Answer or otherwise Move with respect to the Complaint

Text of Proposed Order

MEMORANDUM by Electrician Guy in support of motion to vacate, [42]

AFFIDAVIT by Defendant Electrician Guy in Support of MOTION by Defendant Electrician Guy to vacate order[37] Vacate Entry of Default and extend Electrician Guy's time to Answer or otherwise Move with respect to the Complaint [42]

Exhibit A - "You do not have Permission" messages for ECF 2, 18, 23

Exhibit B - Docket in Peanuts Worldwide LLC v. The Partnerships, et al., 1:23-cv

Exhibit C - Docket in Purple Innovation v. Chuang Fan Handicraft, et al., 2:22-c

Exhibit D - Screenshots from chinafirewalltest.com

Exhibit E - Order in Mwami v. U.S., et al., 1:99-cv-125 (D.D.C.)

Exhibit F - Order in Langford v. Jurez Cartel, et al., 1:20-cv-132 (D.N.D.)

Exhibit G - Proof of Service in Purple Innovation v. Chuang Fan Handicraft, et a

Exhibit H - Brief of Amici Curiae in Palace Skateboards Grp. v. Aimeey, et al.,

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Response to Defendant Electrician Guy's motion to vacate, 42 is due on or before 9/19/2023 and defendant's reply is due on or before 9/26/2023. Mailed notice.

RESPONSE by Peanuts Worldwide LLCin Opposition to MOTION by Defendant Electrician Guy to vacate order 37 Vacate Entry of Default and extend Electrician Guy's time to Answer or otherwise Move with respect to the Complaint 42

DECLARATION of Marcella D. Slay regarding response in opposition to motion, 46

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(Exhibit 6)

REPLY by Electrician Guy to memorandum in support of motion 43, affidavit in support of motion, 44, MOTION by Defendant Electrician Guy to vacate order 37 Vacate Entry of Default and extend Electrician Guy's time to Answer or otherwise Move with respect to the Complaint 42, response in opposition to motion, 46

Affidavit Affidavit in Further Support (responding to factual claims of Plaintiff's purported search for Defendant's address)

Exhibit A - Baidu Baike (Encyclopedia Entry) of Defendant in original and Chrome translation

Exhibit B - Google Search and Copy of First Entry

(Exhibit C - Bing Map Search for Defendant's Address)

NOTICE by Peanuts Worldwide LLC of Recent Related Decision

(Exhibit 1)

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Rachel S Miller

Notice of Recent Related Decision by Peanuts Worldwide LLC

(Exhibit Exhibit 1)

MINUTE entry before the Honorable Rebecca R. Pallmeyer: On May 26, 2023, this court issued an order [28] directing that Schedule A to the Complaint [2], Exhibit 4 to the Declaration of Carrie J. Dumont in Support of Plaintiff's Motion for Temporary Restraining Order [18], and the Temporary Restraining Order [23] be unsealed. In its recent memorandum accompanying its motion to vacate the default judgment [43], Defendant Electrician Guy flagged that these documents remain under seal. The court apologizes to the parties for this clerical error and directs the Clerk to unseal the record in this case. Emailed notice

MEMORANDUM Opinion and Order signed by the Honorable Rebecca R. Pallmeyer on 6/25/2024: Defendant's motion to vacate the entry of default and default judgment [42] is denied. Emailed notice

NOTICE of appeal by Electrician Guy regarding orders 53 Filing fee $ 605, receipt number AILNDC-22190127. Receipt number: n

DOCKETING Statement by Electrician Guy regarding notice of appeal 54

NOTICE of Appeal Due letter sent to counsel of record regarding notice of appeal 54

TRANSMITTED to the 7th Circuit the short record on notice of appeal 54. Notified counsel

ACKNOWLEDGMENT of receipt of short record on appeal regarding notice of appeal 54 ; USCA Case No. 24-2170

ORDER - Circuit Rule 33 dated 8/01/2024 from the 7th Circuit regarding notice of appeal 54 ; Appellate case no. : 24-2170: Pursuant to Circuit Rule 33, all proceedings in this appeal are STAYED pending further court order. Counsel for the Appellant and Appellee are directed to make a telephonic or electronic mail Status Report to the Circuit Mediation Office on August 30, 2024. This requirement may be satisfied by filing a motion under Fed. R. App. P. 42(b) to dismiss the appeal.

MANDATE of USCA dated 8/28/2024 regarding notice of appeal 54 ;USCA No.24-2170 ; No record to be returned.

CERTIFIED COPY OF USCA JUDGMENT dated 8/28/2024 regarding notice of appeal 54 ; USCA No. 24-2170.