2023-cv-04165

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 402, receipt number AILNDC-20783431.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Merch Traffic, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Merch Traffic, LLC

Notice of Claims Involving Trademarks by Merch Traffic, LLC

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Jeffrey I. Cummings. Case assignment: Random assignment.

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.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

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

MEMORANDUM by Merch Traffic, LLC in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Emily Holt regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1 - 6 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

(Exhibit 2-6)

MOTION by Plaintiff Merch Traffic, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Merch Traffic, LLC in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [13] is granted. Plaintiff's motions for leave to file under seal [3] and for electronic service of process [18] are granted. Enter temporary restraining order.Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 7/5/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 129,000 posted by Merch Traffic, LLC (Document not scanned.)

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 24

Declaration of Justin T. Joseph

(Exhibit 1)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/14/2023, answer due 8/4/2023.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [24] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 7/24/23 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4 Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 7/17/2023. Mailed notice

NEW PARTIES: Abi Poster Store, Anime Design Factory Store, Anime Streetwear Store, Chevy Store, Danangua Store, Eharlien Official Store, Eleanos Art Store, erdongH Store, GDD Store, Good Quality Clothes K2 Store, Heavydun Official Store, High quality clothing XB335 Store, JellyCase Store, Kavsenraies Factory Store, KK07 Store, Lavendercases Store, Linerken Factory Store, Lulikaby Factory Store, qiyue007 Store, Shop1102374506 Store, Shop1102435364 Store, Shop1102439310 Store, Shop1102440288 Store, Shop1102525698 Store, Shop1102694493 Store, Shop1102697437 Store, Shop1102709318 Store, Shop1102712311 Store, Shop1102713298 Store, Shop1102714256 Store, Shop1102714264 Store, Shop1102753347 Store, Shop5259129 Store, Shop910558321 Store, Shop911884165 Store, Simpleguy Store, Skull Island Store, The 1990 Phone Cases Store, WGTD Tshirt 2 Store, XHL Store, Yingke Store, ZJTHREEZJ Store, ZKK Store, AUGETY, chenguanqingsdyt, chenjiafuksjdk, douxingbiao59977, foshanshinanhaiquliulvshangmaoyouxiangongsi, FXCNIUBI, gaokuanzzsf, guangzhoushuishangshangmaoyouxiangongsi, HEFANCC, hefeixiongyushangmaoyouxiangong, HuangYicai Art, kunmingqianxuanjingmaoyouxiangongsi, licongcongs, Linweixiong Art, LiuLSGMT, Pataishangmaoyouxiangongsi, sichuanyunhaojiachengkejiyouxiangongsi, This is a late night shop, wanzaixianyizhichaobaihuo, wujianmingyys, wujingyuanolmk, XUEXXX, yangyuesjhdjz, youzhangteuuww, ZENGDAXT, Zhuzyu Art, Allegroo, Angorabest, Braces, Cansonglai, Charle, Eei9, H151, Hongpingguog, Luweiha, P94y, Pjpx, R5k1, Sjvb, V6s0, Yachtt, BINFA-Wall Art, jiujiangyonghanmuxiaoshou Co.ltd, Ningboshi Dajidianzikeji Co.ltd, zhengzhousankecongshangmao Co.ltd, 19830923WWFG, asdasd125454, baoxiaolong8084, d4g5g55, Daniel D Murphy, Duanliuliu78523, dunaizhi2221, efwqbj, Enrique McDaniels, gutao135134, guyueyue, Hhkkj, huigui, huwenjing fashion, limingrong8338, liuxiaohai39058, liuzilong40921, Marjorie D Blount, Panshunhong3399, qiuhan31791, Rosa Gonzalez66, siyan583, Vendoudu Toys, wangrongkun24092, wangzeqi0505, wanxianzongqin, weimeiyue6688, wuguangying, wuhuilingg, xiao jun 668, xushengfei1073, yanruohan668, YINPING678, yuanhaiqin15245, zhangguotao14776, zhangming520, zhangxiaoying31217, zhaoxinming, zhaozhijie55322, zhongjian78154 and zhoufeng55200 added to case caption.

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 29 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants numbers 44, 85, 87, and 88 are dismissed from this case. Mailed notice

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/28/2023, answer due 8/18/2023.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 32 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 53 is dismissed from this case. Mailed notice

MOTION by Plaintiff Merch Traffic, LLC for entry of default, MOTION by Plaintiff Merch Traffic, LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment[34]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[35]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 34 is taken under advisement. Any objections or responses are due by 9/4/23. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 34 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/5/2023. Mailed notice

MAILED trademark report along with certified copies of order and judgment dated 9/5/2023 to Patent Trademark Office, Alexandria VA

NOTICE of Removal of Material from the Custody of the Clerk's Office by John Summerfield (Received for docketing 4/5/2024)

NOTICE of withdrawal of Surety Bond 23 in the amount of $ 129,000 by John Summerfield from Greer, Burns & Crain, Ltd. (Received at the Intake Counter on 3/29/24). (Received for docketing on 4/05/24).