2023-cv-06510

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 402, receipt number AILNDC-20986726.

Exhibit 1

Exhibit 2

Exhibit 3

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 Manish S. Shah. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. 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.

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 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Carrie J. Dumont regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 4 - Parts 1 - 6 regarding declaration 14

Exhibit 4-1

Exhibit 4-2

Exhibit 4-3

Exhibit 4-4

Exhibit 4-5

(Exhibit 4-6)

MOTION by Plaintiff Peanuts Worldwide LLC for 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 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for temporary restraining order 11, motion for miscellaneous relief 16 before Honorable Manish S. Shah on 9/6/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process [3] [11] [16] are granted, and no appearance on the motions is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 9/5/2023. Notices mailed.

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

SURETY BOND in the amount of $ 50,000 posted by Peanuts Worldwide LLC.

MOTION by Plaintiff Peanuts Worldwide LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Peanuts Worldwide LLC in support of extension of time 23

(Declaration of Marcella D. Slay)

NOTICE of Motion by Marcella Deshonda Slay for presentment of extension of time 23 before Honorable Manish S. Shah on 9/19/2023 at 09:45 AM.

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

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 23 is granted, and no appearance on 9/19/23 is necessary. The TRO is extended to 10/3/23. Notices mailed.

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 28

Declaration of Marcella D. Slay

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction 28 before Honorable Manish S. Shah on 10/3/2023 at 09:45 AM.

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/28/2023, answer due 10/19/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Quinn Bradley Guillermo

MINUTE entry before the Honorable Manish S. Shah:Motion hearing held. As stated on the record, the motion for preliminary injunction [28] is granted. Enter Preliminary Injunction Order. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Manish S. Shah on 10/3/2023. Mailed notice

NEW PARTIES: Cangnan Achieve Arts And Crafts Co., Ltd, Foshan Youle Network Technology Co., Ltd., Guangzhou Blue Snail Electronics Co., Ltd., Shantou Great Technology Company Limited, Shenzhen Rui Cai Gifts Co., Ltd., Shenzhen Tianyucai Label Technology Co., Ltd., Shenzhen Yurui Technology Co., Ltd., Xiangtan Ocean-Map Textile Garment Co., Ltd., Yiwu Baimao Arts & Crafts Co., Ltd., Yiwu Quello Import And Export Co., Ltd., Yiwu Weihao Jewelry Factory, 138 Dcover Store, 247 GoodLuck Store Store, Animation Peripheral Fabric Store, Curiosity Toy Store, Fish Music Toy Store, HappyPlanet-HR Store, JunMiao Toy One Store, Lovely Small Toys Store, Mobile 3C NO275 Store, NiceDIY Pro Patch Store, Nuts & Milk Store, Rocks Toy Store, Sanrio Girls Toys JYY Store, Shop1102115633 Store, Shop1102325087 Store, Shop1102516867 Store, Shop1102697742 Store, Sugar Doughnuts Store, The Homesick Store, Tidal Store, UNIPRO Official Store, Wow-surprise Store, Xinfa Mobile Phone Accessories Store, A2YF3ZA82X81GD, AHNNER GARDEN, AlexaTony, amazazan, anh khoa t Shop, Biamigjz, binzhouzhixindianzishangmao, chenjiannandianpu, chenxiaomeii, DAGUYS, DOINB TIAN, Gan Ke Shang Mao, Guangdong Renmei Trading Co Ltd, guangzhounuocaizeshangmao, guolixd, GXTONG, gzhouyingsishangmaoyouxian, Haylee Waters, HeMM, hongdongxianchongrengkejiyouxiangongsi, huagefu(7 days to 18 days to delivery), huang kai yi shang mao, Jackson Andorra, Jarkko Store, jinpingshang, KristyDT, kunmingqingmendianzishangwuyouxiangongsi, lcs123, LGG HOUSE, linnuojiayao, LiSujungybihGYUKH, luanruishanghang, M&L Shop US, NALNANE, neimenggujiehuidianzishangwuyouxiangongsi, Net Tradelink, NUMATU SHOP, QINMINNINGDEDIANPUADRG, RedSamall-US, rongshangda, RrRuoHua, SATACA, SDHM99 DS, Shengxiang Tian(7 days to 18 days to delivery), SMSUOMIDE, Tyrync, uytyFGA, WANGLI YA, weicengtong, xinweilong, XOKUL Stickers, XUANLIN-ZHU, Yarushangmao, Yezijiaouzhouzhan, yishanbanghai, Yiyongxiang, Your Store Stickers, zinuocat, Zocoshi, ZZHONGKK18, bagdesigner, fashiongirl08, guasong, luxury_shop58, mvp_bags, nanguaguo, visney, weddingzone, 5025006, ab-327851, baopingfeng, brian-eustace, card-1388-8, card-1988, hellokitty-shop, juanlin_crystal, lei96_55, luogang37, maxin36541, mingli-9649, newexstore, phuquyllc, sofie2326, tientranxd12, tinghan1shangmao, top-rate-store, wangxi8574758, xeent-56, xeent94, yangchen_2023, yxs-good-seller, Brother fashion, bluegalaxysjc, Classical painting Art Print, opuinkom, Uucomehere and Yocozy added to case caption.

Terminating DOINB TIAN

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

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

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

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

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

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

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

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/17/2023, answer due 12/8/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

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

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to Certain Defendants

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default as to all Defendants, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment[45]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[46]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment[45] before Honorable Manish S. Shah on 12/19/2023 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment 45 is granted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Manish S. Shah on 12/19/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding order 51 in the amount of $50,000 as to certain defendant