2023-cv-16337

COMPLAINT filed by Pit Viper, LLC; Filing fee $ 402, receipt number AILNDC-21371577.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Pit Viper, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Pit Viper, LLC

Notice of Claims Involving Trademarks by Pit Viper, LLC

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Trevor Christian Talhami

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.

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Sunil R. Harjani. Case assignment: Random assignment. (Civil Category 2).

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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

MEMORANDUM by Pit Viper, 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 Vance Lommen regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 2 - Parts 1 - 9 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

Exhibit 2-8

(Exhibit 2-9)

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

MEMORANDUM by Pit Viper, 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)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 18, motion for temporary restraining order 13 before Honorable Elaine E. Bucklo on 12/6/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Motion for leave to file under seal [3] is granted. Motion for TRO [13] is granted. Enter Order. Motion for electronic service of process [18] is granted. Motion hearings set for 12/6/2023 are stricken. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 12/5/2023.

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

INJUNCTION BOND in the amount of $10,000.00 posted by Pit Viper, LLC. (Document not scanned).

MINUTE entry before the Honorable Elaine E. Bucklo: Because the temporary restraining order will expire on 12/19/2023, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 12/15/2023. Greer, Burns & Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. 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. The case is set for a status hearing on 1/19/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 1/12/2024 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

MOTION by Plaintiff Pit Viper, LLC for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Pit Viper, LLC in support of motion for preliminary injunction[27]

Declaration of Rachel S. Miller

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction[27] before Honorable Elaine E. Bucklo on 12/19/2023 at 09:45 AM.

Exhibit A

NEW PARTIES: Party Life (xiamen) Technology Co., Ltd., AOZE Online Store, VAGHOZZ Store, A3K6GSZ4ECF64, abudulaabudureyimu, AMZ-FMY, Biboli, chenwufang, Cloudigo Fashion Official, Crayot, CYFGG, Dikasa Fashion, duxiangwangluoyou, ENSHIZHOUCHUIZISHANGMAOYOUXIANGONGSI, FFPE, GOENDR-US, HT HERBS, JiegoVision, kunmingyancongyingshangmaoyouxiangongsi, Lazybear shop, lihaiqingkeji, Louriy-US, Mermaid Ltd., MingShangMaDouMeng, QULIT-US, Roaqua, rotateman, SHIHUAWEI, SiSuShangMao, TTOAOKE US, US-AOYIKEJI, VisBeaut, Waladaseller, WANWAN-US, WUSHUAIWU, Xpose, Zhengyinhuans, zhijiangshipianjushangmaoyouxiangongsi, ZhouJuanDuanWangLuoKe, a31415928, amazingme, cccdhgateso, chanelnecklace3, cjrj, cool_sunglasses, designersunglasses168, destin2, fashion1999go, fashionbomb, fsy901yy, gaozhou000, gucciglasses, gwnz, hautecouture66, hautecouture77, hautecouture88, hautecouture99, hot_sale1688, iloveyouforever, jlyx, kenneth333, kjchannel, l57s, lazyfashion, lluis, luxury_lovebelt, luxury16888, luxury1899, massager_vibrator, metrostore, mg1d, monikofashion, ninn, pccf, penldant05, perfumeb01, perfumeb03, qqqww12343, s2zx, sextoy_play, sexy_adult, sunglasses_gg, sunglasseslmj2023, topfashionstore666, wangmingfa1, wearewinnder, weping, zhangmao02, zqiuyan666, zqiuyan688, zshy1988, biangeart, yuxi_1973, aolu, babaoshacc, babaoshaee, BIg BULL A, BURUOO, Elise glasses, Fit Viir Outdoor Fshion Snglas, gettnle, leesheng, leeshenga, Like Buying This, LOTFASHION, MAYSUN sunglasses, RayBliss Sunglasses, SunTrend Sunglasses, zhaomong, zhaomonga, zhaomongd, ZOOZW, Hefei liaoshou building materials co., ltd, dingyuxuan8128, disenos3d, weilubo1234, xuangaoqian8385 and yanbaolong0649 added to case caption.

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/14/2023, answer due 1/4/2024.

Declaration of Trevor C. Talhami

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo:Bucklo: Plaintiffs' motion for entry of preliminary injunction as to certain defendants [27] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint [2], Exhibit 2 to the Declaration of Vance Lommen [17] and the TRO [23]. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 12/19/2023. Mailed notice.

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to certain defendant

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/28/2023: Mailed notice.

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/3/2024, answer due 1/24/2024.

Declaration of Trevor C. Talhami

Exhibit A

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to certain defendants

STATUS Report per 26 by Pit Viper, LLC

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff report there's active settlement negotiations with several defendants. Plaintiff will move for default judgment at a later date where appropriate, the status hearing is reset for 2/15/2024 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 2/8/2024. The court will enter an order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to certain defendant

MOTION by Plaintiff Pit Viper, LLC for entry of default, MOTION by Plaintiff Pit Viper, LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Pit Viper, LLC in support of motion for entry of default, motion for default judgment 41

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 42

(Exhibit 1)

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment 41 before Honorable Elaine E. Bucklo on 1/31/2024 at 09:45 AM.

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment [41] as to all remaining defendants is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the cash bond posted in the amount of ten thousand dollar ($10,000) to Plaintiff or its counsel by check made out to the Greer Burns & Crain IOLTA account. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 1/30/2024. Mailed notice.

MAILED trademark report with certified copies of orders dated 1/30/24 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $250,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 46 in the amount of $250,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[46] as to certain defendant

FULL SATISFACTION of Judgment regarding order[46] in the amount of $250,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[46] in the amount of $250,000 as to certain defendants