2024-cv-01640

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-21682578.

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 Marcella Deshonda Slay

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2).

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.

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Plaintiff's motion for leave to file under seal 3. Plaintiff may file the following documents under seal: (1) Schedule A attached to the Complaint and (2) Exhibit 2 to the Declaration of Emily Holt. Emailed notice

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 14

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Emily Holt regarding memorandum in support of motion 15

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1-3 regarding declaration 17

Exhibit 2-1

Exhibit 2-2

(Exhibit 2-3)

MEMORANDUM by Merch Traffic, LLC Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum 19

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

(Exhibit 8)

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 21

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 22

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion for a temporary restraining order [14], and motion for electronic service of process [21]. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 3/7/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 3/5/2024. Emailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified in the Complaint (jcc,)

Registry Deposit Information Form by Merch Traffic, LLC

BOND in the amount of $10,000.00 check, Receipt. No. 100003520 posted by Merch Traffic, LLC

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[27]

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 3/18/2024, answer due 4/8/2024.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction [27] is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint [2]; (2) Exhibit 2 to the Declaration of Emily Holt [18]; and (3) the TRO [25]. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Emailed notice

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 3/19/2024. Emailed notice

NEW PARTIES: Guangzhou Shanzhan Trading Co., Ltd., Shenzhen HMD E-Commerce Co., Ltd., An Interesting Shop Store, BBTHBDNBY ALILI Store, HomeCraft DIY Store, Shop1102788506 Store, Shop1102832216 Store, Shop1102853470 Store, Shop1103041593 Store, Yinuoda Poster 218 Store, YUQI DE HOME1 Store, A46S30IKJEZY9, AH37LDUS9XWLX, DUCHANHVNSTORE, Felizer Factory Store, ganhuiie, guohongqiang, jiayuxianhua, LiangWanYinShangMaoYouXianGongSi, Pagreus, putianshichengxiangquwanenjumaoyiyouxiangongsi, ruandoudoumaoyi, squaretek, stalker mich, TJCIIAANITRE, zhijiangshimujianshangmaoyouxiangongsi, babiq06, bdo6, designer168clothing, edhv, fsuh, hzjxmf002, igpvb, kenneth_store, kgm3, kupb, lvlz, lyix, m2l3, nmmn, qf1z, quzmj, slrx, us_massachusetts, vmsu, xiechunlai168, youyiq5, wush15, NIDTONG and YU XI XI added to case caption.

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Luana Faria De Souza (Faria De Souza, Luana)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/24/2024, answer due 5/15/2024.

Declaration of Luana Faria de Souza

Exhibit A

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

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

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to a Certain Defendant

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[38]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[39]

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment against the Defendants Identified in Schedule A 38 is granted. Enter Final Judgment Order. The ten thousand dollar ($10,000.00) cash bond posted by Greer Burns & Crain Ltd., including any interest minus the registry fee, is hereby released to Justin R. Gaudio of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the cash bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain Ltd., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Franklin U. Valderrama on 5/22/2024. Mailed notice.