2024-cv-05521

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 405, receipt number AILNDC-22198106.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

(Exhibit 6)

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 Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2). (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

Exhibit 3

(Exhibit 4)

DECLARATION of Candace Arrington regarding memorandum in support of motion 15

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 5 Parts 1-6 regarding declaration 17

Exhibit 5-1

Exhibit 5-2

Exhibit 5-3

Exhibit 5-4

Exhibit 5-5

(Exhibit 5-6)

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 19

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

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 14, motion for miscellaneous relief 19 before Honorable Jorge L. Alonso on 7/16/2024 at 09:30 AM.

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for leave to file under seal 3 is granted. Plaintiff's Ex Parte Motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14 is granted. Enter Sealed temporary restraining order. Plaintiff's Motion for electronic service of process pursuant to Fed.R.Civ.P.4(f)(3) 19 is granted. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 7/16/2024. Notice mailed by Judge's staff

ENTERED IN ERROR.

Registry Deposit Information Form 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 28

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 29

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time 28 before Honorable Jorge L. Alonso on 7/25/2024 at 09:30 AM.

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

NOTICE of Correction regarding 32

MINUTE entry before the Honorable Jorge L. Alonso: The Court grants Plaintiff's motion to extend TRO 28. Telephonic status hearing set for 8/13/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

BOND in the amount of $90,000 company check, receipt no. 100008905, posted by Peanuts Worldwide LLC. (Text entry; no document attached.)

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 35

Declaration of Trevor C. Talhami

(Exhibit 1)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 35 before Honorable Jorge L. Alonso on 8/13/2024 at 09:30 AM.

(Exhibit A)

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/8/2024, answer due 8/29/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to a certain Defendant

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 9/25/24 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction as to certain Defendants [35] is granted. Enter Preliminary Injunction Order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 8/13/2024. Notice mailed by Judge's staff

NEW PARTIES: Changsha Dongguan Packaging Products Co., Ltd., Dongguan Jiujie Toys Manufacturing Co., Ltd., Dongguan Longtang Toys Co., Ltd., Fujian Kaopu Commodity Co., Ltd., Fuxiang Gaoxin(Shenzhen) Electronic Ltd., Fuzhou Youfanyuansu Furniture Trade Co., Ltd, Ji'an Aili Arts Crafts Co., Ltd., Jiaxing Super Creator Housewares Co., Ltd., Jinjiang Chengle Shoes And Garment Co., Ltd., Jinjiang Chidian Town Weiwei Shoemaking Accessory Store, Jinjiang Chizhiheng Trading Co., Ltd., Market Union Co., Ltd., Nanchang Momoer Commodity Co., Ltd., Quanzhou Hao Qi Trading Co., Ltd., Quyang County Jiazhong Garden Sculpture Co., Ltd., Shaanxi Small Magic Frog Trading Co., Ltd., Shanghai Heyi Network Technology Co., Ltd., Shaoxing Baifeng Textile Co., Ltd., Shenzhen Beiqiaowest Technology Co., Ltd., Shenzhen Hart Stationery Co., Ltd., Shenzhen Justdu Electronic Co., Ltd., Shenzhen Pengrui Technology Co., Ltd., Shenzhen Shenman Technology Co., Ltd., Shenzhen Wangshun Computer Embroidery Co., Ltd., Shishi Xinshi Trade Ltd, Shishi Xiongshengxingchao Garment Accessories Co., Ltd., Suzhou Q Textile Co., Ltd., Tonglu Zhuowai E-Commerce Co., Ltd., Yiwu Hebi Pet Products Co., Ltd, Yiwu Qianju Trading Co., Ltd., Zhaoqing Daqingtian Electronic Commerce Co., Ltd., Zhengzhou Luoyou Import And Export Trade Co., Ltd., Zhuji City Soft Xuan Knitting Co., Ltd., A2EX0P6OTF2ZD8, A2MTLLG4XQUJD4, A59R8RT5WWFL8, BOSHLIN, changshashiyuhuaquyaochengdianshanggongzuoshi, chaohuitee, Chilynie Patch, ChuangwuSD, Fcongyu Flag, Handmade Nhat Minh Shop, Hengzhizhen, HHuoLigrto, HUYEN TRANG Mobile, Hvukeke, KANG1BAIYUN, LeALe, lijuantee, longmenxianpinglingxinxinzibaihuodian, MAC THI NHAN 888, MINMINVN, QAVINU, QAVINU OFFICIAL, QY SIGN, shuangyuedianzishangwu, SX-CASH, The FapBlue Tv, wang6erming, XiXianXinQuQinHanXinChengMengXiangDaBaiHuoDian, xuanshibaihuo, Yangjiangshijipaganshangmaoyouxiangongsi, yexinge-shangmao, yueyanghuaabaihuodian, YuLiWuLi, YYANGP, ZhaOBiN, ZhuangFeng Trading Co., Ltd, chaozi62, ColoringbookUS, conggu19, coporwe, drg088, hrz-0322, johnb-29, nnup1-64, osblas_0, serinaxiexie, TDSTART, wang4738, willouu, xianpuhaojiefengsh_0, yunnanshiyinshan-0, LiYuShengHua shop, Lv Liang kitchenware store, Roilykary, SHANGNIULU Online and YUZHONGCN added to case caption. (Text entry; no document attached.)

ATTORNEY Appearance for Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd. by Christopher Paul Keleher

MOTION by Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd. To Modify Asset Restraint

Exhibit Declaration store principal

Exhibit Storefront webpage

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for miscellaneous relief[43] before Honorable Jorge L. Alonso on 9/11/2024 at 09:30 AM.

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

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment[46]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[47]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment[46] before Honorable Jorge L. Alonso on 9/10/2024 at 09:30 AM.

Exhibit A

RESPONSE by Zhaoqing Daqingtian Electronic Commerce Co., Ltd.in Opposition to MOTION by Plaintiff Peanuts Worldwide LLC for entry of default MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to all Defendants [46]

Exhibit Proposed default judgment order

Exhibit Hearing Transcript before Judge Manish Shah

REPLY by Peanuts Worldwide LLC to response in opposition to motion, [50]

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 9/10/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's response to Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd.'s Motion to modify the asset restraint 43 shall be filed by 9/24/24; Defendant's reply shall be filed by 10/1/24. Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd. shall answer or otherwise plead by 9/24/24. Plaintiff's Motion for entry of default and default judgment 46 is granted in part, with the exception of Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd. Enter Default Judgment Order. Motion hearing date of 9/11/24 is stricken. Telephonic status hearing previously set for 9/25/24 is stricken and reset to 10/8/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

FINAL Judgment Order. Signed by the Honorable Jorge L. Alonso on 9/10/2024. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order[54] in the amount of $50,000 as to certain defendants

RESPONSE by Peanuts Worldwide LLCin Opposition to MOTION by Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd. To Modify Asset Restraint [43]

DECLARATION of Jennifer V. Nacht regarding response in opposition to motion[56]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

FULL SATISFACTION of Judgment regarding order[54] in the amount of $50,000 as to certain defendant

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd.

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment, [59]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[60]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, [59] before Honorable Jorge L. Alonso on 10/3/2024 at 09:30 AM.

Exhibit A

REPLY by Zhaoqing Daqingtian Electronic Commerce Co., Ltd. to response in opposition to motion[56] To Modify Asset Restraint

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/3/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Defendant's oral motion for further extension if denied. Plaintiff's Motion for entry of default and default judgment against Zhaoqing Daqingtian Electronic Commerce Co., Ltd. [59] is granted. Enter Final Default Judgment Order. Defendant Zhaoqing Daqingtian Electronic Commerce Co., Ltd.'s Motion to modify the asset restraint [43] is denied as moot. Status hearing previously set for 10/8/24 is stricken. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 10/3/2024. Notice mailed by Judge's staff

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

FULL SATISFACTION of Judgment regarding order 54 in the amount of $150,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 54 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 67, order 54 in the amount of $200,000 as to certain Defendants

FULL SATISFACTION of Judgment regarding order 54 in the amount of $150,000 as to certain defendant