2024-cv-05838

COMPLAINT filed by Pit Viper, LLC; Filing fee $ 405, receipt number AILNDC-22228512.

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

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

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[11]

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

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Vance Lommen regarding memorandum in support of motion[12]

Exhibit 1

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 2 - Parts 1-6 regarding declaration[14]

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[16]

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

Exhibit 1

Exhibit 2

MAILED trademark report to Patent Trademark Office, Alexandria VA.

Trademarks

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

MAILED copyright report to Registrar, Washington DC.

Copyrights

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11] is granted. Plaintiff's motion for electronic service of process [16] and motion for leave to file under seal [3] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 7/16/2024. Mailed notice.

Registry Deposit Information Form by Pit Viper, LLC

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

SURETY BOND in the amount of $ 111,000 posted by Pit Viper, LLC. (Document not imaged)

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 26

Declaration of Rachel S. Miller

(Exhibit 1)

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/25/2024, answer due 8/15/2024.

Declaration of Trevor C. Talhami

(Exhibit A)

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Luana Faria De Souza (Faria De Souza, Luana)

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 30

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 31

(Exhibit 1)

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/1/2024, answer due 8/22/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion for entry of a preliminary injunction 26 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Plaintiff should file a status report by 9/16/24. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 8/9/2024. Mailed notice.

NEW PARTIES: Baolai Trade (Yiwu City) Co., Ltd., Beijing Songli Safety Product International Corp., Ltd., Cangnan Xinyun Trading Co., Ltd., Dongguan Dekai Trading Co., Ltd., Dongguan Mingyue Technology Co., Ltd., Dongguan Shangmiao International Trade Co., Ltd., Dongguan Yuan Chen Trading Co., Ltd., Foshan Nanhai Meishi Garment Facotry, Gaomi Best Crafts Co., Ltd., Guangdong Hubo Sports Products Co., Limited, Guangxi Nanning Huafeite Trading Co., Ltd., Guangzhou Dilupu Optics Technology Co., Ltd., Guangzhou Julong Sports Products Co., Ltd., Guangzhou Rongcan Trading Co., Ltd., Guangzhou Sunok Glasses Co., Ltd., Guangzhou Usom Glasses Co., Ltd., Guangzhou ZNYJ Co., Ltd., Hefei Halo Optical Technology Co., Ltd., Hunan Superhot Trading Co., Ltd., Jiangsu Yongchuang Jinggong Technology Co., Ltd., Jiaxing Shiyou Trading Co., Ltd., Linhai Aixi Glasses Factory, Linhai City Zhenqi Eyewear Firm, Linhai Cool Bar Glasses Factory, Linhai Kaihe Glasses Factory, Masa International Service(sh) Co.,ltd, Nanchang Auri Sports Products Co.,Ltd, Nanyang Guiman Trading Co., Ltd., Nanyang Xuhong Trading Co., Ltd., Ruian Qidian Eyeglasses Co., Ltd., Shanghai Xupu Gifts Co., Ltd., Shenzhen Changlifeng Technology Co., Ltd., Shenzhen Shade Glasses Co., Ltd., Shenzhen Shengyouan Industry Co., Ltd., Shenzhen Yuedong Glasses Co., Ltd., Sichuan Mozixu Technology Co., Ltd., Suzhou Fufeng Trading Co., Ltd., Taizhou Bangti Trading Co., Ltd., Taizhou Daxin Trading Co., Ltd., Taizhou Guanhong Trading Co., Ltd., Taizhou Jiaojiang Jiete Glasses Factory, Taizhou Ruixin Glasses Accessories Co., Ltd., Taizhou Shanghua Glasses Co., Ltd., Wenzhou Baibo Eyeglasses Co., Ltd., Wenzhou Changhui International Trade Co., LTD., Wenzhou Everfly Optical Co., Ltd., Wenzhou Gforce Optical Co., Ltd., Wenzhou Grand International Trade Co., Ltd., Wenzhou Hengbo International Trade Co., Ltd., Wenzhou Ivision Optical Co., Ltd., Wenzhou Kovisions Import&Export Co.,Ltd., Wenzhou Mike Optical Co., Ltd., Wenzhou Sunray Technology Co., Ltd., Wenzhou Sunway Eyewear Co., Ltd., Wenzhou Well Optical Co., Ltd., Wuhan Kaixinhong Tech Co., Ltd., Wuhan Leshenshi E-Commerce Co., Ltd., Xi 'an Million Trading Co., Ltd., Xiamen Novelty Trading Co., Ltd., Xiamen Shunfanyuan Supply Chain Co., Ltd., Yiwu Boshiming E-Commerce Co., Ltd., Yiwu Camel Imp.&exp.co.,ltd, Yiwu Chenran Jewelry Co., Ltd., Yiwu Conchen Glasses Co., Ltd., Yiwu Jinshi Trading Co., Ltd., Yiwu Jinyu Packaging Co., Ltd., Yiwu Jushan Trading Co., Ltd., Yiwu Juteng Import And Export Co., Ltd., Yiwu Kutan Online Businesses Firm, Yiwu Migic E-Commerce Firm, Yiwu Rhaegal Glasses Co., Ltd., Yiwu Rongliang Trading Co., Ltd., Yiwu Wanzhou Electronic Commerce Co., Ltd., Yiwu Xiangchen Crafts Factory, Yiwu Yihua Trade Co., Ltd, Yiwu Yiong E-Commerce Firm, Yiwu Yunji Trading Co., Ltd., Zhejiang Baolai Optical Co., Ltd., 6464lucky, long hang, OULAIQI GLASSES, cc_jewelry01, cjpl, dashu11, dh_lovejewelry, gq6b, ponyvip, Popular2024, smgm, sunglass_wow, tengdaele, tiffanmvp, trendy_jewelry_ll, truststore2021, xiaohua188, zhengminghui08, qingshuiy32, widewidepigtoycollection, EVRP Spectacle headgear hotels, B-Star, foshanshisensiyanshangmao, kanqianshangmaoyouxiangongsi, Miaojing, NOLDS, Sheiny, shiteng, wangyao, xiangpiaopiao, xianrun foods co., ltd, Yiyang aquatic products and zezh added to case caption.

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

ANSWER to Complaint with Jury Demand by Taizhou Jiaojiang Jiete Glasses Factory

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

Exhibit A

MEMORANDUM by Pit Viper, 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

Exhibit 2

MOTION by Plaintiff Pit Viper, LLC to approve consent judgment as to Certain Defendants

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Agreed motion for entry of consent judgment as to defendants nos. 105 and 106 [41] is granted. Enter Consent Judgment. Mailed notice.

CONSENT JUDGMENT Signed by the Honorable Mary M. Rowland on 8/28/2024. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Any response to motion for default [38] due 9/10/24. Status report due 9/30/24. Mailed notice.

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

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

STATUS Report per [34] by Pit Viper, LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [47]. Motion for default [38] is granted. Enter order. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 9/17/2024. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED trademark report to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order[49] in the amount of $50,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[49] in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 49 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[49] in the amount of $50,000 as to certain defendants

STIPULATION of Dismissal as to Defendant Taizhou Jiaojiang Jiete Glasses Factory (Joint) (Faria De Souza, Luana)

FULL SATISFACTION of Judgment regarding order 49 in the amount of $50,000 as to certain defendant

NOTICE of Removal of Material from the custody of the Clerk's Office 25 by Plaintiff's counsel Greer Burns & Crain Ltd. (Received at the Intake Counter on 11/21/2024). (jn,) Modified on 11/22/2024.

FULL SATISFACTION of Judgment regarding order 49 in the amount of $50,000 as to certain defendants