2024-cv-09883

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22588154.

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 Kahlia Roe Halpern

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

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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 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 11

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Emily Holt regarding memorandum in support of motion 12

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1-2 regarding declaration 14

Exhibit 2-1

(Exhibit 2-2)

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 16

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

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs Motion For Leave To File Under Seal 3, Motion For Electronic Service Of Process Pursuant To Fed. R. Civ. P. 4(f)(3) 16, and Ex Parte Motion For Entry Of A Temporary Restraining Order, Including A Temporary Injunction, A Temporary Asset Restraint, And Expedited Discovery 12 are granted. Enter sealed order. Telephonic hearing set for 10/29/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Robert W. Gettleman on 10/15/2024. Emailed notice

Registry Deposit Information Form by Merch Traffic, LLC

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

INJUNCTION BOND in the amount of $10,000 posted by Merch Traffic, LLC. (Document not scanned)

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 23

Declaration of Kahlia R. Halpern

(Exhibit 1)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/24/2024, answer due 11/14/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Andrew Daniel Burnham

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 10/29/2024. No defendants appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion For Entry Of A Preliminary Injunction 23 is granted. Enter order. The Law Firm of Greer, Burns & Crain Ltd., 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: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf The Clerk is directed to unseal Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Emily Holt 15 and the TRO 20. Telephonic hearing set for 11/26/2024 at 9:30 a.m. Plaintiff's counsel is directed to file a brief status report by 11/21/2024. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 10/29/2024. Emailed notice

NEW PARTIES: A13RD7SSHDRLPE, ADemonLover, ADSCXYUS, aixindianzishangwu, AKZILNB0T89Q4, AzudDHK, BaiKunLin TingLuo, bangmei us post, binbinzishangmao, bobysaili, Bru Marting, CangZhouXiangAnJianCaiYouXianGongSi, chlinin, ciowol, Dashanjue, dsf fafafa, DZXXZX, emtraitungmin, ertqwes, facaiqiandedian, Foshanshinuomangshangdain, GONGQIANJINNNN, Guangzhou Kuangfei Trading Co., Ltd., guangzhoujiulichangmaoyishanghanggerenduzi, guangzhoushiwuxiaokejiyouxiangongsi, guchengxianxizhongfushangmaoyouxiangongsi, guozhicheng, heilongjiangyinchaoshangmaoyouxiangongsi, hengshuifanzhachuangmaoyiyouxiangongsi, hongdongxianaigukejiyouxiangongsi, horizon_studio2023, hui min, HYTDAFAC, Jade Dragon Shop, jinghui post, JUNJIEWAIMAO, KJDAIWQE, LanPingBaiH, lDiamon LI, longhaishunyi, majunjiededian, minqingxianfengxunmaoyiyouxiangongsi, NETYUREWA, Open a song, ping ping the Meeting by Chance poster, PROENDQEW, QINDALLE, qing long Feiyue poster, qinhanxinchengjijinhaobaihuodiangerenduziqiye, QQMEIL, ROHINISHUDHA, Roxanne Hrroyo, scioxzij, sdawtr, SDESXYUS, shangzusdp42, shaohaoxinxi, SHAOTONGGUORANXIANSHANGMAOYOUXIANGONGSI, shenchkunming, shi jie Instant posterYNMT, SHISHI ART SHOP, SIANHHHA, SnailDecor, Starsoundsig, suxinTao88, taiyuannuohanmaoyiyouxiangongsi, The Kitchen Storen, tiaosmer, ToddMGarcia, VA Store Big, VA StoreDN3, vssy335yafd, VZXOIJSD, wangrui2s2s2, woeryen, WRESXX, XCSOSOAA, xieqiana, xincheng-S, yaernted, YANG X JING, yangxingcuidedianpu and yanLbaby added to case caption.

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

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

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

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

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 33

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 34

(Exhibit 1)

STATUS Report per 27 by Merch Traffic, LLC

(Exhibit A)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 11/26/2024. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion for Entry of Default and Default Judgment 33 is granted. Enter order. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 11/26/2024. Emailed notice

MAILED trademark report with order dated 11/26/2024 to Patent Trademark Office, Alexandria VA

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Merch Traffic, LLC to Justin R. Gaudio Greer, Burns & Crain Ltd. 200 West Madison St Suite 2100 Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7775 84.

FULL SATISFACTION of Judgment regarding order 38 in the amount of $500,000 as to certain defendants