2024-cv-12421

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22794378.

(Exhibit 1)

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 Sharon Johnson Coleman. 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.

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

NEW PARTIES: nitkunmingr added to case caption.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff is put on notice that it may be required to file a memorandum discussing the propriety of joinder under Federal Rule of Civil Procedure 20(a)(2) if it appears that defendants are too numerous or unconnected. In addition, should default judgment enter against defendant(s), Plaintiff should be prepared to prove up damages by affidavit or hearing. Mailed notice.

AMENDED complaint by Merch Traffic, LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding amended complaint[12]

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]

DECLARATION of Emily Holt regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 regarding declaration[17]

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[19]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 19, motion for temporary restraining order 14 before Honorable Sharon Johnson Coleman on 12/12/2024 at 10:15 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Presentment of plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] set for 12/12/2024 at 10:15 AM is reset to 10:00 AM (NOTE TIME CHANGE ONLY) as an in-person hearing in courtroom 1241. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 12/12/2024. Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] are granted. Enter Order. An in-person status hearing is set for 12/20/2024 at 10:15 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 12/12/2024. Mailed notice.

Registry Deposit Information Form by Merch Traffic, LLC

MOTION by Plaintiff Merch Traffic, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Merch Traffic, LLC in support of extension of time 27

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 28

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 27 before Honorable Sharon Johnson Coleman on 12/20/2024 at 10:15 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's ex parte motion to extend the Temporary Restraining Order 27 is granted. Enter Order. No appearance necessary on 12/20/2024. The in-person status hearing set for 12/20/2024 is stricken and reset to 1/8/2025 at 10:00 AM. Mailed notice.

EXTENSION OF TEMPORARY Restraining Order. Signed by the Honorable Sharon Johnson Coleman on 12/17/2024. Mailed notice.

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 Honorable Virginia M. Kendall on 12/20/2024: Mailed notice.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 33

(Declaration of Kahlia R. Halpern)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 33 before Honorable Sharon Johnson Coleman on 1/8/2025 at 10:00 AM.

(Exhibit A)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/27/2024, answer due 1/17/2025.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 1/8/2025. Defendant did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction [33] is granted. Enter Order. The Clerk of Court is directed to unseal plaintiff's Schedule A to the Complaint [2], Schedule A to the Amended Complaint [13], Exhibit 2 to the Declaration of Emily Holt, and the Temporary Restraining Order [25]. An in-person status hearing is set for 2/24/2025 at10:30 AM. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Sharon Johnson Coleman on 1/8/2025. Mailed notice.

MOTION by Plaintiff Merch Traffic, LLC for entry of default, MOTION by Plaintiff Merch Traffic, LLC for default judgment as to Defendant nitkunmingr and the Individuals and Entities Operating nitkunmingr

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment, [41]

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

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [41] before Honorable Sharon Johnson Coleman on 1/28/2025 at 10:00 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Jennifer Van Nacht

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 1/28/2025. Defendant did not appear nor contact the Court. Plaintiff's motion for entry of default and default judgment [41] is granted. Default judgment is entered in favor of plaintiff and against defendant identified in the Amended Schedule A to the Complaint. Enter Order. The one thousand dollar ($1,000) bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. Status hearing set for 2/24/2025 is stricken. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Sharon Johnson Coleman on 1/29/2025. Mailed notice.