2024-cv-12443

2024-cv-12443 Merch Traffic, LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :12/4/2024
Court :Northen District of Illinois
Law FirmGBC

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Date

Document

1

Dec. 4, 2024

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22797596.

Exhibit 1

2

Dec. 4, 2024

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding complaint 1

3

Dec. 4, 2024

MOTION by Plaintiff Merch Traffic, LLC for leave to file under Seal

4

Dec. 4, 2024

CIVIL Cover Sheet

5

Dec. 4, 2024

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Merch Traffic, LLC

6

Dec. 4, 2024

Notice of Claims Involving Trademarks by Merch Traffic, LLC

7

Dec. 4, 2024

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Justin R. Gaudio

8

Dec. 4, 2024

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Amy Crout Ziegler

9

Dec. 4, 2024

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

10

Dec. 4, 2024

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

Dec. 4, 2024

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 2).

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

NEW PARTIES: zhouzhengmingliang added to case caption.

11

Dec. 4, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3] before Honorable John Robert Blakey on 12/11/2024 at 11:00 AM.

12

Dec. 5, 2024

MAILED trademark report to Patent Trademark Office, Alexandria VA

13

Dec. 5, 2024

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

14

Dec. 6, 2024

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

(Exhibit 1)

15

Dec. 6, 2024

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding amended complaint 14

16

Dec. 6, 2024

MOTION by Plaintiff Merch Traffic, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

17

Dec. 6, 2024

MEMORANDUM by Merch Traffic, LLC in support of motion for temporary restraining order 16

18

Dec. 6, 2024

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

19

Dec. 6, 2024

DECLARATION of Emily Holt regarding memorandum in support of motion 17

(Exhibit 1)

20

Dec. 6, 2024

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 regarding declaration 19

(Exhibit 2-1)

21

Dec. 6, 2024

MOTION by Plaintiff Merch Traffic, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

22

Dec. 6, 2024

MEMORANDUM by Merch Traffic, LLC in support of motion for miscellaneous relief 21

23

Dec. 6, 2024

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

24

Dec. 6, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 21, motion for temporary restraining order 16 before Honorable John Robert Blakey on 12/18/2024 at 11:00 AM.

26

Dec. 10, 2024

SEALED ORDER Signed by the Honorable John Robert Blakey on 12/10/2024. Mailed notice

25

Dec. 11, 2024

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, the Court grants Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [21]. The Court also grants Plaintiff's ex parte motion for entry of a temporary restraining order [16]. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 12/24/24. The 12/18/24 Notice of Motion date is stricken as to all motions. Mailed notice

27

Dec. 11, 2024

Registry Deposit Information Form by Merch Traffic, LLC

28

Dec. 13, 2024

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

29

Dec. 13, 2024

MEMORANDUM by Merch Traffic, LLC in support of extension of time 28

30

Dec. 13, 2024

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 29

31

Dec. 13, 2024

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 28 before Honorable John Robert Blakey on 12/18/2024 at 11:00 AM.

32

Dec. 17, 2024

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's ex parte motion 28 to extend the temporary restraining order entered 12/10/24 25 and strikes the 12/18/24 Notice of Motion date. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 1/7/25. Mailed notice

33

Dec. 17, 2024

SURETY BOND in the amount of $ 10,000.00 posted by Merch Traffic, LLC (Document not scanned).

38

Dec. 20, 2024

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.

34

Dec. 26, 2024

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)

35

Dec. 26, 2024

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 34

Declaration of Kahlia R. Halpern

(Exhibit 1)

36

Dec. 26, 2024

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 34 before Honorable John Robert Blakey on 1/8/2025 at 11:00 AM.

(Exhibit A)

37

Dec. 26, 2024

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/26/2024, answer due 1/16/2025.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

39

Jan. 6, 2025

MINUTE entry before the Honorable John Robert Blakey: Based upon the Court's trial schedule, the 1/8/25 Notice of Motion date is stricken, and the hearing on Plaintiff's motion for preliminary injunction 34 is hereby reset to 1/10/25 at 11:00 a.m. in Courtroom 1203. Mailed notice.

40

Jan. 9, 2025

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Lucas Allen Peterson

41

Jan. 10, 2025

MINUTE entry before the Honorable John Robert Blakey: Defendant has neither filed an appearance in this matter or otherwise objected in response to the TRO or Plaintiff's motion for entry of a preliminary injunction [34]. Accordingly, and based upon the same findings made in this Court's TRO [26], this Court finds that a preliminary injunction is appropriate and warranted, as well as unopposed and grants Plaintiff's motion for preliminary injunction [34]. Enter Preliminary Injunction Order. The Court directs the Clerk to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add the defendant to the Court's docket within three business days. Plaintiff may find instructions at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Plaintiff shall file a status report by 2/24/25. Mailed notice.

42

Jan. 10, 2025

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable John Robert Blakey on 1/10/2025. Mailed notice.

43

Jan. 22, 2025

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)

44

Jan. 22, 2025

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment 43

45

Jan. 22, 2025

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 44

(Exhibit 1)

46

Jan. 22, 2025

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 43 before Honorable John Robert Blakey on 1/29/2025 at 11:00 AM.

(Exhibit A)

47

Jan. 28, 2025

MINUTE entry before the Honorable John Robert Blakey: Based upon the Court's trial schedule, the 1/29/25 motion hearing date is stricken and reset for 2/5/25 at 11:00 a.m. in Courtroom 1203. Mailed notice.

48

Feb. 4, 2025

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

49

Feb. 5, 2025

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 2/5/2025 regarding Plaintiff's motion for entry of default and for default judgment as to Defendant zhouzhengmingliang 43. Defendant having failed to appear to object to the motion or otherwise, and for the reasons explained in the accompanying order, the Court grants Plaintiff's motion for entry of default and default judgment 43. Enter Default Judgment Order. All matters in dispute now having been resolved, the case is closed. Civil case terminated. Mailed notice.

50

Feb. 5, 2025

FINAL JUDGMENT ORDER. Signed by the Honorable John Robert Blakey on 2/5/2025. Mailed notice.

51

Feb. 5, 2025

MAILED trademark report with judgment dated 2/5/25 to Patent Trademark Office, Alexandria VA

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