2025-cv-00196

COMPLAINT filed by Pit Viper, LLC; Filing fee $ 405, receipt number AILNDC-22924995.

Exhibit 1

Exhibit 2

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 Trevor Christian Talhami

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

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2).

NEW PARTIES: Dongguan Miao Xin Craft Co., Ltd., Dongguan Zhiqin Technology Co., Ltd., DYNAMICS TRADING (FOSHAN) CO., LTD, Global Best Way Co., Ltd., Golden Rice Bowl (shenzhen) Technology Co., Ltd., Haifeng County Hai City Lonico Accessories Firm (individual Business), Jiangxi Kubi Trade (Group) Co., Ltd., Jiaxing TR-Technology Co., Ltd., Linhai City Runying Glasses Co., Ltd., Linhai Eyepath Technology Co., Ltd, Linhai Hengyuan Glasses Co., Ltd., Linhai Kailong Optical Glasses Co., Ltd., Linhai Pineapple Glasses Co., Ltd., Shantou Love Summer Technology Co., Ltd., Shenzhen Yameiou Optical Co., Ltd., Taizhou Chenxiao Im&Ex Co., Ltd., Taizhou Feihong Technology Co., Ltd, Wenzhou Baibo Eyeglasses Co., Ltd., Wenzhou Brightlook Optical Co., Ltd., Wenzhou Faith Import & Export Co., Ltd., Wenzhou Sunbest Optical Co., Ltd., Wenzhou Sunray Technology Co., Ltd., Wenzhou Zheqi Glasses Co., Ltd., Xiamen Runtan Technology Co., Ltd., Yiwu Dubang Motorcycle Parts Co., Ltd., Yiwu Jinyao Apparel Co., Ltd., Yiwu Longge Accessories Limited, Yiwu Market Union Co., Ltd., Yiwu Mingkang Trading Co., Ltd., Yiwu Sunflower Electronics Commerce Co., Ltd., XIAMEN LESUI TRADING CO.,LTD, XiaXiaShangMao, YKY-US, YunHaiGJ, ch_shop6, chen_qi, cmasiyu, dh_best_sellers, dhch092204, fsy901yy, global_fashion_top1, high_quality_hoodie, hot_selling_top1, hottest_clothes, jewelryworld889, lingling11, linlingn, Munfashion, pangniu01, ppfashionshop, saror, sunglass_owow8, tgrff, top_sweet, trendy_fashion_top1, vipssdh001, wakasport3232, world_shop_yd, xlwdhgate6688, zhizhu11, freell6-7, huangjs, jcx-group, ouu8522222, vrj8722222, yongshan235, CUOZHI.CO, fengyuewenhua, haibingchuangkeji, KunMingWuHuass, lixiaoshangmao, paipaixuanni, QIANSHU, Savour, shiyanfushi and xinnanjue added to case caption.

MAILED original $79,000 surety bond posted by Pit Viper, LLC to Amy Crout Ziegler of Greer, Burns, Crain LTD. via certified mail # 7006 0100 0001 7312 5809.

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]

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

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 3 - Parts 1-2 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]

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

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 leave to file under seal [3] and motion for electronic service of process [16] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY Restraining Order Signed by the Honorable Mary M. Rowland on 3/10/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Pit Viper, LLC

Registry Deposit Information Form by Pit Viper, LLC

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

CIVIL BOND in the amount of $ 79,000 posted by Pit Viper, LLC. (Document not scanned).

MOTION by Plaintiff Pit Viper, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Pit Viper, LLC in support of extension of time[27]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[28]

MINUTE entry before the Honorable Mary M. Rowland: Motion for extension of TRO 27 is granted. TRO extended to 4/7/25. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/20/2025. Mailed notice.

MOTION by Plaintiff Pit Viper, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Pit Viper, LLC in support of motion for preliminary injunction[32]

Declaration of Trevor C. Talhami

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/1/2025, answer due 4/22/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for preliminary injunction 32 is due by 4/16/25. Status report from Plaintiff due by 4/23/25. 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 defendant

STATUS Report Pursuant to [35] by Pit Viper, LLC

Exhibit A

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

(Exhibit A)

MEMORANDUM by Pit Viper, LLC in support of motion for entry of default, motion for default judgment 39

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 40

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [38]. Without objection, motion for preliminary injunction [32] 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. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for default is due 5/15/25. Status report due 6/2/25. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 4/30/2025. Mailed notice.

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

STATUS Report Pursuant to [43] by Pit Viper, LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 46. The motion for default judgment 39 is granted against the remaining defendants unopposed. Enter Order. Civil case terminated. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: The seventy-nine thousand dollar ($79,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns, & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 6/3/2025. Mailed notice.

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

RETURN of U.S. Post Office Receipt, article no. 7006 0100 0001 7312 5809.