2025-cv-00411

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22950190.

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 Andrea R. Wood. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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: Dongguan Metro Clothing Co., Ltd., Dongguan Qianlong Clothing Co., Ltd., Fuzhou Taijiang District Celier International Trade Co., Ltd., Guangzhou Qixiang Trading Co., Ltd., Guangzhou Yingling Clothing Co., Ltd., Guangzhou Zhongzhige Clothing Co., Ltd, Hebei Mofeite Import And Export Trade Co., Ltd., HYASIA ELECTRONIC Co.,Ltd, Longyan Huixun E-Commerce Co., Ltd., Zhongshan Mengqi E-Commerce Co., Ltd., A1JHGNLYGDGHK8, A28F2L49S487Z5, A2C5YDAIYK17UF, A2EXHOP0OZQ7MS, A2RM9XI6BYDKJK, A2SKFF4H6MIC8B, A3FOMB5XODJ41I, ADAI art shop, awendeshenghuoxiaopu11, AWXTOFDMLRC4Z, Cranesa, Dawn M Kusch, Doyimlth, dsgdfgdfsgsdf, EmilyRFlores, Enriqmith, Guangzhouyonghangshangmaoyouxiangongsi, Hosvwus, huan fa shun, HUONG CBA, Jinsine, Ladily, LILIN ART SHOP, Michijalva, NaiMoDongUs, oiuhjkmgf, pengmiaodianzi, Puchu Trade, QinAnXianLongChengZhenGuiPingZhuanChang, SJL poster shop, TAYOKII, TylerDHart, VT STOREDN, WandaHLawrence, weibao us post, ZaoQiangHongXiWuJinZhiZaoYouXianGongSi, ZHIYONG POSTER, ZR Poster, good_choice003, my_style07, rykeri, vgtees, acwa21da, cvno2716, lamu7140, lizhi48, ruoyueliangyilai, sonandtee, thidu-6, wangyaqi7, wanzheyaowanggaochu, weik9662, yangchaozheng, zhouweixian-0, AOTEMANNA, Dwight Decor, Jalang, OO Canvas, Sensen wall art, jingshenmaoyi, WAAYTYBINBIN and xuhao neiyi & added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

DECLARATION of Emily Holt regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1-2 regarding declaration 16

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 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

MINUTE entry before the Honorable Andrea R. Wood: 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 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 1/30/2025 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 1/30/2025. For the reasons stated on the record, 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 [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A regarding complaint [2], and (2) Exhibit 2 - Parts 1-2 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 1/30/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 2/13/2025 at 11:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 1/30/2025. 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[26]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[27]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend temporary restraining order 26 is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 2/27/2025. Telephonic status hearing set for 2/13/2025 is stricken and reset for 2/27/2025 at 10:45 PM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

ATTORNEY Appearance for Defendant Ladily by Steven G Kalberg

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[31]

Declaration of Kahlia R. Halpern

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/21/2025, answer due 3/14/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction [31] will be heard at the telephonic hearing set for 2/27/2025 at 10:45 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

ATTORNEY Appearance for Defendant Jinsine by Steven G Kalberg

MEMORANDUM by Jinsine, Ladily in Opposition to motion for preliminary injunction[31]

Exhibit List

Declaration of Sara Wang

Declaration of Vivi Chow

Exhibit A Jinsine Sales Data

Exhibit B Jinsine Amazon.com Account Balance

Exhibit 1 Ladily Sales Data

Exhibit 2 Ladily Amazon.com Account Balance

REPLY by Plaintiff Merch Traffic, LLC to Defendants' Opposition to Plaintiff's Motion for Entry of a Preliminary Injunction [36]

DECLARATION of Kahlia R. Halpern regarding reply[37]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 2/27/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 31 is entered and continued. Defendants Ladily and Jinsine are granted leave to supplement their opposition brief 36 by 3/5/2025. The Temporary Restraining Order is extended until 3/7/2025 to ensure Defendants receive adequate notice and an opportunity to be heard regarding the motion for a preliminary injunction. Any party aggrieved by the extended Temporary Restraining Order may file a motion for relief to be heard on an emergency basis. Telephonic status hearing set for 3/7/2025 at 9:45 am. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

SUPPLEMENT to memorandum in opposition to motion, 36

Supplemental Declaration of Sara Wang

Supplemental Declaration of Vivi Chow

Exhibit C Jinsine Supplemental Sales Data

(Exhibit 3 Ladily Supplemental Sales Data)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/7/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [31] is granted with the modifications discussed on the record. Defendants Ladily and Jinsine shall respond to Plaintiff's discovery requests by 3/21/2025. By 3/28/2025, the parties shall file a joint status report stating whether based on the discovery that's been provided are the parties in agreement as to the sales associated with the accused products, and if not, what the difference of opinion is. Telephone status hearing is set for 4/2/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 3/7/2025. Mailed notice

MOTION by Defendants Jinsine, Ladily for extension of time to file answer regarding complaint 1 or otherwise respond (unopposed)

MINUTE entry before the Honorable Andrea R. Wood: Defendants Jinsine and Ladily's unopposed motion for a first extension of time to answer or otherwise respond to Plaintiff's complaint 43 is granted. Defendants Jinsine and Ladily shall answer or otherwise respond to the complaint by 4/14/2025. Mailed notice

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

STATUS Report per 41 (Joint) by Merch Traffic, LLC

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/2/2025. As discussed on the record, any motion for entry of default and default judgment shall be filed by 4/18/2025. Telephonic status and motion hearing set for 4/24/2025 at 10:00 AM. Any party wishing to oppose the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to participate in the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

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 48

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 49

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment as to all remaining Defendants 48 will be heard at the telephonic hearing set for 4/24/2025 at 10:00 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Thomas Joseph Juettner

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/24/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [48] is taken under advisement. Telephonic status hearing set for 5/9/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment as to all remaining Defendants 48 is granted. Enter Default Judgment Order. All claims as to all Defendants are now resolved. All future hearing dates are stricken. This case is closed. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 4/29/2025. Mailed notice