2025-cv-01080

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23029559.

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 Steven C. Seeger. 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.

MINUTE entry before the Honorable Steven C. Seeger: An initial status report is due by April 21, 2025. Counsel must read the Standing Order entitled "Initial Status Conferences and Joint Initial Status Reports" on the Court's website. The parties must confer as required by Rule 26(f) about the nature, scope, and duration of discovery. The parties must submit two documents to the Court. First, the parties must file the Joint Initial Status Report under Rule 26(f) on the docket. A Word version of the Joint Initial Status Report is available on the Court's website. All parties must participate in the preparation and filing of the Joint Initial Status Report. The Court requires a joint report, so a filing by one side or the other is not sufficient. Second, the parties must email a Word version of a proposed Scheduling Order under Rule 16(b) to the Court's proposed order inbox. Lead counsel for the parties must participate in filing the initial status report. Plaintiff must serve this Order on all other parties. If the defendant has not been served with process, plaintiff's counsel must contact the Courtroom Deputy at jessica_j_ramos@ilnd.uscourts.gov to reschedule the initial status report deadline. Plaintiff should not file the Joint Initial Status Report before the defendant(s) has been served with process. The parties must discuss settlement in good faith and make a serious attempt to resolve this case amicably. All counsel of record must read and comply with this Court's Standing Orders on its webpage. Please pay special attention to the Standing Orders about Depositions and Discovery. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

AMENDED complaint by Merch Traffic, LLC against homepro5 and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

(Exhibit 1)

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. 3) is hereby denied for the reasons stated by the Court in Zorro Productions, Inc. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (23-cv-5761). Mailed notice.

MOTION by Plaintiff Merch Traffic, LLC for discovery Expedited

(Exhibit 1)

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 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

MINUTE entry before the Honorable Steven C. Seeger: At the plaintiff's request, the deadline to file a joint initial status report is extended to June 10, 2025. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to conduct expedited discovery (Dckt. No. 16) is hereby granted. Plaintiff's motion for electronic service of process (Dckt. No. 17) is hereby granted. Order to follow.Mailed notice

ORDER GRANTING EXPEDITED THIRD-PARTY DISCOVERY AND ELECTRONIC SERVICE OF PROCESS Signed by the Honorable Steven C. Seeger on 4/25/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) homepro5 by Plaintiff Merch Traffic, LLC

SUMMONS Issued (Court Participant) as to Defendant homepro5

MINUTE entry before the Honorable Steven C. Seeger: On April 25, 2025, the Court granted Plaintiff's motion for expedited third-party discovery and electronic service of process (Dckt. No. 22). The Court permitted third parties 14 days to respond to discovery requests. Plaintiff had an obligation to serve those requests in a timely manner. Plaintiff must file a status report by May 9, 2025. Plaintiff must serve process by May 23, 2025. The Court expects Plaintiff to keep this case moving along. The Court directs the parties to engage in meaningful, good faith settlement discussions at the earliest opportunity. A failure to comply will lead to appropriate relief, including dismissal. Mailed notice

SUMMONS Returned Executed by Merch Traffic, LLC as to homepro5 on 5/5/2025, answer due 5/26/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff recently served process on Defendant. An answer is due by May 26, 2025. (Dckt. No. 26) The Court expects Plaintiff to move the case along in a timely manner. If Defendant misses the deadline, Plaintiff must file a motion for the entry of default and a default judgment no later than two business days after the deadline. A response to the motion for default judgment is due two weeks later. The Court reminds Plaintiff of the need to submit a Word version of a proposed judgment to the proposed order inbox, Proposed_Order_Seeger@ilnd.uscourts.gov. Plaintiff must serve a copy of this order and file a certificate of service. A failure to comply will lead to appropriate relief, including dismissal or the entry of judgment. Mailed notice (gel,)

CERTIFICATE of Service by Plaintiff Merch Traffic, LLC regarding set deadlines, 27

(Exhibit A)(Faria De Souza, Luana)

MOTION by Plaintiff Merch Traffic, LLC for entry of default, MOTION by Plaintiff Merch Traffic, LLC for default judgment as to Defendant Homepro5

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment[29]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[30]

Exhibit 1

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's motion for the entry of default and default judgment (Dckt. No. 29). The deadline to respond to the complaint has come and gone. The response to the complaint is late. The Court hereby enters default under Rule 55(a) against Defendant Homepro5. As noted in the Court's previous order dated May 6, 2025 (Dckt. No. 27), any response to the motion is due two weeks after the motion that is, by June 11, 2025. A failure to respond will lead to appropriate relief, including granting the motion and entering final judgment. The Court directs the parties to engage in good faith, energetic settlement discussions. Plaintiff must serve a copy of this order and file a certificate of service. Mailed notice

CERTIFICATE of Service by Plaintiff Merch Traffic, LLC regarding text entry, 32

(Exhibit A)(Faria De Souza, Luana)

STATUS Report pursuant to [20] by Merch Traffic, LLC

Exhibit A

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's motion for the entry of default and default judgment against Defendant homepro5 (Dckt. No. 29). The response to the complaint is long overdue. Defendant did not respond to the motion for default judgment, either. The Court set a deadline of June 11, 2025 for Defendant to respond. That deadline has passed. The motion for default judgment is hereby granted. The Court hereby enters default judgment against Defendant homepro5 under Rule 55(b). Final Judgment Order and Permanent Injunction Order to follow. The case is closed. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Steven C. Seeger on 6/12/2025. Mailed notice.

PERMANENT INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 6/12/2025. Mailed notice.