2025-cv-01180

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23042055.

(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 Joan H. Lefkow. Designated as Magistrate Judge the Honorable Maria Valdez. 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.

NEW PARTIES: A9902SGCQZACR, B2C iiii shop, chenghaojiaoyu, fansmerten, fanwei llc, guangzhoudingpuxiangshangmaoshanghanggerenduzi, guangzhoulinzeshangmaoyouxiangongsi, HOAN VNA, KHANH LINH CD, llllqqe, LuBaiXinMaoYiYouXianGongSi, LUONG VB HP, mouduisd, oufangjunnnn, qing chen Youth poster, QuanMeiKanManZhiBaiShangMao, Renailing D, sdiojfoc, taizhoushibabaoyuanyiyouxiangongsi, tinghuandou, VA Store2N, VA StoreDN9, VA StoreKIT, VA StroreDN3, vciojdoifg, wuwujj, xciosajdo, xuhaodongmeijindanbaohaodian, YANYANZHEN, Zhaojinzeng, ZhenGuangPuCu, GETHIS, KLD Tees, Modern Corner, super oil painter, Fashion Icon, shenzhenshiyuangmaoyiyouxiangongsi, taiyuanlianjunhangmaoyi, u+i. and XWZO cloth added to case caption.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Virginia M. Kendall for all further proceedings pursuant to the provisions of 28 USC 294(b). Mailed notice

(Request for reassignment) (ags)

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 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

(Exhibit 2-1)

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 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 temporary restraining order 14, motion for leave to file 3, motion for miscellaneous relief 19 before Honorable Virginia M. Kendall on 2/13/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing is reset for 2/12/2025 at 9:30 AM. Mailed notice

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Hannah Alexa Abes

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 2/12/2025. Oral argument heard from Plaintiff's Counsel regarding Motion for Temporary Restraining Order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery 14. Plaintiff's Motion for Temporary Restraining Order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery 14 is granted in part and denied in part. The Court denies Motion for Temporary Restraining Order to include a Temporary Injunction and a Temporary Asset Restraint 14. Plaintiff's Motion for expedited Discovery 14 is granted. Plaintiff's Counsel shall provide the Court with a proposed Order regarding expedited Discovery and non disclosure on or before 2/14/2025. Plaintiff's Motion for leave to file under seal 3 and Motion for electronic service of process 19 are granted. Status hearing set for 3/5/2025 at 9:30 AM. Mailed notice

MOTION by Plaintiff Merch Traffic, LLC for reconsideration regarding order on motion for leave to file, order on motion for temporary restraining order, order on motion for miscellaneous relief, motion hearing, set deadlines/hearings, 25

(Exhibit 1)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for reconsideration, 26 before Honorable Virginia M. Kendall on 2/20/2025 at 09:30 AM.

TRANSCRIPT OF PROCEEDINGS held on 02/12/2025 before the Honorable Virginia M. Kendall. Motion Hearing. Order Number: 51039. Court Reporter Contact Information: Gayle A. McGuigan, CSR, RMR, CRR, Gayle_McGuigan@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 3/13/2025. Redacted Transcript Deadline set for 3/24/2025. Release of Transcript Restriction set for 5/21/2025.

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 2/20/2025. Oral argument heard regarding Motion for Reconsideration 26. The Court takes Motion for Reconsideration 26 under advisement. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 3/5/2025 is stricken. Mailed notice

TRANSCRIPT OF PROCEEDINGS held on 02/20/2025 before the Honorable Virginia M. Kendall. Motion Hearing. Order Number: 51161, 51162, 51163. Court Reporter Contact Information: Gayle A. McGuigan, CSR, RMR, CRR, Gayle_McGuigan@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 3/25/2025. Redacted Transcript Deadline set for 4/4/2025. Release of Transcript Restriction set for 6/2/2025.

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 4/16/2025 at 9:30 AM. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 4/16/2025 at 9:30 AM will NOW PROCEED VIA WEBEX. Prior to the hearing, you are directed to cut and paste this hyper link into a browser: https://us-courts.webex.com/join/virginia_kendallilnd.uscourts.gov You can use the dial in option ONLY if you do not have access to a device with video capability: (650)-479-3207, the access code is: 180 698 4009. 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 Virginia M. Kendall. Status hearing held on 4/16/2025 via Webex. The Court indicated a written Order regarding Motion to Reconsider 26. Status hearing set for 5/1/2025 at 9:30 AM.Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Merch Traffic, LLC's ("Plaintiff") Motion for Reconsideration 26 of the Court's Order 25 denying in part Plaintiff's Motion for a Temporary Restraining Order 14 is granted. Taking a fresh look at Plaintiff's arguments in its written submission and those made orally during the 2/20/2025 Motion Hearing, the Court finds that joinder of the Defendants in this matter will "promote[] judicial economy while protecting the interests of the parties[.]" Zou v. The Entities, et al., No. 23-cv-16600 (N.D. Ill. Mar. 8, 2024) (ECF No. 60 at 3). Refusing to join the Defendants requires Plaintiffs to make a difficult choice between seeking expedited discovery at the expense of monetary relief at the end of this case and filing a "series of multiplying cases." (Dkt. 26 at 2). Joining the Defendants, on the other hand, provides the Plaintiffs with a meaningful chance at relief while minimizing the burden on the Court's docket. Moreover, joinder poses no risk of prejudice or unfairness to the various Defendants, who will each have an opportunity to defend against Plaintiff's claims in the same way they would if the cases were filed separately. Discretionary joinder as the best path forward. Accordingly, the Court strikes its Order 25 and grants Plaintiff's Motion for a Temporary Restraining Order 14. The Temporary Restraining Order shall remain in effect until 4/30/2025. Status hearing set for 5/1/2025 is reset for 4/30/2025 at 9:30 AM. Plaintiff shall provide an updated Proposed Order to the Court for entry. Mailed notice

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 4/17/2025. Mailed notice

Registry Deposit Information Form by Merch Traffic, LLC

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

SURETY BOND in the amount of $ 10,000.00 posted 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 42

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 43

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 42 before Honorable Virginia M. Kendall on 4/30/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for extension of Temporary Restraining Order 42 is granted. Temporary Restraining Order shall remain in effect up to and including 5/15/2025. Status hearing is set for 5/22/2025 at 9:30 AM. If a hearing is needed prior to 5/22/2025, please contact the emergency duty Judge. Status and Motion hearing set for 4/30/2025 are stricken. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Status hearing set for 5/22/2025 is reset for 5/20/2025 at 9:30 AM. 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 48

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 49

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 48 before Honorable Virginia M. Kendall on 5/20/2025 at 09:30 AM.

(Exhibit A)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/12/2025, answer due 6/2/2025.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Virginia M. Kendall. Motion and Status hearing held on 5/20/2025. Plaintiff's Motion for Preliminary Injunction 48 is granted. Order to follow. Plaintiff advised he will be filing a Motion for default and default judgment. Mailed notice

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 5/20/2025. 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 55

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 56

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 55 before Honorable Virginia M. Kendall on 6/12/2025 at 09:30 AM.

(Exhibit A)

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion due to a Jury Trial proceeding, Motion hearing set for 6/12/2025 is reset for 9:00 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 6/12/2025 is reset for 12:30 PM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 6/12/2025. Plaintiff's Motion for entry of default and default judgment 55 is granted. Enter Order of default as to all remaining Defendants in this case. Judgment Order to enter. Mailed notice

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 6/12/2025. Mailed notice