2025-cv-01395

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23065029.

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 Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

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 liutianshun, the Individuals and Entities Operating liutianshun and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

(Exhibit 1)

MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff has filed a complaint alleging infringement by 48 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 20 is rarely appropriate in Schedule A cases. Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder on or before February 25, 2025. Alternatively, by the same date, the plaintiff may file an amended complaint naming one or more defendants; however, if the plaintiff names multiple defendants, the plaintiff must show that joinder of those defendants is proper. All pending motions are hereby stayed pending resolution of the joinder issue. Mailed notice.

EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding amended complaint, 13

Notice of Withdrawal of Plaintiff's Motion for Leave to File Under Seal 3 by Merch Traffic, LLC

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[18]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[18], motion for discovery[17] before Honorable Jeremy C. Daniel on 5/22/2025 at 09:30 AM.

ORDER. Signed by the Honorable Jeremy C. Daniel on 5/13/2025. Motions [17] and [18] are granted. The motion hearing is stricken. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) liutianshun and the Individuals and Entities Operating liutianshun by Plaintiff Merch Traffic, LLC

SUMMONS Issued (Court Participant) as to Defendants liutianshun, the Individuals and Entities Operating liutianshun

MINUTE entry before the Honorable Jeremy C. Daniel: Status hearing set for 6/3/2025 at 9:30 a.m. Mailed notice.

SUMMONS Returned Executed by Merch Traffic, LLC as to liutianshun on 5/19/2025, answer due 6/9/2025; the Individuals and Entities Operating liutianshun on 5/19/2025, answer due 6/9/2025.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to liutianshun and the Individuals and Entities Operating liutianshun

MINUTE entry before the Honorable Jeremy C. Daniel: Pursuant to the Notice of Dismissal [27], this case is dismissed without prejudice. Civil case terminated. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MINUTE entry before the Honorable Jeremy C. Daniel: Any party to this action has until October 21, 2025, to justify the continued need to seal any documents in this case. The Court intends to unseal all documents in this case after that date. Mailed notice.