2025-cv-01460

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23073748.

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

CASE ASSIGNED to the Honorable LaShonda A. Hunt. 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.

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Luana Faria De Souza (Faria De Souza, Luana)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

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

AMENDED complaint by Merch Traffic, LLC against chenqiong929, the Individuals and Entities Operating chenqiong929 and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

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

MINUTE entry before the Honorable LaShonda A. Hunt: Based upon the filing of the notice of withdrawal 15, Plaintiff's motion for leave to file under seal 3 is withdrawn. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. The parties are ordered to file a Joint Initial Status Report for New Case by 6/4/25. A template for the report can be found on Judge Hunt's webpage under "Initial Status Conference and Status Report." A telephonic initial status hearing is set for 6/11/25 at 9:30AM. Attorneys/parties may appear by dialing: 1-650-479-3207 and entering access code: 2311 499 1046. No attendee code is required. Please review in advance the policies governing telephonic hearings that can be found on Judge Hunt's webpage on the court website. Mailed notice (gel,)

MOTION by Plaintiff Merch Traffic, LLC for discovery Expedited

Exhibit 1

NOTICE of Motion by Justin R. Gaudio for presentment of motion for discovery[18] before Honorable LaShonda A. Hunt on 6/10/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to conduct expedited discovery [18] is granted. The Court grants Plaintiff's request for expedited discovery as the Court finds that expedited discovery is warranted to obtain Defendant's contact information. Enter Order Authorizing Expedited Discovery. The motion hearing set for 6/10/25 [19] is stricken. If no other relief has been sought, Plaintiff is ordered to file a status report by 6/23/25 updating the Court on the progress of expedited discovery and proposed next steps in the case. Mailed notice.

ORDER AUTHORIZING LEAVE TO CONDUCT EXPEDITED DISCOVERY Signed by the Honorable LaShonda A. Hunt on 5/29/2025. Mailed notice.

MINUTE entry before the Honorable LaShonda A. Hunt: In light of the Court's order granting Plaintiff's motion for leave to conduct expedited discovery and ordering a status report be filed by 6/23/25 if no other relief has been sought 20, the joint status report deadline of 6/4/25 and telephonic initial status hearing on 6/11/25 17 are stricken. Mailed notice.

MOTION by Plaintiff Merch Traffic, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for miscellaneous relief[23]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[24]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[23] before Honorable LaShonda A. Hunt on 6/18/2025 at 10:00 AM.

Exhibit A

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for electronic service [23] is granted. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with online marketplace defendants. Enter Order Authorizing Electronic Service of Process. Motion hearing set for 6/18/25 [26] and status report deadline set for 6/23/25 [22] are stricken. A status report regarding next steps is due by 7/16/25, if other appropriate relief has not been sought by that date. Mailed notice (gel,)

ORDER AUTHORIZING ELECTRONIC SERVICE OF PROCESS Signed by the Honorable LaShonda A. Hunt on 6/11/2025. Mailed notice (gel,)

SUMMONS Submitted (Court Participant) for defendant(s) chenqiong929 and the Individuals and Entities Operating chenqiong929 by Plaintiff Merch Traffic, LLC

SUMMONS Issued (Court Participant) as to Defendants chenqiong929, the Individuals and Entities Operating chenqiong929

SUMMONS Returned Executed by Merch Traffic, LLC as to chenqiong929 on 6/11/2025, answer due 7/2/2025; the Individuals and Entities Operating chenqiong929 on 6/11/2025, answer due 7/2/2025.

Declaration of Luana Faria de Souza

Exhibit A

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to chenqiong929 and the Individuals and Entities Operating chenqiong929 (Faria De Souza, Luana)

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil Procedure 41(a)(1) and Plaintiff's Notice of Voluntary Dismissal [32], this action is being dismissed without prejudice. Any pending motions or deadlines are stricken. Civil case terminated. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: The Clerk's office is directed to unseal all documents in this case. Mailed notice (gel,)