2025-cv-01531

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23081844.

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 Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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: A2NDOWXD5QE9N4, A2UTPXY9PBAKEJ, CAO NGUYEN STORE 234254, gfbugbiuh, guangzhouyouhangdianzishangwuyouxiangongsi, guizhouxinyuetedajiuyeyouxiangongsi, GYHUHYH, hfghdh, KEKU, ludianzhengxiangshangmaoyouxiangongsi, MANMAN12, Matthewvery, Pengjianbo123, suhaoyu2023, UmayaLife USA, wangguanglei078, WangQiangWangLuoKeJiYouXianGongSi, wshtyyy, wuhumuyingshangmaoyouxiangongsi, Wuzhaotang, Xian You You Zhi Chen Mao Yi You Xian Gong Si, yangyangzeze, Yanyany L, YiQingYuanGuoPinYouXianGongSi, zhaohaibobaihuo, NowArtWorld, trr-quan, Bingbing Liang wall art, Liang Jingjing wall art, Metro Male, Original Life Style, Rainbow cabin wall art, ZFKVK, BINH MINH LTD and Nanjingmengyiyuanjiudianguanliyouxiangongsi added to case caption.

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[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Emily Holt regarding memorandum in support of motion[12]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 regarding declaration[14]

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[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [16] are granted. Plaintiff's ex parte motion for entry of a temporary restraining order [11] is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 3/4/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend the TRO must be filed by 2/27/2025. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. In addition plaintiff must promptly serve summons electronically. If there is an insufficient interval between service of summons and the preliminary injunction hearing the Court may deny entry of a preliminary injunction due to inadequate notice of the lawsuit. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 2/18/2025.

Registry Deposit Information Form by Merch Traffic, LLC

MAILED Trademark report to Patent Trademark Office, Alexandria VA

(List of Tradmarks, Ex. 1)

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

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Merch Traffic, LLC

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

INJUCTION BOND in the amount of $ 10,000 posted by Merch Traffic, LLC (Document not scanned)

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction, MOTION by Plaintiff Merch Traffic, LLC for extension of time of the Preliminary Injunction Hearing and Temporary Restraining Order

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction, extension of time, [27]

Declaration of Kahlia R. Halpern

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/26/2025, answer due 3/19/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: The Court denies plaintiff's motion for entry of a preliminary injunction [27] due to an insufficient interval between electronic service of summons (on 2/26/2025) and the preliminary injunction hearing (3/4/2025). The Court is no longer sua sponte extending the ex parte TRO in these circumstances; plaintiff will have to file a motion. The telephonic preliminary injunction hearing set for 3/4/2025 is converted to a telephonic status hearing at the same date and time.

MOTION by Plaintiff Merch Traffic, LLC for reconsideration regarding order on motion for preliminary injunction, order on motion for extension of time, terminate motions, [30]

Exhibit A

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

MOTION by Plaintiff Merch Traffic, LLC for extension of time of Temporary Restraining Order

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of extension of time 33

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 34

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic preliminary injunction hearing held on 3/4/2025. Plaintiff's motion for reconsideration 31 is denied for the reasons stated on the record. The case is set for a telephonic status hearing on 3/18/2025 at 8:55 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. 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 Matthew F. Kennelly: Plaintiff's motion for extension of the ex parte TRO is granted based on plaintiff's showing of good cause. The ex parte TRO entered by the Court on 2/18/2025 is extended through 3/18/2025. Telephonic preliminary injunction hearing is set for 3/18/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction must be filed by no later than 3/13/2025. Mailed notice.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction (renewed)

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 38

(Declaration of Kahlia R. Halpern)

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has appeared or responded to the complaint or the motion for preliminary injunction. Plaintiff's motion for entry of a preliminary injunction is granted 38. Enter Preliminary Injunction Order. The telephonic hearing set for 3/18/2025 is vacated. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 5/20/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 5/13/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 3/17/2025. 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[42]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for default judgment 42 is set for a telephonic hearing on 4/7/2025 at 8:55 AM, using call-in number 650-479-3207, access code 2305-915-8729.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default 42 is granted. Final Default Judgment Order to follow. Any hearing dates before this Court are stricken. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 4/7/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order 47 in the amount of $50,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[47] in the amount of $50,000 as to certain defendant (Faria De Souza, Luana)