2025-cv-01537

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23082194.

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 Robert W. Gettleman. Designated as Magistrate Judge the Honorable Young B. Kim. 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: A2130A45BFQ9RT, A3SQLQ7BQXBNAG, ADLACE, Desai saije, dingmeimeibvf, Guangzhoucanlingyanshangmaoyouxiangongsi, Jiangjianqingq, linyuxingbdgt, liuggfa, phoenix nirvana clothing-polo shirt, putianshichengxiangquzhaoshenshuoshangmaoyouxiango, shaoqujishangmao, tongdianshangmaoyouxiangongsi, Week Wua Writing, xiangyangshideheshangmaoyouxiangongsi, yashangshangmaoguangzhouyouxiangongsi, ZhengjiaweiUS, yoqloe, ABKIQFWA, CQDAZFWD, FXLPBB, LWXBD, Tide FrontStudio, Fashionab, KIIKN, Youpin Supermarket and KAWA e-Store added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Robert W. Gettleman: Motion for leave to file under seal [3] is granted. Emailed notice

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]

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]

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) [19] and Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery [14] are granted. Enter sealed order. Telephonic hearing set for 3/4/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 2/19/2025. Emailed notice

Registry Deposit Information Form by Merch Traffic, LLC

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

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

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

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[28]

Declaration of Kahlia R. Halpern

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/27/2025, answer due 3/20/2025.

Declaration of Luana Faria de Souza

Exhibit A

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Trevor Christian Talhami

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 3/4/2025. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion for Entry of a Preliminary Injunction 28 is granted. Enter order. The Law Firm of Greer Burns & Crain, 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 at: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf The Clerk is directed to unseal Schedule A to the Complaint 2, Seller Aliases screenshots attached to the Declaration of Emily Holt 18 and the Temporary Restraining Order 23. Telephonic hearing set for 4/22/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 3/4/2025. Emailed 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[34]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[35]

Exhibit 1

ATTORNEY Appearance for Defendant Tide FrontStudio by Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tide FrontStudio

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to certain defendant

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

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 4/22/2025. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion for Entry of Default and Default Judgment as to All Remaining Defendants [34] is granted. Enter order. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 4/22/2025. Emailed notice

MAILED final trademark report with a copy of minute entry [41] and final judgment [42] to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 42 in the amount of $500,000 as to certain defendants