2025-cv-01960

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23130733.

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 Georgia N Alexakis. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 4/24/25 at 9:30 a.m. in person in Courtroom 1719. By 4/17/25,the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's motion to seal is granted [3]. Upon review of the complaint, the Court sua sponte raises the propriety of joining 18 defendants in a single action. By 3/12/25, plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of this Court's orders in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28 (N.D. Ill. Oct. 28, 2024), and Anagragam International v. The Partnerships, 24 CV 12194, Dkt. 87 (N.D. Ill. Feb. 21, 2025). In the alternative, plaintiff has leave to file an amended complaint by 3/12/25 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting this Court's order in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025).

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 guangzhoulizhangshangmaoshanghanggerenduzi, the Individuals and Entities Operating guangzhoulizhangshangmaoshanghanggerenduzi 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, 15

MOTION by Plaintiff Merch Traffic, LLC for discovery Expedited

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 Georgia N Alexakis on 4/10/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's motions for expedited discovery and electronic service of process are granted [17], [18]. No appearance is required on 4/10/25. The Court finds that expedited discovery is warranted to identify defendants. The Court also finds that electronic service does not violate any treaty and is consistent with due process because it is an effective way to communicate with the online marketplace defendants. The Court decides these issues, however, without the benefit of adversarial presentation. If any defendant were to appear and object, the Court will take a fresh look at the issues of electronic service and expedited discovery as well as any issues related to personal jurisdiction and joinder. Enter Order, as modified by the Court.

ORDER Signed by the Honorable Georgia N Alexakis on 4/8/25.

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

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

SUMMONS Returned Executed by Merch Traffic, LLC as to guangzhoulizhangshangmaoshanghanggerenduzi on 4/15/2025, answer due 5/6/2025; the Individuals and Entities Operating guangzhoulizhangshangmaoshanghanggerenduzi on 4/15/2025, answer due 5/6/2025.

Declaration of Luana Faria de Souza

Exhibit A

STATUS Report pursuant to [11] by Merch Traffic, LLC

Exhibit A

MINUTE entry before the Honorable Georgia N Alexakis: Upon review of the plaintiff's status report 27, the Court resets the initial status hearing scheduled for 4/24/25 to 5/13/25 at 9:30 a.m., although the Court will vacate the 5/13/25 status hearing if plaintiff files a motion for entry of default before then.

NOTICE of Voluntary Dismissal by Merch Traffic, LLC

MINUTE entry before the Honorable Georgia N Alexakis: Per Plaintiff's notice of voluntary dismissal, pursuant to Federal Rule of Civil Procedure 41(a)(1), plaintiff's claims in this matter as to Defendant guangzhoulizhangshangmaoshanghanggerenduzi and the individuals and entities operating guangzhoulizhangshangmaoshanghanggerenduzi are dismissed without prejudice. Civil case terminated. Mailed notice.

MAILED Trademark report and closing order to Patent Trademark Office, Alexandria VA.