2025-cv-02307

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23166895.

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 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.

NEW PARTIES: Ableton13, anhuiyiqiangwuyefuwuyouxiangongsi, changyundianzishangwu, cqian753, dfgertsdf, eqieuqaa, faxinshangmao, GuangZhouFuJianShangMaoShangHang(GeRenDuZi), hdguangzhoulixinshangmaoyouxiangongsi, jilinshengxiangyunlaiwuliuyouxiangongsi, junxuyouxiangongsi, liuyangshiranmohuobaihuoyouxiangongsi, LiXiangLi Poster, luminchan, mengchengxiananxinyitongshangmaoyouxiangongsi, NHI 2001 SHOP, SDddSHOP, shengxidunshangmaoyouxiangongsi, Tommy shelbe, XingTaiShiDiShouDianZiShangWuYouXianGongSi, XingTaiShiKuaKaShangMaoYouXianGongSi, XingTaiShiLiNeShangMaoYouXianGongSi, XingTaiShiPoAiShangMaoYouXianGongSi, XingTaiYuZhuoKeJiYouXianGongSi, XingTaiZhaoZhuoKeJiYouXianGongSi, Yang xiong, yichunyuanzhouqufaxiuyangzhiyouxiangongsi, ZhuZhouDuoYunMaoYiYouXianGongSi, ziye159, leenato, LovelyTee Store, nam1069, zhanghao00, zozoshop19, Bendaisy09, ERIOYIO and xinmamaoyi 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]

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 (etc.) [13] is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 3/24/2025 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 or motion to extend TRO must be filed by 3/19/2025. 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. Plaintiff is also advised that an insufficient interval between service of summons and the preliminary injunction hearing may result in denial of a preliminary injunction due to inadequate notice of the lawsuit. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 3/10/2025.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 3/10/2025.

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

SURETY BOND in the amount of $ 10,000.00 posted by Merch Traffic, LLC

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

MEMORANDUM by Merch Traffic, LLC in support of extension of time[28]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[29]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of the temporary restraining order [28] is granted; the ex parte TRO entered by the Court on 3/10/2025 is extended through 4/7/2025. The telephonic preliminary injunction hearing set for 3/24/2025 is vacated and reset to 4/7/2025 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 4/2/2025. Plaintiff is reminded that an insufficient interval between service of summons and the preliminary injunction hearing may result in denial of a preliminary injunction due to inadequate notice of the lawsuit.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 32

(Declaration of Kahlia R. Halpern)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/24/2025, answer due 4/14/2025.

Declaration of Kahlia R. Halpern

(Exhibit A)

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or an answer to the complaint or a response to the motion for preliminary injunction. Plaintiff's motion for entry of a preliminary injunction 32 is granted. Enter Preliminary Injunction Order. 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 telephonic motion hearing and preliminary injunction hearing set for 4/7/2025 is vacated. The case is set for a telephonic status hearing on 6/12/2025 at 8:50 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 6/5/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 4/7/2025. 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 37

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 38

(Exhibit 1)

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default 37 is granted. Final Default Judgment Order to follow. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 4/28/2025. Mailed notice.