2025-cv-02713

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23210956.

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 Manish S. Shah. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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: Dongguan Humen Xinhongxing Electrical Appliance Firm, Pujiang Jiaying Knitting Co., Ltd., InnyBin, RightLove, TongJiangJiuHuiJianSheGongChengYouXianGongSi, YUFKJ-US, ArluKin Clothing, AUAshop, Aurora engine, Blanket, Bonongma, Chic Sustainable, CITYBOY STUDIO, Cool mens wardrobe, Dream sticker shop, DSDTHREEB, FF Aluminum SHOP, Firebird Trade, FOREVER CHOW, Fun clothing items, GANMIAB, hjkllshop, HXLAA, ioiVshop, JXHFOURC, KROJK, lklshop, LYTQHB, MirthBloom, Plus Size Mall, QINGSHIBEN, QWRshop, TengyunFashion, Trend wardrobe studio, UFCC, WETshop, WEYshop, wulanna, xinyaohuaguangR, YFH Online and foshanshiningpanxinshangmao added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

DECLARATION of Emily Holt regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 regarding declaration 16

(Exhibit 2-1)

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 temporary restraining order 13, motion for leave to file 3, motion for miscellaneous relief 18 before Honorable Manish S. Shah on 3/26/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motions [3] [13] [18] are taken under advisement and no appearance on 3/26/25 is necessary. The court will enter a ruling via cm/ecf. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [13] [18] are granted. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 3/31/2025. Notices Mailed.

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 $ 50,000 posted by Merch Traffic, LLC (Document not scanned)

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]

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time[28] before Honorable Manish S. Shah on 4/10/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion for extension of time 28 is granted, and no appearance is necessary. The TRO is extended to 4/28/25. Notices Mailed.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 34

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 35

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 34 before Honorable Manish S. Shah on 4/22/2025 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/15/2025, answer due 5/6/2025.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [34] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 4/22/2025. Notices Mailed.

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

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

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 43

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 44

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 43 before Honorable Manish S. Shah on 5/14/2025 at 09:45 AM.

(Exhibit A)

ATTORNEY Appearance for Defendants CITYBOY STUDIO, FOREVER CHOW, Plus Size Mall, Trend wardrobe studio by Ni Xue

MOTION by Defendants CITYBOY STUDIO, FOREVER CHOW, Plus Size Mall, Trend wardrobe studio for extension of time to file answer

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 43 is granted and the motion for extension of time to answer 48 is denied. Enter Default Judgment Order. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 5/14/2025. Notices Mailed.