2025-cv-03363

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 405, receipt number AILNDC-23274275.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Schedule A regarding complaint 1

MOTION by Plaintiff Peanuts Worldwide LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Peanuts Worldwide LLC

Notice of Claims Involving Trademarks by Peanuts Worldwide LLC

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Jorge L. Alonso. 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: Delicate gift one, DENGZIQI SHOP, Design Haven, Desu Nine, Different mug, Dioulai Style, Diowen, Diverse Art, DIY Jnoy, DJ NIGHT, DKG Decoration, DM Fashion Mens wear, Dora Ladies, Dream Edge the best canvas, duotabao, Duowei Tee, Edge Apparel, Edge Art, EShineShine Fashion, EverydayElegance, Everything you need is here NO, fa haoyunlai, FaCaiShop, FAMEOPROSHOP local, FancifyWear, Fascinate Blankets, Fashion beautiful clothes workshop, fashion forwar one, Fashion YYS, FashionFlare, FDQWE, FemHoodie, FENDISAEN, FFA FABU, Fire Skull, FLAME TREE, Flowers Tiger, folded blanket, FUUVH, FXLPDD, Gala cup, GANMIAe, General mall, GenZ Wardrobe, getmoretimetoplay, GEVVIC, GGFDE, Gjqing, GLAM DISTRICT THREE, Good Home A, Good Mens Casual Clothing, GOODSTORE, GZ XIU MI wudian, GZ ZY badian, Handcrafted treasures, Hanfeng Hat Shop, hantingshop, Haoge blanket, Happy leisure time, Happy Shopping zuu, HCC Clothing qidian, heiqinfang shop, Henry Cheng, Hershuing, hezhishengzhibin, Hibisc, HLOKJUHGQQ, HLS shop, Hohui, Hoodie Go, HsH Funny, hwdyp, I like it myself banone, Im funny, Imprleral Gappen, Ingenuity AA, Integrity wholesale goods, Invincible Aluminum Signs, INXX MARKET, Iron Family HHH, Iron Family L, Iron Family LL, JDLQP, Jenny Creative Home Furnishing and GFD added to case caption.

MOTION by Plaintiff Peanuts Worldwide LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Peanuts Worldwide LLC in support of motion for temporary restraining order[11]

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

DECLARATION of Carrie Dumont regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 3 - Parts 1-2 regarding declaration[14]

MOTION by Plaintiff Peanuts Worldwide LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Peanuts Worldwide LLC in support of motion for miscellaneous relief[16]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[16], motion for temporary restraining order[11], motion for leave to file[3] before Honorable Jorge L. Alonso on 4/3/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [11] [16] are granted, and no appearance is necessary. Plaintiff's written submissions establish that if Defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating Plaintiff's interests in identifying Defendants, stopping the alleged infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with Plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to Defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify Defendants and implement the asset freeze. If any defendant appears and objects, the Court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The Court finds that security in the amount of $84,000 - $1,000 per defendant - is sufficient to secure the injunctive relief. Motion hearing set for 4/3/25 is stricken. Telephonic status hearing set for 4/15/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 4/2/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Peanuts Worldwide LLC

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

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

INJUNCTION BOND in the amount of $85,000 posted by Peanuts Worldwide LLC (Document not scanned).

MOTION by Plaintiff Peanuts Worldwide LLC for preliminary injunction

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for preliminary injunction[25]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[26]

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[25] before Honorable Jorge L. Alonso on 4/15/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/10/2025, answer due 5/1/2025.

Declaration of Hannah A. Abes

Exhibit A

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Rachel S Miller

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 5/29/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [25] is granted. Enter Preliminary Injunction order. Plaintiff 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 www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 4/15/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain Defendants

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment[39]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[40]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment[39] before Honorable Jorge L. Alonso on 5/22/2025 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Justin Tyler Joseph

ATTORNEY Appearance for Defendants GANMIAe, hezhishengzhibin by Adam Edward Urbanczyk

MOTION by Defendants GANMIAe, hezhishengzhibin for extension of time UNOPPOSED

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time[45] before Honorable Jorge L. Alonso on 5/22/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 5/22/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to a certain Defendant

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Defendants GANMIAe, hezhishengzhibin's Unopposed Motion for extension of time [45] is granted in part to 5/29/25. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants [39] is granted. Enter Default Judgment Order. Status hearing remains set for 5/29/25. Notice mailed by Judge's staff

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 5/22/2025. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Kahlia Roe Halpern

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 6/5/25 at 9:30 a.m. The deadline for Defendant to answer is extended to 6/4/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Rachel Meira Ackerman

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 6/24/25 at 9:30 a.m. The deadline for Defendant to answer is extended to 6/23/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order[52] in the amount of $150,000 as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 7/9/25 at 9:30 a.m. If a stipulation to dismiss is filed in advance of that date, no one needs to appear on 7/9/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Defendants GANMIAe, hezhishengzhibin by Brian Swift

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 7/22/2025 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

STIPULATION of Dismissal as to a Certain Defendant

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to Defendant No. 66

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment[61]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[62]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment[61] before Honorable Jorge L. Alonso on 7/22/2025 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Lucas Allen Peterson

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment against Defendant No. 66 [61] is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 7/22/2025. Notice mailed by Judge's staff