2025-cv-03468

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 405, receipt number AILNDC-23285604.

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 Andrea R. Wood. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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: Shenzhen Mingbo Electronic Commerce Co., Ltd., DIM QUNH, YingShunYuHongZhuangShiZhuangXiu, chsdnjvkojesgjioe, DANNI1990, HavenCo Shop, jingquhua, Kangren, kimanh909, LmploqaxeHao, MAITHANH2, NIKAKANMA, Star Griezmann LLC, YouMme Codx, ZeShouJianZhuLaoWu, jpmh6358, Keokrias Toy Supplies, nguyentu-9573, qinhuangdaoshaochaoshangmaoyouxiangongsi, vanpt84, xuyang_46, a Fashion Decorative Painting, ABC Blankets, ADORN YEARS, AKTBGFE, Amour Case, Art Haven Pro, Art Oil Painting Gallery, Artisans Soul, Artistic Reverie HA, ARTOM, ATGBJHNOLJ, Auraae, Baixiang Chen, Bamboo Gonxi, Barnett Chen, BEST LOVES, BKBT, BLACK COW, Blanket Candy, Blanket Flying Man, blanket of home, Blue Lotus Art, Blueberry Painting Shop, Boil the mural for a while, BOS IRONART, BostLinderStudio, Brilliant Jewelry A, Zhang Mingcong, chenqun, Chic Artworks, Chic Fusion, Chic Mirage, Chic Tides, CHMUJIN Art Prints local, CHXS ART, Cicolk Shop, CKMMMT, ClosetCrush, Clothing Fashion Home, CloudTouch, COBAR, Coconut Elf, Color frame painting, Comfort Havenn, Comfortable Creation House, CoolStyle D, CQGYHHG, CRAZY HOW, Crazy Lee, Creative Case Factory, CrossMingle, Csgo NoOne, CUSTOM SHEEP, CustomChic, CYL Fashion, DAHUAJIAFANG, Daisy Yuan, Damowang, Daxton Decoration and DDPIJJ added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 14

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 15

DECLARATION of Carrie Dumont regarding memorandum in support of motion 15

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 3 - Parts 1-2 regarding declaration 17

Exhibit 3-1

(Exhibit 3-2)

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 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 19 are set for a telephonic motion hearing on 4/23/2025 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 4/23/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A [2], and (2) Exhibit 3 - Parts 1-2 [18]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 3:00 p.m. on 4/25/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 5/9/2025 at 9:30 AM. [Note Date Change]. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 4/25/2025. Mailed notice

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 Shenzhen Mingbo Electronic Commerce Co., Ltd. and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 10,000.00 posted by Peanuts Worldwide LLC. (Document not imaged) (Received via the Clerk's Office drop box on 05/02/2025)

MOTION by Plaintiff Peanuts Worldwide LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Peanuts Worldwide LLC in support of extension of time[29]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[30]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order [29] is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 5/23/2025. Telephonic status hearing set for 5/9/2025 is stricken and reset for 5/23/2025 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

MOTION by Plaintiff Peanuts Worldwide LLC for preliminary injunction

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for preliminary injunction[33]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[34]

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/14/2025, answer due 6/4/2025.

Declaration of Hannah A. Abes

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction [33] will be heard at the telephonic hearing set for 5/23/2025 at 9:30 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 5/23/2025. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 5/23/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [33] is granted. Enter Preliminary Injunction Order. Plaintiff's anticipated motion for default and default judgment shall include a spreadsheet that identifies up-to-date information on the amounts that are being restrained for each of the remaining defendants. The Clerk's Office is directed to unseal: (1) Schedule A [2], (2) Exhibit 3 - Parts 1-2 [18], and (3) the sealed temporary restraining order [24]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 6/26/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Mailed notice

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 42

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 43

Exhibit 1

(Exhibit 2)

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 6/26/2025. No Defendants appear. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [42] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice. (jn,)

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

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 6/30/2025. Mailed notice. (jn,)

MAILED trademark report with certified copy of minute order dated 6/26/25 to Patent Trademark Office, Alexandria VA.

MAILED copyright report with certified copy of minute order dated 6/26/25 to Registrar, Washington DC.

NOTICE of withdrawal of bond[28] by Greer, Burns & Crain Ltd.

FULL SATISFACTION of Judgment regarding Default Judgment, order 48 in the amount of $500,000 as to certain defendant