2025-cv-03579

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23297006.

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)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

Civil BOND in the amount of $10,000.00 check Receipt no 100019231 posted by Merch Traffic, LLC

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MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for leave to file under seal 3 is granted. Mailed notice

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 14

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

DECLARATION of Emily Holt regarding memorandum in support of motion 15

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 regarding declaration 17

(Exhibit 2)

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 19

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 14, motion for miscellaneous relief 19 before Honorable Virginia M. Kendall on 4/16/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing set for 4/16/2025 at 9:30 AM will NOW PROCEED VIA WEBEX. Prior to the hearing, you are directed to cut and paste this hyper link into a browser: https://us-courts.webex.com/join/virginia_kendallilnd.uscourts.gov You can use the dial in option ONLY if you do not have access to a device with video capability: (650)-479-3207, the access code is: 180 698 4009. 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

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 4/16/2026. Plaintiff's Motion for Temporary Restraining Order [14] is granted. Temporary Restraining Order shall remain in effect up to and including 4/30/2025. Sealed Order to follow. Plaintiff's Motion for electronic service of process [19] is granted. Status hearing set for 4/30/2025 at 9:30 AM. Mailed notice

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 4/16/2025. Mailed notice

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

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[30]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[30] before Honorable Virginia M. Kendall on 4/30/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/25/2025, answer due 5/16/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Status and Motion hearing set for 4/30/2025 at 10:30 AM. Mailed notice

MINUTE entry (Corrected) before the Honorable Virginia M. Kendall. On the Court's own Motion, Status and Motion hearing set for 4/30/2025 is reset for 5/1/2025 at 10:30 AM. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 5/1/2025. Plaintiff's Motion for Preliminary Injunction [30] is granted. Order to follow. Status hearing is set for 6/12/2025 at 9:30 AM. Mailed notice

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 5/1/2025. 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 38

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 39

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 38 before Honorable Virginia M. Kendall on 5/29/2025 at 09:30 AM.

(Exhibit A)

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 5/29/2025 is reset for 12:00 PM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Rachel Meira Ackerman

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 5/29/2025. Plaintiff's Motion for entry of Default and Default Judgment as to all remaining Defendants [38] is granted. Enter Order of Default as to all remaining Defendants. Final Judgment Order to follow. Mailed notice

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 5/29/2025. Civil case terminated. Mailed notice

MAILED Trademark report with certified copy of minute order dated 5/29/2025 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendants