2025-cv-04556

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23401868.

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.

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2). (qrtr,)

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. (qrtr,)

NEW PARTIES: ANa-us, Fashion personality T-shirt, kangfucheng, mingzhuoshengtai, rongonrgxingfu, XiAnJinZhouShangMaoYouXianGongSi, XingTaiShiXiaoZhunDianZiKeJiYouXianGongSi, yanjieqi, Zhanliang Cool Store, ZhiJiangShiXueNuShangMaoYouXianGongSi, AKJHVDJE, AlllllllIIIIIIIIIIIIIIIIllllllllllllllllIIIIIIIII, AlllllllllIIIIIIIIIIIIllllllllllllllIIIIIIIIIIIII, Auroraa AQ, BDJADCHB, BFITFITSHOP, Black and White Factory, ChenHuiCloth painting, CHKXYZ Online, CHM Online, CJP Decorative paintings and posters, Continentbuy local, Cool clothesXP, Coolplayboy, DDD Studio, DEANNATCQ, DFFRET, DIY Shine, E Money comes from the old shopkeeper, Fineness Sign, Framed Elegance, GJIKUHYBB, GJKIEHJGG, HaoziTrade, HSDFSFF, HYXBNLKK, HYXGGOZZ, HYXMNBVV, HZC de xiaodian, IJTKGB, Jiapin Trading Tshirt, KidsCraftCorner DIY, King Male, leisure time mens wear ccc, Lthg succeed in, Lucki ness, Luckiness E, Luckiness J, Mainstream shiping, maizibahao, Mary LLC, Merero Goods, mug printing, nonoteees, OYZW painting poster expert, Realace DIY, SSLZZZ, TarotTee, TOBETEE, Tshirt fashion, ttopliuzhanglin, Unique Crafts DIY, WJONEE, WSDCSZZ, XD menswear club, xinyaohuaguangI, Ycen Clothing and ZZRASZZ added to case caption.

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 Parts 1-2 regarding declaration[16]

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 miscellaneous relief[18], motion for leave to file[3] before Honorable Elaine E. Bucklo on 5/7/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal [3]; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery [13]; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 5/22/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 5/15/2025. 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 of the expiration of the TRO. 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 case is set for a status hearing on 6/23/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 6/16/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 5/8/2025. Mailed notice.

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

Registry Deposit Information Form by 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[27]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[28]

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time[27] before Honorable Elaine E. Bucklo on 5/22/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order [27] is granted to 6/5/2025. Mailed notice.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[33]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[33] before Honorable Elaine E. Bucklo on 6/4/2025 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 5/29/2025, answer due 6/19/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction [33] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint [2], Seller Aliases screenshots attached to the Declaration of Emily Holt [15] and the TRO [23]. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 6/4/2025. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo:The Clerk of Court is directed to unseal the following documents: All previously sealed documents are hereby unsealed. Mailed notice.

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

STATUS Report per 22 by Merch Traffic, LLC

(Exhibit A)

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 Elaine E. Bucklo on 6/26/2025 at 09:45 AM.

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment as to all remaining defendants 43 is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Merch Traffic, LLC or its counsel Greer Burns & Crain Ltd. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 6/26/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order 48 in the amount of $100,000 as to certain defendants (Faria De Souza, Luana)