2025-cv-05050

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23455541.

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 Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2).

NEW PARTIES: xiangchengshishanghuamaoyiyouxiangongsi, A little sister who sells paintings, A SUBORDINATE, ArtCanvasss, Chrisweng, Daisy AN, Dexterity comes experience, FUNNY AO FANG, FUNNY HL, HLKMMA, honglaoshi, James Poster Art House, JuCaiPen, Konglongshizhuang, MetroMale, Neon Pulse, New frame painting, NNNZQ, ohhtfh, PINGWEIER, PureDesigns, Senior gentleman, SHENG TIME, StylishTee, Tee Many Choices, the key of knowledge, Thick and small, TomiY, Transworld Bazaar, TTDBD, Y624946'shop, Yiayu, yixuanbaihuodian, ZhaoCaiLaLe and ZZGV added to case caption.

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[11]

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

DECLARATION of Emily Holt regarding memorandum in support of motion[12]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 regarding declaration[14]

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[16]

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

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 16 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order 11 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 5/27/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction is to be filed by 5/22/2025. Plaintiff is advised that the Court may deny enter of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 5/12/2025.

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 25

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 26

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of the temporary restraining order 25 is granted; the ex parte TRO entered by the Court on 5/12/2025 is extended through 6/10/2025. The telephonic preliminary injunction hearing for 5/27/2025 is vacated and reset to 6/10/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction is to be filed by 6/5/2025. Plaintiff is again advised that the Court may deny enter of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[29]

Declaration of Kahlia R. Halpern

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/4/2025, answer due 6/25/2025.

Declaration of Luana Faria de Souza

Exhibit A

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

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/5/2025, answer due 6/26/2025.

Declaration of Luana Faria de Souza

Exhibit A

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Thomas Joseph Juettner

MINUTE entry before the Honorable Matthew F. Kennelly: 25 C 5050Merch Traffic v. The PartnershipsTelephonic Preliminary Injunction Telephonic preliminary injunction hearing held on 6/10/2025. Plaintiff's motion for preliminary injunction 29 is granted. Preliminary Injunction order to follow. The Clerk is directed to unseal all documents that were previously filed under seal. 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. 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 telephonic status hearing on 8/12/2025 at 8:50 a.m. The plaintiff is directed to file a status report by 8/5/2025. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. 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.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 6/10/2025. Mailed notice.

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

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Justin Tyler Joseph

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[39]

Exhibit 1

Exhibit 2

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

Exhibit 1

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default 39 is granted. Final Default Judgment Order to follow. Any hearing dates set before this Court are stricken. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Matthew F. Kennelly on 7/2/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order 43 in the amount of $100,000 as to certain defendant (Faria De Souza, Luana)