2025-cv-08969

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23817479.

(Exhibit 1)

(Exhibit 1)

(Exhibit 2-1)

(Exhibit A)

(Exhibit A)

Declaration of Luana Faria de Souza

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding complaint 1

(Exhibit A)(Faria De Souza, Luana)

Exhibit 2

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 Justin Tyler Joseph

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 Laura K. McNally. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

NEW PARTIES: AE72RQN7H, ANDUUNI, aoan shop, Comfort Z Store, guangzhouyetiaoshangmaoyouxiangongsi, Koimcuiy, Liberty Thread Co., liuyangshixuejunyuebaihuoyouxiangongsi, NHISTLOFAF, PHUONGWLINH SOTRE SHOP5555555558888888, TaoTao024, Tranngoccong, VA STOREBERAT, VANG THI LIA STORE, Very interesting shop, Wangyumeng A, xinshangfuzhuang, zhijiangshixianzhongdianzishangwushanghanggerenduzi, HatsHubs, Image Hat, nguye-7781, ph.factoryshop, Baines Decor, CLVIEFWF, COCOON Mens Wear, jojojoteee, ZF KUAJING F, langjingdz, Saffron Stitch and SOMT Cotton Clothing added to case caption. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

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

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 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

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file under seal 3 and motion for electronic service of process 18 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order (etc.) 13 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 8/18/2025 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 or motion to extend TRO is to be filed by 8/13/2025. Plaintiff is advised that the Court may deny entry 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 8/4/2025.

Registry Deposit Information Form by Merch Traffic, LLC

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 Justin T. Joseph 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 8/4/2025 is extended through 9/2/2025. The telephonic preliminary injunction hearing set for 8/18/2025 is vacated and reset to 9/2/2025 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 8/27/2025. Plaintiff is reminded that the Court may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

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

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 31

DECLARATION of Justin T. Joseph regarding memorandum in support of motion 32

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/14/2025, answer due 9/4/2025.

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

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or an answer or a response to plaintiff's motion for preliminary injunction. The telephonic preliminary injunction hearing set for 9/2/2025 is vacated. Plaintiff's motion for a preliminary injunction is granted [31]. Enter Preliminary Injunction Order. 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 a telephonic status hearing on 11/10/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 11/3/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 9/2/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to a Certain Defendant

MOTION by Plaintiff Merch Traffic, LLC for entry of default, MOTION by Plaintiff Merch Traffic, LLC for default judgment as to all Defendants

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment[39]

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