2026-cv-00883

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-24641405.

(Exhibit 1)

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

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1-2 regarding complaint[1]

Exhibit 2-1

(Exhibit 2-2)

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 Luana Faria De Souza (Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Jennifer Mary Younan

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA (qrtr,)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.(qrtr,)

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 - Parts 1-2 regarding declaration[17]

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]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 4 and motion for electronic service 19 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order 14 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 2/12/2026 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 2/9/2026. 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 1/29/2026.

Registry Deposit Information Form by Merch Traffic, LLC (Faria De Souza, Luana)

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

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to a Certain Defendant (Faria De Souza, Luana)

MOTION by Plaintiff Merch Traffic, LLC for extension of time of Temporary Restraining Order

(Exhibit A)(Faria De Souza, Luana)

MEMORANDUM by Merch Traffic, LLC in support of extension of time 28 (Faria De Souza, Luana)

DECLARATION of Luana Faria de Souza regarding memorandum in support of motion 29 (Faria De Souza, Luana)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/9/2026, answer due 3/2/2026.

Declaration of Jennifer M. Younan

(Exhibit A)

SURETY BOND in the amount of $ $10,000.00 posted by Merch Traffic, LLC

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of the temporary restraining order 28 is granted; the ex parte TRO entered by the Court on 1/29/2026 is extended through 2/26/2026. The telephonic preliminary injunction hearing set for 2/12/2026 is vacated and reset to 2/26/2026 at 9:05 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 2/23/2026. 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.

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)(Faria De Souza, Luana)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 34 (Faria De Souza, Luana)

DECLARATION of Luana Faria de Souza regarding memorandum in support of motion 35 (Faria De Souza, Luana)

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has appeared or filed a response to the complaint or to the motion for preliminary injunction. The telephonic preliminary injunction hearing set for 2/26/2026 is vacated. Plaintiff's motion for entry of a preliminary injunction is granted 34. 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 4/27/2026 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 4/20/2026. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 2/25/2026. Mailed notice.

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

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)(Faria De Souza, Luana)

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment 41

Exhibit 1

(Exhibit 2)(Faria De Souza, Luana)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 42

(Exhibit 1)