2026-cv-02054

COMPLAINT filed by Pit Viper, LLC; Filing fee $ 405, receipt number AILNDC-24765423.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Schedule A regarding complaint[1]

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 3 regarding complaint[1]

MOTION by Plaintiff Pit Viper, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Pit Viper, LLC

Notice of Claims Involving Trademarks by Pit Viper, LLC

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Maria Valdez. 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.

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

MOTION by Plaintiff Pit Viper, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Pit Viper, LLC in support of motion for temporary restraining order[14]

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

DECLARATION of Vance Lommen regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 3 regarding declaration[17]

MOTION by Plaintiff Pit Viper, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Pit Viper, 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 3/16/2026 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 or motion to extend TRO is to be filed by 3/12/2026. The Court advises that it 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 3/2/2026.

Registry Deposit Information Form by Pit Viper, LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Pit Viper, 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 posted by Pit Viper, LLC (document not scanned)

MOTION by Plaintiff Pit Viper, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Pit Viper, LLC in support of extension of time[28]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[29]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to extend the temporary restraining order [28] is granted; the ex parte TRO entered by the Court on 3/2/2026 is extended through 3/30/2026. The Ttlephonic preliminary injunction hearing set for 3/16/2026 is vacated and reset to 3/30/2026 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 3/26/2026. The Court advises that it 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 Pit Viper, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Pit Viper, LLC in support of motion for preliminary injunction[32]

Declaration of Trevor C. Talhami

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/18/2026, answer due 4/8/2026.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has appeared or responded to the complaint or the motion for preliminary injunction. The telephonic preliminary injunction hearing set for 3/30/2026 is vacated. Plaintiff's motion for entry of a preliminary injunction [32] is granted. 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 6/1/2026 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 5/22/2026. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 3/26/2026. Mailed notice.

NEW PARTIES: Outdoor Sport Glasses Store, VIPERGLASSES Store, Cn1100474013fsdae Store, PIT VIPER SUNGLASSES Store, QUISVIKER CYCLING Store, QUISVIKER-GQ Store, RUG GLASSES Store, Shop1102770545 Store, Shop1104032007 Store, YUMOON GLASSES Store and OZOKSKS SUNGLASSES added to case caption.