2023-cv-07272

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 402, receipt number AILNDC-21013954.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

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

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment.

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.

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 Berel Yonathan Lakovitsky

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Emily Holt regarding memorandum in support of motion 12

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1 - 4 regarding declaration 14

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

(Exhibit 2-4)

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

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for temporary restraining order 11, motion for miscellaneous relief 16 before Honorable Jorge L. Alonso on 9/14/2023 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for leave to file under seal [3] is granted. Plaintiff's Ex Parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery [11] is granted. Enter Sealed Temporary Restraining Order. Plaintiff's Motion for electronic service of process pursuant to Fed.R.Civ.P. 4(f)(3) [16] is granted. Telephonic status hearing set for 9/28/23 at 9:30 a.m. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 9/14/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Quinn Bradley Guillermo

SURETY BOND in the amount of $71,000 posted by Merch Traffic, LLC (Document not scanned.)

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

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[27]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[27] before Honorable Jorge L. Alonso on 9/28/2023 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/25/2023, answer due 10/16/2023.

Declaration of Quinn B. Guillermo

Exhibit A

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 11/15/23 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction as to certain Defendants [27] is granted. Enter preliminary injunction order. The Clerk is directed to unseal all previously sealed document. Plaintiff 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 at www.ilnd.uscourts.gov. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Notice mailed by Judge's staff

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 9/28/2023. Notice mailed by Judge's staff

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

NEW PARTIES: Fine Blanket Shop Store, Shop1102772837 Store, Shop1102813679 Store, Shop910722081 Store, Shop910875004 Store, TO EMPTY 1941 Store, anxixianfengchengzhenlinxinnanbaihuolingshouchaosh, asdadwqwe, Bormart, CHAU BAO AN, chichidangaoba, dehuaxiangangliangzhaocaifushishang_apo_hang, elidgerg, foshanshishangchenjinshangmao, FRAMUN Store, guangzhouyinghongshangmaoyouxiangongsi, Illuminating light, Isabella R Towle, jinjiangshimeilingjiedaocaishiliangbaihuolingshou, JRYZX, KIEU CAO TUAN SHOP, KtUD&Mth, linzhijiejk, MEI-99, Metal sign shop, MUUMZI, Nanduart, Pawsonalization, Qian Duoduo Art Shop, QIUNIWU US, Ruichang Satin Changshi Clock Store, Samoilex Shop, sgsgkjf, shishishifenglijiedaoxieshuangbinbaihoulingshoucha, SimonArtDesign, Suncatcher Dream, TG VU DUC HAI, TRUNG ANH ADAM SHOP, vastlotus, VUTUANANHSTORE, xianyouxianlinanzhenhuangzhenwenjushangdian, xianyouxianzhongshanzhenxiexiubinglingshoubaihuoch, XiHeXianPengPengXiongDiGanGuoPiFaDian, yuanzhouqubainuoyanbaihuodian, Zebraart, zhaiyuanshangmaoyouxiangongsi, ZRUIXIN, zybbm, musuo03, customyourmug, chuqiujewelry, voeseto bags, ayuer, buchangyou1989, CHENCHUFEN2323, chenlingchao3161, christti, Jinfurui Trade, liangchao5141, likangning0456, Magan, majin227, MGGifts, suzhaoyang666, wangwei4804, xieyunchang1988, yangyang0701 and yansss home added to case caption.

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 10/13/2023, answer due 11/3/2023.

Declaration of Quinn B. Guillermo

(Exhibit A)

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

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Marcella Deshonda Slay

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)

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

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 39 before Honorable Jorge L. Alonso on 11/15/2023 at 09:30 AM.

(Exhibit A)

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's motion for entry of default and default judgment 39 is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 11/15/2023. Notice mailed by Judge's staff

MAILED trademark report and certified copy of order dated 11/15/2023 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 45 in the amount of $200,000 as to certain defendant

NOTICE of withdrawal of surety bond 26 by John Summerfield (Received for docketing 3/1/24)