2024-cv-00871

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-21589979.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

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 Marcella Deshonda Slay

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, Plaintiff's motion for leave to file under seal [3] is granted. Plaintiff is granted leave to file Schedule A to the Complaint [2] and Exhibit 2 to Declaration of Emily Holt under seal. Emailed notice

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]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Emily Holt regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1 - 9 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]

Exhibit 1

Exhibit 2

MEMORANDUM by Merch Traffic, LLC Establishing that Joinder is Proper

Declaration of Justin R. Gaudio

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion for a temporary restraining order 14, and motion for electronic service of process 19. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 2/13/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Franklin U. Valderrama on 2/8/2024.

SURETY BOND in the amount of $ 10,000 posted by Merch Traffic, LLC (Document not scanned).

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

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[26]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/22/2024, answer due 3/14/2024.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction 26 is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint 2 ; (2) Exhibit 2 to the Declaration of Emily Holt 18 and (3) the TRO 24. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Emailed notice.

(Add and Terminate Party) (axc)

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 2/23/2024. Emailed notice

NEW PARTIES: Jinjiang Chidian Town Junxin Plastic Products Firm, H01 Boys And Girls Clothes Shop Store, Moon Art Store Store, Nice 3C 2 Store, Shop1102788640 Store, Shop1102958801 Store, AL Poster Shop, ANXUNU, ATTIHWFRQN1YK, AXCB147UXCLUU, BEEBARYJ-US, Best Star Direct, cangshencebaihuodian, changshashoutui, CQLI, danhluudinh89, Doeean, Fchen art'store, Fooler-US, francoscavo654, GallegoGifts, Gogolin US, GXHQianXuxia, Hangangdeng, hezeyingzhouxinxikejiyouxiangongsi, HJHGHB, Hu Xu Stick Look, huitang0327, huynhhoanganvip, JOUCY, JulyMeMe, Laopei, LaPomme, Leeyo--US, lixinxiaohubaihuoxiaoshouyouxiangongsi, Mool-US, MyKem, Orlco Art Store, RenMingKaiShanXiOuHua, Roytal--LCD, shishishifenglijiedaozhangluxuanriyongpingjingying, Six Eight Six Store, Syeek--US, taiyuanjiatingshangmaoyouxiangongsi, TatBrows, Tedkos--LCD, wanlingxieye, wenyatou, WGHcangf04190, wuhanshisinubibaihuodian, wujinsenxiaodian, xiehexieye, XinFuWangLuoKeJi, XJapple, XJoop--US, yangchouda, YangJiangHaiWei, yichangshiwujiagangqukongxunbianlidian, yong Liu Shop, Yoole-US, YUANFU666, ZhangJiaEn001, zhaodongfudongkongyubaihuodian, b12q, duckyo, ffcl, ggvl, graymice, highluxury008, hjek, lekah, liyongle1, nan06, paris_011, peach_garden23, pinknice, qsoy, superjacket369, us_new_york, vipsalemax5, vipsalemax8, wev8, zhejiangweiyi, dudb7334, kingofthediy, mosna1, ronol-55, russak-80, sidera_58, tri9042, truthik70, Household Lang day, mingtuhy and Poster Zone added to case caption.

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

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/14/2024, answer due 4/4/2024.

Declaration of Marcella D. Slay

(Exhibit A)

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

NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to 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

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment[36]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[37]

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment as to All Remaining Defendants [36] is granted. Enter Final Judgment Order. The ten thousand dollar ($10,000.00) surety bond posted by Greer Burns & Crain Ltd., including any interest minus the registry fee, is hereby released to Amy Crout Ziegler of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Amy Crout Ziegler of Greer Burns & Crain Ltd., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606 [via certified mail]. Civil case terminated. Mailed notice.

ATTORNEY Appearance for Defendant YUANFU666 by Christopher Paul Keleher

MOTION by Defendant YUANFU666 for extension of time to file answer regarding complaint[1]

FINAL JUDGMENT ORDER. Signed by the Honorable Franklin U. Valderrama on 4/11/2024. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Defendant YUANFU666 has now filed a motion for extension of time to file answer regarding complaint 41. The Court denies the motion. In light of the Court's grant of default and default judgment on 4/10/2024, and in an absence of a motion to vacate that order and reinstate this case, the Court cannot consider the pending motion while this case remains terminated. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 04/10/2024 to Patent Trademark Office, Alexandria, VA.

ENTERED IN ERROR (ags) Modified on 5/21/2024

FULL SATISFACTION of Judgment regarding order 42 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[42] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[42] in the amount of $200,000 as to certain defendant