2024-cv-01196

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 405, receipt number AILNDC-21630687.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Peanuts Worldwide LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Peanuts Worldwide LLC

Notice of Claims Involving Trademarks by Peanuts Worldwide LLC

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2). (jcc,)

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 copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Peanuts Worldwide LLC for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Peanuts Worldwide 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 Candace Arrington regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 5 - Parts 1-7 regarding declaration[17]

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

MEMORANDUM by Peanuts Worldwide 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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 19 are set for a telephonic motion hearing on 2/23/2024 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 2/23/2024. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2], and (2) Exhibit 5 - Parts 1-7 [18]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:45 a.m. on 2/23/2024 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 3/8/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 2/23/2024.

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

SURETY BOND in the amount of $ 10,000 posted by Peanuts Worldwide LLC (Document not scanned)

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Jennifer Van Nacht

MOTION by Plaintiff Peanuts Worldwide LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Peanuts Worldwide LLC in support of extension of time[28]

Declaration of Rachel S. Miller

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 28 is granted. The Court finds good cause to extend the temporary restraining order an additional 14 days to 3/22/2024. Telephonic status hearing set for 3/8/2024 is stricken and reset for 3/22/2024 at 1:30 PM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendant

MOTION by Plaintiff Peanuts Worldwide LLC for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for preliminary injunction[33]

Declaration of Rachel S. Miller

Exhibit 1

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/19/2024, answer due 4/9/2024.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction as to certain defendants [33] is set for a telephonic motion hearing on 3/22/2024 at 1:30 PM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 3/22/2024. Only Plaintiff appeared. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction as to certain defendants [33] is granted. Enter Preliminary Injunction Order. The Temporary Restraining Order expires on its own terms as to any remaining defendants not subject to the preliminary injunction order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint [2], and (2) Exhibit 5 - Parts 1-7 [18], and (3) the sealed temporary restraining order [25]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 5/2/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 3/22/2024. Mailed notice

NEW PARTIES: Dongguan Shangen Garment Co., Ltd., Guangzhou Prodigy Daily-Production Co., Ltd., Guangzhou Yuexiu District Shengyi Jewelry Firm, Haifeng County Meilong Baoxing Jewelry Factory, Hangzhou Brightly Shone I-E Co., Ltd., Hangzhou Yihong Import & Export Co., Ltd., Hefei ZY Trade Co., Ltd., Huizhou Boya Arts And Crafts Co., Ltd., Ningbo Rich Material Technology Co., Ltd., Royaumann Co., Ltd., Shaoxing Yaofu Materials Co., Ltd., Shenzhen Chuangyaoke Technology Co.,Ltd, Shenzhen Datang Enterprise Service Co., Ltd., Shenzhen Mantianxing Information Technology Co., Ltd., Shenzhen Weida Science And Technology Ltd., Shenzhen Yazhitang Trading Co., Ltd., Suzhou Getogether Sujiao Co., Ltd., Wuhan Haoqibao E-Commerce Co., Ltd., Yiwu Leihui Trade Co., Ltd., Yiwu Yiner Tech Developing Co., Ltd, Zhejiang Wenchuan Technology Co., Ltd., Zhuji Dazhengwushang Import And Export Co., Ltd. - 1, Zhuji Kaihui Socks Co., Ltd., A1ZNAO50ZVGK9C, A284X3XJ2FHLLI, A3UDYW2CJ2Y7B0, Anhdan123, APNAVSFUO4JPR, axxfczxjbfsd, C.genmai01, C.HAIYANG002-FBM, C.YUZHONG34-FBM, cuidianzishangwu, DOUBLE AMERICAN, FAPBLUE TV - US, foshanshinanhaiqumomashangmaoyouxiangongsi, FuZhouAiYuWenHuaChuanMeiYouXianGongSi, Giraffe shop, Hieu100088, highe shop, KFC123456, Kriklar, luoyangshichanhehuizuquwangxibaihuodian, lyongt206, MA VAN TRUC SHOP, MENG1HUI, MG CO LTD-1, Minqing Trading, Miu stores, Moxigon, MOYINYUETAN, nan ping shi yan ping qu yue long bai bai huo dian, NANCHANGZHOUDITINGSHANGMAOYOUXIANGONGSI, pingdingjietashangmaoyouxiangongsi, pingdinglinyingmaoyishanghang(gerenduzi), qichangbaihuodian, Ruannan, ruchendianzi, saihanquhainabendijuminrichangshenghuofuwugongzuos, sanjiemeixinxin, ShangGaoXianHaoChenBaiHuoDian, shifangshiliuheqiaodianzishangwugongzuoshi, SHUIXIGUANSHANGMAO, Smart Query ddjie, SM-shops, Suxiaoming, WangJingyan, WANGWEIYONG, wuhanshijiangxiaqupengxinshangmaozhongxin, wuhanshijiangxiaquyujianshangmaozhongxin, xinyishifanzhanhshangmaoyouxiangongsi, YEZZZZ, yichanggaoxinquqianyueshipinjingyingbu, ZHANG1YUANGUI, Zhouyifu-us, ladysbag3366, 8bity.vn, black_roses-98, crissy8682, dreamervarietyshop_01, GG BOM, hieptr_29, willemate, xuhao6565, Toys like a billionaire, LUHAN, yangwen co.ltd and zhenghui5745 added to case caption.

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendant

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to a Certain Defendant

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/9/2024, answer due 4/30/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment 44

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 45

(Exhibit 1)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/2/2024 and continued to 6/6/2024 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment [44] will be heard at the telephonic hearing set for 6/6/2024 at 10:15 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

NOTICE of Voluntary Dismissal by Peanuts Worldwide LLC as to certain defendants

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 6/6/2024. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment [44] is entered and continued. By 6/14/2024, Plaintiffs shall make a supplemental submission that identifies which Defendants are the subject of the trademark claims and which are the subject of the copyright claims, including identifying each Defendants' requested statutory damage amount. Telephonic status hearing set for 6/21/2024 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

SUPPLEMENT to motion for entry of default, motion for default judgment 44

Exhibit A

(Exhibit 1)

MINUTE entry before the Honorable Andrea R. Wood: Telephone conference held. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment [44] is granted. Enter judgment order. Civil case closed. Mailed notice.

ENTERED DEFAULT JUDGMENT Signed by the Honorable Andrea R. Wood on 6/21/2024. Mailed notice.

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding entered judgment 53 in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding entered judgment 53 in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding entered judgment 53 in the amount of $100,000 as to certain defendant

NOTICE of withdrawal of surety bond 26 by John Summerfield (Received at the Intake Counter on 11/21/2024)

FULL SATISFACTION of Judgment regarding entered judgment 53 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding entered judgment 53 in the amount of $500,000 as to certain defendant