2024-cv-03028

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-21857766.

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 Justin Tyler Joseph

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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 Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

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

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 1-6 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

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte telephone status hearing held on 4/23/2024. Transcript is to remain sealed. Motion for temporary restraining order [14] is granted. Enter Temporary Restraining Order. Motion for electronic service of process pursuant to Fed. R. Civ. P 4(f)(3) [19] is granted. Mailed notice. (jn,)

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 4/24/2024. Mailed notice.

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

CIVIL BOND in the amount of $ 76,000 posted by Merch Traffic, LLC. (Document not Scanned).

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 25

Declaration of Kahlia R. Halpern

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 25 is set for 5/8/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/3/2024, answer due 5/24/2024.

Declaration of Justin T. Joseph

(Exhibit A)

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

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 5/8/2024. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 25 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Plaintiff's Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Emily Holt 18, and the TRO 22. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 6/7/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 5/8/2024. Mailed notice.

NEW PARTIES: Chengdu Heqiuli Clothing Co., Ltd., Dongguan Bu'an Clothing Co., Ltd., Dongguan Jinse Apparel Co., Ltd., Dongguan Kuangmin Clothing Co., Ltd., Dongguan Leika Garment Co., Ltd., Dongguan Metro Clothing Co., Ltd., Dongguan Qilima Clothing Co., Ltd., Dongguan Ronghan Clothing Co., Ltd, Dongguan Xuan De Le Clothing Co., Ltd., Dongguan Youchen Apparel Co., Ltd., Dongguan Yuanyang Garment Co., Ltd., Fujian Dadudu Technology Co., Ltd., Fuzhou Cangshan Jiufeite Import And Export Trade Co., Ltd., Fuzhou Hellojim Trading Co., Ltd., Fuzhou Laiyu Import And Export Co., Ltd., Fuzhou Qitian E-Commerce Co., Ltd., Guangzhou Mywear Industrial Co., Ltd., Hangzhou Tuoke Garment Co., Ltd., Quanzhou Tianyi Clothing Co., Ltd., Quanzhou Tianyi Clothing Co., Ltd. 1, Shenyang Willian Network Technology Co., Ltd., Shishi Wansilv Chemical Fiber Product Co., Ltd., Xiamen Doupuying Trading Co., Ltd., Zhongshan Weier Clothing Co., Ltd., ANMGOTQBS7UJT, chenweideshangdian, Dynict, FDDZC Flagship Store, guangzhoushifenyoushangmaoyouxiangongsi, Heilongjiang Ruoming Network Technology Co., Ltd, huamiaozhouyang, huangzhiyuanquanzhushangmao, Ibrahimova, kunmingfengdubaihuoshanghang, linjianyu shop, liuhengshangdian, longxiyueshangmao, miemieheibutou, pingdingboyangshangmaoyouxiangongsi, pingdingyiruishangmaoyouxiangongsi, QiChunXianCunAnLuDianZiGongZuoShi, Sibari, TASYA Studio, untose, Very happy painting, xiaoyafenggeshangmao, yuanpingdedianpu, yunchengshiyanhuqushubeitou, yunchengshiyanhuquyouzeyushangmaoyouxiangongsi, zhangkebaihuodian, Zhangxuehaizxh, dhgateblue, goodfaith1994, huiyuandian1q, pjliang8819, tingluan, tobetrend, beddingsuit2023, binkbin, breuh10bc, Chic Trend Loom, chyients, ducphi.98, JC-Clothing Store, lakhir-45, qiqimaoyi, ttecommerce, wanjiu-01, youxuemin1234, Street Knights, Ying Song garment factory, BAIBAIJINGJING, bobo, Huke Industry Co.Ltd, Joshine and MAYZERO added to case caption.

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 32

Declaration of Kahlia R. Halpern

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction is set for 5/23/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. (jn,)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/16/2024, answer due 6/6/2024.

Declaration of Kahlia R. Halpern

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 5/23/2024. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 32 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Plaintiff's Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Emily Holt 18, and the TRO 22. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 6/24/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 5/23/2024. Mailed notice.

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Luana Faria De Souza (Faria De Souza, Luana)

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

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 6/7/2024. The telephone status hearing set for 6/24/2024 is vacated. A telephone status hearing is set for 7/9/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Merch Traffic, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Merch Traffic, LLC

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 43

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 44

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status set for 7/9/2024 is vacated. A telephone hearing as to the motion for entry of default and for default judgment[43] is set for 6/24/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Defendant Fuzhou Cangshan Jiufeite Import And Export Trade Co., Ltd. by Adam Edward Urbanczyk

MOTION by Defendant Fuzhou Cangshan Jiufeite Import And Export Trade Co., Ltd. for extension of time

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time [48] is granted. The deadline for Fuzhou Cangshan Jiufeite Import and Export Trade Co., Ltd. to answer is extended to 7/11/2024. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 6/24/2024. Adam Urbanczyk was present on behalf of certain defendants. No other defendants appeared. Motion for entry of default [43] is granted. Plaintiff's counsel is to send an updated proposed default judgment order. Telephone Status Hearing set for 8/6/2024 at 09:00 AM. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Thomas M. Durkin on 6/24/2024. Mailed notice.

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

MINUTE entry before the Honorable Thomas M. Durkin: Pursuant to the notice of dismissal, the last remaining defendant has been dismissed. All pending dates before this court are stricken. Civil case terminated. Mailed notice.

MAILED patent report to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant