2024-cv-03766

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-21945757.

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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 Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

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]

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DECLARATION of Emily Holt regarding memorandum in support of motion[12]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1-3 regarding declaration[14]

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]

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Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[16], motion for temporary restraining order[11], motion for leave to file[3] before Honorable Manish S. Shah on 5/16/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [11] [16] are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 5/14/2024. Notices Mailed.

Registry Deposit Information Form by Merch Traffic, LLC

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

SURETY BOND in the amount of $ 50,000 posted by Merch Traffic, LLC. (Document not Imaged)

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[23]

Declaration of Kahlia R. Halpern

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NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[23] before Honorable Manish S. Shah on 5/28/2024 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/22/2024, answer due 6/12/2024.

Declaration of Luana Faria de Souza

Exhibit A

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Rachel S Miller

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 23 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 5/28/2024. Notices Mailed.

NEW PARTIES: A3HRYK6E0EZ7Q7, COLOURPLAY, dfhgMAXIAOYUSHANGHANG, DREMDO-US, Farmakas, Fulse, Han Hong A, HuangChaoLIL, hubeishengqinglingdianzishangwushanghang, Isikovitz, La bar, Laylala, Lin Yue, Luotong L, LUZHAI, manfuLWzC3W0, MA-star - 1, nmcamst, oujinlianposter, PERFECT99, Peter Lou Ssha, PingDingYiXunYuShangMaoYouXianGongSi, ShiShengHuoBaiHuoDian, Sima La, TheFrench, TianKHua, tiongertwie, Tom Koenigs, XCHZZDP, yangjiangshimenggangruoshangmaoyouxiangongsi, yingtanshiyujiangquqingyouxibaihuodian, alariceeny, baidian111, baidian222, baidian333, baidian444, baidian555, ccawda, dhgateuu, householdd, kkefyea, vaidurya, chengmaiyukuangqixi-0, Tarot-1990, yuanhhhh, DanZhouShiHongJinLinGongSi, Fengpu Trading Co., Ltd, FIDWALQINT, jianjiankangkang, linianshangmaoyou, ShiTianHui, TaiYuanLiPaTiXinXiKeJi, WANGCHANG and XINXINGSHICHENG added to case caption.

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 with the exception of a certain Defendant

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment, [32]

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DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[33]

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MOTION by Plaintiff Merch Traffic, LLC to approve consent judgment as to a Certain Defendant

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NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [32], motion to approve consent judgment[35] before Honorable Manish S. Shah on 6/26/2024 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motions for entry of default judgment [32] and to approve consent judgment [35] are granted. Enter Default Judgment Order. Enter Consent Judgment. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 6/26/2024. Notices Mailed.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 6/26/2024. Notices Mailed.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

NOTICE of withdrawal of surety bond 27 by John Summerfield from Greer, Burns & Crain, Ltd. (Received at the Intake Counter on 7/25/24).