2024-cv-05824

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22226453.

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 Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Sheila Finnegan. 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]

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 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]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 16 are granted. Plaintiff is advised that it should effectuate service promptly and not wait until close to the date for the preliminary injunction hearing. Plaintiffs ex parte motion for entry of a temporary restraining order (etc.) 11 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 7/29/2024 at 8:50 AM. The following call-in number will be used: 650-479-3207, access code 980-394-33. Motion for preliminary injunction or motion to extend TRO is to be filed by 7/24/2024. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 7/15/2024.

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

Registry Deposit Information Form by Merch Traffic, LLC

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

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 23

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 7/22/2024, answer due 8/12/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Matthew F. Kennelly: Because it appears from the docket that summons in this case were not electronically served until 7/22/2025, the preliminary injunction hearing set for 7/29/2024 is vacated and reset to 8/5/2024 at 9:05 AM, using call-in number 650479-3207, access code 980-394-33. The ex parte temporary restraining order entered on 7/15/2024 is extended at the Court's instance through the close of business on 8/5/2024. The Court reserves the right to vacate the hearing on 8/5/2024 if no defendant has appeared or filed a response to the motion for preliminary injunction.

ATTORNEY Appearance for Defendant KJHL by Pete Scott Wolfgram

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 8/1/2024, answer due 8/22/2024.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: The defendants in this case were electronically served with summons by no later than 7/22/2024. No defendant has appeared in the case; responded to the complaint; or filed anything at all. The telephonic preliminary injunction hearing set for 8/5/2024 is vacated. Plaintiff's motion for entry of a preliminary injunction 23 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 10/8/2024 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 980-394-33. Plaintiff is directed to file a status report on 8/1/2024. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 8/2/2024. Mailed notice.

NEW PARTIES: Quanzhou City Licheng District Wuxia Clothing Accessories Firm(Individual Business), Shenzhen T - Worthy Electronics Co., Ltd., A3H0JA7M2X6Q3U, Amz Loole-us, chuxiaokun, cutebox-studio, EmilyHome, FSJkangy428, guchengxianfangwangtianhangshangmaoyouxiangongsi01, jiangxishengningdanzhuangshigongchengyouxiangongsi, Jinan Mingjinsong Clothing Trading Co., Ltd, Juyue, KJHL, laohekoushixingruifudianzishangwugongzuoshi, lichengwu+fengpingshangmao, MAILAINK, ShunRanBianLiShangHang, Stitionhoness, WENTANGPOSTER, xiaoguoling, yongyaojing, ZHANG2WENJUAN, zhijiangshihuangpaofushangmao, zhijiangshixuanercaishangmaodian, rdcx6688, atccoltd, AZHOBBYSTORE, KHOASPACE, podgift, Qiang0023, retromusicposter, rrfd001, baytrau, Beautiful progress, dssdgdsgs, guangzhoumaidashangmaoyouxiangongsi, Hailing Stationery store, Henan Aojing Ecological, PengXiaoYu, XiangYangShiChunLuoShangMaoYouXianGongSi and XiaoNingFeiShangMao added to case caption.

MINUTE entry before the Honorable Matthew F. Kennelly: This order corrects docket entry 30 which contained a typographical error. The defendants in this case were electronically served with summons by no later than 7/22/2024. No defendant has appeared in the case; responded to the complaint; or filed anything at all. The telephonic preliminary injunction hearing set for 8/5/2024 is vacated. Plaintiff's motion for entry of a preliminary injunction 23 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 10/8/2024 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 980-394-33. Plaintiff is directed to file a status report on 10/1/2024. Mailed notice.

MOTION by Defendant KJHL for extension of time to file answer regarding complaint[1] (Unopposed)

MINUTE entry before the Honorable Matthew F. Kennelly: Defendant KJHL's unopposed motion for extension of time 33 is granted; response to complaint is to be filed by 9/7/2024. This does not affect any other date or deadline set by the Court.

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[37]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[38]

Exhibit 1

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default 37 is granted. Final Default Judgment Order to follow. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 8/27/2024. Mailed notice. Modified on 8/29/2024.

MAILED trademark report with certified copy of minute order dated 8/27/2024 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 41 in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 41 in the amount of $100,000 as to certain defendant

NOTICE of withdrawal of surety bond 22 by John Summerfield (Received at the Intake Counter on 10/29/2024) (Received for docketing 11/21/2024)