2024-cv-06119

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22264084.

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

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2).

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Kahlia Roe Halpern

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.

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

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(List of Trademarks ex 1)

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

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for leave to file under seal [3] is granted. Mailed 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 1-2 regarding declaration 17

Exhibit 2-1

(Exhibit 2-2)

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)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 19, motion for temporary restraining order 14 before Honorable Virginia M. Kendall on 8/6/2024 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 8/6/2024. Plaintiff's Sealed Motion for Temporary Restraining Order [14] is granted. Temporary Restraining Order shall remain in effect up to and including 8/20/2024. Sealed Order to follow. Plaintiff's Motion for electronic service of process [19] is granted. Mailed notice

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 8/6/2024. Mailed notice

Registry Deposit Information Form by Merch Traffic, LLC

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

INJUNCTION BOND in the amount of $ 10,000.00 posted by Merch Traffic, LLC. (Document not scanned)

MOTION by Plaintiff Merch Traffic, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Merch Traffic, LLC in support of extension of time[27]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[28]

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time[27] before Honorable Virginia M. Kendall on 8/20/2024 at 09:30 AM.

ORDER regarding extension of Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 8/19/2024. Status hearing set for 9/3/2024 at 9:30 AM. Motion hearing set for 8/20/2024 is stricken. Mailed notice

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 32

Declaration of Kahlia R. Halpern

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 32 before Honorable Virginia M. Kendall on 9/3/2024 at 09:30 AM.

(Exhibit A)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/23/2024, answer due 9/13/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

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

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 9/3/2024. Plaintiffs' Motion for Preliminary Injunction 32 is granted. Order to follow. Status hearing set for 10/22/2024 at 9:30 AM. Mailed notice

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 9/3/2024. Mailed notice

NEW PARTIES: Dongguan City Fanfeizi Apparel Co., Ltd., Dongguan City Hongyu Apparel Co., Ltd., Dongguan City Hui Lin Apparel Co., Ltd., Dongguan Humen Xinhongxing Electrical Appliance Firm, Dongguan Rainbow Spray Garment Co., Ltd., Dongguan Weihong Trading Co., Ltd., Dongguan Xinyan Garment Co., Ltd., Dongguan Yunchangfei Garment Co., Ltd., East Apparel (Dongguan) Co., Ltd., Fujian Surprise Network Technology Co., Ltd., Fuzhou Jiaxing Youpin International Trade Co., Ltd., Fuzhou Oulilang Trading Co., Ltd., Guangxi Axi Technology Co., Ltd., Guangzhou Baiyun Area Etai Garment Factory, Guangzhou Kailishi Clothing Limiled Company, Guangzhou Langai E-Commerce Co., Ltd., Guangzhou Ruibeier Industrial Co., Ltd., Guangzhou Yuedong Clothing Co., Ltd., Guangzhou Zhongzhige Clothing Co., Ltd, Hangzhou Digu Clothing Co., Ltd., Hangzhou Shiyun Gayment Co., Ltd., HK XINYAN INDUSTRY LIMITED, Huzhou Jindou Network Technology Co., Ltd., Jiangxi Boton Garment Co., Ltd., Jiangxi Fangda Garment Co., Ltd., Jiangxi Laike Garment Co., Ltd., Jiangxi Smile Garment Co., Ltd., Jiangxi Xinda Garment Co., Ltd., Nanchang Vision Garment Co., Ltd., Ningbo Dekey Import & Export Co., Ltd., Ningbo Langke Import And Export Ltd., Ozeason Sportswear (Guangzhou) Co., Ltd., Quanzhou Darlfun Garments Co., Ltd., Quanzhou Xinyu International Trade Co., Ltd., Shangrao Gleshi Garment Company Limited, Shenzhen Tongchuang Sportswear Co.,Ltd., Tengdali (foshan) Technology Co., Ltd., Xiamen Enkulai Trading Co., Ltd., Xiamen Flyway Trading Co., Ltd., Yantai Yuda Clothing Co., Ltd., Yiwu Shirun Import And Export Co., Ltd., Zhongshan Mengqi E-Commerce Co., Ltd., A13NHVR8S4C39H, A1MV5IBMXSJ371, A20RC6P2UUZUF, A3P74P5V6VFOW1, Bartenev, ganlinxiaodian, Henanlingmamaoyiyouxiangongsi, HengYangShiZhengXiangQuErYuQinBaiHuoYouXianGongSi, HOANGHUY STORE, Jiapanshangmaodian, MA FEI, MCHOU (Usually delivered in about 10 days), Mitalley, NINENINE, Noaross Custom Flag Factory, ROKSLIDE, RongFengHome, tongshanxianshamishangmaoyouxiangongsi, TwoTPesos, When the door business shop, wutaotao, Yenikov, Yongkaili, zhouxiabaihuodian, ddmytoys, HYYS, jiahong2, moonshshsk, rww9208, Sizzle Chic Store, song1001, US ClothingStore-88, wangboxiong, Customgic, Easoongift, FeRuiYYD, GuangZhouFuLong, REVIVERISE STORE, TaiYuanChuNanKeJiYouXianGongSi, TeeZworld and TianChen 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

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment[41]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment[41] before Honorable Virginia M. Kendall on 10/3/2024 at 09:00 AM.

Exhibit A

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for entry of Default and Default Judgment against all Defendants remaining in the case 41 is granted. Enter Order of Default as to Defendants as outlined in Schedule A. Final Judgment to follow. Motion hearing set for 10/3/2024 and Status hearing set for 10/22/2024 are stricken. Mailed notice

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 9/24/2024. Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order, terminated case 46 in the amount of $150,000 as to certain defendants