2024-cv-07431

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22378436.

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 Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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

(Exhibit 2-1)

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)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 16, motion for leave to file 3, motion for temporary restraining order 11 before Honorable Jeremy C. Daniel on 8/28/2024 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. The plaintiff's motions 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 [11] and motion for electronic service of process pursuant to FED.R.CIV.P. 4(f0(3) [16] are granted. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 8/28/2024.Mailed notice.

Registry Deposit Information Form by Merch Traffic, LLC

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

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

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 24

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 25

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 24 before Honorable Jeremy C. Daniel on 9/11/2024 at 09:30 AM.

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Andrew Daniel Burnham

EXTENSION OF TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 9/11/2024. Motion hearing held. Plaintiff's motion to extend the temporary restraining order [24] is granted. The TRO now expires on 9/25/2024. 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[30]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[30] before Honorable Jeremy C. Daniel on 9/17/2024 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 9/12/2024, answer due 10/3/2024.

Declaration of Luana Faria de Souza

Exhibit A

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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 9/17/2024. Motion hearing held. Plaintiff's motion for entry of a preliminary injunction as to certain defendants [30] is granted. The plaintiff is hereby 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 www.ilnd.uscourts.gov/instructions. Mailed notice.

NEW PARTIES: A1F6VDENYEPQMF, A1H9VQ9EBM409A, And-robles, AUGETY, Aurora art shop, BaLayue, BDGYEFTT, Chenpingp, ComfortNook22, Fairshaw, fanjiangfeng, foshanshinanhaiquhanfangeshangmaoxinggerenduzi, Gaosi Tools, Gracor201, guangzhouduofushangmaobugerenduzi, Guangzhouhaochushangmaoyouxiangongsi, guangzhouyongshemaoyiyouxiangongsi, Hongdingqwuqn, It's a special castle, JingMenShiDongBaoQuShuanYeBaiHuoDian, Lhasa Germany, Liu Congc, liusuit, lizifengxiaodian, minhdertor, MUJIAN, NOORSHREE, QinHuangDaoLingQuanWenHuanChuanMeiYouXianGongSi, ScienDirect-wma, Speed and Fire, tongshanxianqianzhuiyumaoyiyouxiangongsi, TU-STOUR, Wuhan Muziyue Trading Co., Ltd, XingTaiLaoJianMaoYiYouXianGongSi, XudianART, xueyanga, Xuxiustrong, yongjixiyubaihuoshanghanggerenduzi, YuXinyu, YWJDP, Zhnegyb, zouyujian, Teal Forest, shuaihang, Tian Fragrant Toys, BBBRRR8, c6c6c6w8, Gregory J. Loveridge, her3i2, linyaping, meixiaomei and yubochang2799 added to case caption.

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

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[38]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[39]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment[38] before Honorable Jeremy C. Daniel on 10/10/2024 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Defendants Tian Fragrant Toys, shuaihang by Adam Edward Urbanczyk

MOTION by Defendants Tian Fragrant Toys, shuaihang for extension of time

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time[44] before Honorable Jeremy C. Daniel on 10/10/2024 at 09:30 AM.

ATTORNEY Appearance for Defendants Tian Fragrant Toys, shuaihang by Brian Swift

MINUTE entry before the Honorable Jeremy C. Daniel: Defendants Tian Fragrant Toys and shuaihang's motion for an extension of time [44] is granted. These defendants shall answer or otherwise plead on or before October 30, 2024. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Default judgment entered. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 10/10/2024. Mailed notice.

***Civil Case Terminated.

MOTION by Defendants shuaihang, Tian Fragrant Toys for extension of time UNOPPOSED

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time[50] before Honorable Jeremy C. Daniel on 11/7/2024 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Defendants shuaihang and Tian Fragrant Toys' motion for an extension of time [50] is granted. These defendants shall answer or otherwise plead on or before November 20, 2024. The motion hearing is stricken. Mailed notice.

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

MINUTE entry before the Honorable Jeremy C. Daniel: Status Report due on or before 12/13/2024. Mailed notice.

STATUS Report pursuant to [54] by Merch Traffic, LLC

MINUTE entry before the Honorable Jeremy C. Daniel: Pursuant to the plaintiff's status report 55, which reports that all defendants have either defaulted or been dismissed, this case is now closed. Civil case terminated. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: Any party to this action has until October 20, 2025, to justify the continued need to seal any documents in this case. The Court intends to unseal all documents in this case after that date. Mailed notice.