2024-cv-07604

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22393824.

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

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable Sheila M. 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.

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)

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[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Emily Holt regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 Part 1 regarding declaration[16]

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[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for temporary restraining order[13], motion for miscellaneous relief[18] before Honorable Sara L. Ellis on 8/29/2024 at 01:45 PM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motions for leave to file under seal [3], for electronic service of process [18], and for entry of a temporary restraining order [13]. The Court sets a telephonic status date for 9/12/2024 at 1:45 PM. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status date. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Sara L. Ellis 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 preliminary injunction

Exhibit A

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction[26]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[26] before Honorable Sara L. Ellis on 9/12/2024 at 01:45 PM.

Exhibit A

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/6/2024, answer due 9/27/2024.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for preliminary injunction 26. The Court sets a telephonic status date for 10/15/2024 at 9:45 AM. Plaintiff should file any motion for entry of default and for default judgment and notice the motion for presentment at the next status date. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns & 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. https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Sara L. Ellis on 9/10/2024:Mailed notice

NEW PARTIES: A1EBS5XBJ2ZG1H, AmyHHood, AR5Y4T0016C0O, Avlovsky, BaiHu1, baodingchaomianmaoyiyouxiangongsi, BlissPoster32, Chen Jianl, Chinchuliscu, color11, Froblovsky, guangzhouhaolushangmaoyouxiangongsi, hungbeo, koucacui, LAMSTLOFASH, Lelong Bull, lipeisnderr, Mallet, Melalangelo, Pan Ji tower, PianZe1, QUANG HUY SHOP 2399, Schnupfeld, Shtaralova, Stryzek, Sunb8, taiyuanshilichuzuwangluokejifuwubugerenduzi, Tianjin Hexi Hadron clothing wholesale shop, vandaigyhy213, wanghong231, XiYangSYue, Zheng Wuu, ZJYHIIAIIO, ngla_77, Jiuwu J, LANMAN GLEAN, Limited edition clothing, MI SHU TIIN, Pigment Playhouse, Poster Factory, Rrose, Winmist, Rongwang Lighting store, Weifujin, grdfhtrhjnytf, hgh678fghg, huxialong723, jingzhonglai5967, niandongyan1234, nmxbvcfdr1520, qingyimian and wanghuimin19961120 added to case caption.

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

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, [33]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[34]

Exhibit 1

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

Exhibit A

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [33], motion to approve consent judgment[36] before Honorable Sara L. Ellis on 10/8/2024 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Defendant Rrose by Christopher Paul Keleher

MOTION by Defendant Rrose for extension of time to file answer regarding complaint[1] (First extension, unknown if opposed)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[39] before Honorable Sara L. Ellis on 10/9/2024 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motions for entry of default and default judgment 33 and to approve consent judgment 36. The Court grants Defendant's motion for extension of time to answer or otherwise plead 39. Defendant's responsive pleading is due by 10/23/2024. The Court strikes the telephonic status date set for 10/8/2024 and resets it to 10/29/2024 at 9:30 AM. Plaintiff should file a status report on the status of Defendant Rrose by 10/24/2024. Mailed notice

STATUS Report per [41] by Merch Traffic, LLC

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

MINUTE entry before the Honorable Sara L. Ellis: The Court strikes the telephonic status date set for 10/29/2024 and resets it to 11/12/2024 at 9:30 AM. If the parties file a notice of dismissal pursuant to F.R.Civ.P. 41(a)(1) prior to the next status hearing, no appearance is required. Mailed notice

MINUTE entry before the Honorable Sara L. Ellis: Pursuant to Plaintiff's notice of voluntary dismissal [43], the Court dismisses this matter without prejudice and with leave to reinstate within 270 days, after which this dismissal will convert to one with prejudice. The parties will each bear their own costs and fees. Civil case terminated. Emailed notice

CONSENT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 11/13/2024:Emailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 11/13/2024. Emailed notice

MAILED Trademark report with certified copy of minute order dated 11/08/24 to Patent Trademark Office Alexandria VA

FULL SATISFACTION of Judgment regarding Default Judgment 47 in the amount of $100,000 as to certain defendant

MAILED original ten-thousand-dollar $10,000 surety bond posted by Merch Traffic, LLC to Greer, Burns & Crain, Ltd. 200 W Madison St. Ste 2100, Chicago, IL 60606 via certified mail #9589 0710 5270 0579 7825 57