2024-cv-07906

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22423369.

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

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable David Weisman. Case assignment: Random assignment. (Civil Category 2).

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)

AMENDED complaint by Merch Traffic, LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Schedule A regarding amended complaint 11

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 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 temporary restraining order[13], motion for miscellaneous relief[18], motion for leave to file[3] before Honorable LaShonda A. Hunt on 9/17/2024 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to file under seal 3 is granted. Schedule A 2 and Exhibit 2 to the Declaration of Emily Holt 17 shall remain under seal pending further order of the Court. Emailed notice.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery 13 and Plaintiff's Motion for Electronic Service of Process 18 is granted. 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. The Court finds that (1) the submitted evidence establishes a likelihood of success on the merits (including evidence of active infringement and sales into Illinois); (2) the harm to plaintiff is irreparable and cannot be fully compensated by money damages; (3) an injunction is in the public interest because of the consumer confusion caused by counterfeit goods and infringement interferes with Plaintiff's ability to control its intellectual property; and (4) 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 way to communicate with these online marketplace defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the Court will revisit the asset freeze, joinder, and personal jurisdiction. A $1,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Emailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable LaShonda A. Hunt on 9/12/2024. Emailed notice.

Registry Deposit Information Form by Merch Traffic, LLC

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (qrtr,)

BOND in the amount of $ 1,000.00 check, Receipt No. 100010871 posted by Merch Traffic, LLC

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/18/2024, answer due 10/9/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

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

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil Procedure 41(a)(1) and the Notice of Voluntary Dismissal Under Rule 41(a)(1) 27, this action is being dismissed without prejudice as to ADUSHOES and the Individuals and Entities Operating ADUSHOES. All pending motions and deadlines are terminated as moot. Civil case terminated. Emailed notice.

MOTION by Plaintiff Merch Traffic, LLC for Release of Bond (Faria De Souza, Luana)

NOTICE of Motion by Luana Faria De Souza for presentment of motion for miscellaneous relief[29] before Honorable LaShonda A. Hunt on 8/26/2025 at 10:00 AM. (Faria De Souza, Luana)

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for release of bond [29] is granted. Enter Order. The motion hearing set for 8/26/25 [30] is stricken. Mailed notice.

ORDER to Release Bond to Plaintiff. Signed by the Honorable LaShonda A. Hunt on 8/22/2025. Mailed notice.