2024-cv-07984

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22429266.

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 Jorge L. Alonso. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2).

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 - Parts 1-2 regarding declaration 14

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 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 Jorge L. Alonso on 9/11/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [11] [16] are granted, and no appearance is necessary. The 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. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. 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, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $93,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 9/11/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 9/10/2024. Notice mailed by Judge's staff

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 $ 93,000.00 posted by Merch Traffic, LLC (Document not scanned.)

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 24

Declaration of Kahlia R. Halpern

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 24 before Honorable Jorge L. Alonso on 9/24/2024 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 9/19/2024, answer due 10/10/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 9/24/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction as to certain Defendants [24] is granted. Enter Preliminary Injunction Order. Plaintiff 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 at www.ilnd.uscourts.gov. Telephonic status hearing set for 11/7/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 9/24/2024. Notice mailed by Judge's staff

NEW PARTIES: Putian Yuanzhou E-Commerce Co., Ltd., 12czs, A1FKRT0F3FR5CE, A1SG0DMAZCMIMH, Amandaor, Aw399i.vsiy, Bingshu Store, CENNUOHOME, Cheng Xiaoo, Chery MarsA, Corsicari, D Beautiful Cong, DaiYueTuoHong, DeclSkins, Dragon Fly Z, en64634046, foshanshixinbodaishangmaoyouxiangongsi, fulinyi, Gaza wavelength, guangzhoulingmingmaoyiyouxiangongsi, guangzhouqingjishangmaoyouxian, hengsushangmaooo, hengyangshimaanwangluokejiyouxiangongsi, jinlulu Happy, junliangsa, KNIMANESHABI, L Liu Kaikai, Lance A Parton, LiuJiaQi FeiChao, ma po, MaureenSmith, minyu3333, Mzys35s, ong Xuebin, peoplesign, putianshihanjiangquhezhenhuamaoyiyouxiangongsi, qirouvRpFnm, Rose245iller, ShanXiRongTangGuoKaiWangLuoKeJiYouXianGongSi, shaoshuaixiaodian, shenyefanshangmaobaihuoxiaodian, StevenHoppe, Thank swallow, Traffm5an, Valedra Store, Wang Tengf, wanglingskjdksj, Wangsiming, WANGYINGu, Xiu Rou Nuo, Xuyufeifei, Yang Xiaonan, YeKi, Yutong Zhao Store, zouyaot Shop, monclerjack, original_top, tktk, csuntees, frtauibn2, langhongyou, Demai, GAERGRMA, HNSTBTDZSWLLC, Lanhongyou, LXXeiiu, TaiYuanShiKongQingShangMao, wuhanyikewenshangmao, chunpingdian, daiguangxian999, Duanliuliu78523, gaozhgcai6318, hexingyan6079, Hummingbird Industries, hurongfang123, hushuhuan1114, Jason West, kidswen, laixiaoling5741, lihuahaya, longlisha, Mary Shannon, meizhi5201314, niwenqi820, Richarter, S6D6F6, sunguoqing245, Tonghuistationerystore, Vencent Bettini, xingzhenkun, yanyan1988, yiguo fashion and zhaoyu47474 added to case caption.

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/24/2024, answer due 10/15/2024.

Declaration of Luana Faria de Souza

Exhibit A

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

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 36

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 37

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 36 before Honorable Jorge L. Alonso on 10/23/2024 at 09:30 AM.

(Exhibit A)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/23/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment 36 is granted. Enter Final Default Judgment Order. Status hearing date of 11/7/24 is stricken. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 10/23/2024. Notice mailed by Judge's staff

MAILED trademark report to Patent Trademark Office, Alexandria VA. (jn,)

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

MAILED trademark report with certified copy of minute order dated 10/23/2024 to Patent Trademark Office, Alexandria VA. (jn,)

FULL SATISFACTION of Judgment regarding order 42 in the amount of $150,000 as to certain defendants