2024-cv-09890

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22588675.

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 Robert W. Gettleman. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category Two).

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.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Manish S. Shah for all further proceedings pursuant to 28 USC 294(b). 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[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Emily Holt regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Part 1 regarding declaration[15]

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[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for miscellaneous relief[17], motion for temporary restraining order[12] before Honorable Manish S. Shah on 10/22/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions are granted and no appearance is necessary. The court limits the asset restraint to assets traceable to the proceeds of sales of infringing products. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/21/2024. Notices Mailed.

Registry Deposit Information Form by Merch Traffic, LLC

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

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 Manish S. Shah on 10/31/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time [24] is granted, and no appearance is necessary. The TRO is extended to 11/18/24. Notices Mailed.

INJUCTION BOND in the amount of $ 50,000.00 posted by Merch Traffic, LLC

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 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 Manish S. Shah on 11/12/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/5/2024, answer due 11/26/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [30] is granted in part. Just as with the Temporary Restraining Order, the court declines to impose a total asset restraint on defendants and will only restrain assets that can be traced to the sale of the infringing works. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 11/12/2024. Notices Mailed.

NEW PARTIES: Quanzhou Diyuan Trading Co., Ltd, A2HHBNXAN160QL, A3KWM0ACJDZ79, ASKRAK, candzhangfan, DGbf5552, EleanorJoseph, Gerenlichak, gyinxianhanmuxinshangmao, Hoangngan2001, KunyaoWu store, leis865, lidexiangdianpu, linxuesfe, LIUKUIMAOYI, LuoQing11, minishopmix, Phuong thai store, weihomed, YCHOOP, YingGaiUKshop, yuxianglinxin, zhangningsds, ZKSMYX and Hutong Vehicle added to case caption.

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

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/18/2024, answer due 12/9/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

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 Manish S. Shah on 12/17/2024 at 09:45 AM.

Exhibit A

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

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 38 is granted. Enter Default Judgment Order. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/17/2024. Notices Mailed.