2025-cv-02111

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23146803.

Exhibit 1

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 Mary M. Rowland. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

NEW PARTIES: AnQingQinGuangShangMaoYouXianGongSi, chuangjiaye, DKJFDDS523, HengYangXianYanDingShangMaoYouXianGongSi, hoanghuyen1010, HongQingYuMaoYiYouXianGongSi, JuyongUS, LinJ ART SHOP, RoyalBlueDesigns, TaiYuanChengShuoShangMao, Tumbeer, wanghaojian, xianxielid, YANGNIANZUTOUXIGUA, yanjinxianhefucanyinguanliyouxiangongsi, YANJSDIJN, 2024gooddeal, aofeihu0, pdartace, Personality show, qaodfehf6, guangzhoumaidashangmaoyouxiangongsi and oguang added to case caption.

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

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

(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 18

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

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13 is granted. Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 18 are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/10/2025.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Merch Traffic, LLC

Registry Deposit Information Form by Merch Traffic, LLC

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

SURETY BOND in the amount of $24,000 posted by Merch Traffic, LLC (Document not scanned)

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[27]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[28]

MINUTE entry before the Honorable Mary M. Rowland: Motion for extension of TRO [27] is granted. TRO extended to 4/7/25. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/20/2025. 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[32]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[33]

SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/27/2025, answer due 4/17/2025.

Declaration of Kahlia R. Halpern

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for preliminary injunction 33 is due by 4/11/25. Status report from Plaintiff due by 4/18/25. Mailed notice.

STATUS Report per [36] by Merch Traffic, LLC

Exhibit A

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

(Exhibit 2)

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

Exhibit 1

(Exhibit 2)

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

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [36]. Without objection, Plaintiff's motion for preliminary injunction [32] is granted. Enter Preliminary Injunction Order. Any response to Plaintiff's motion for default [38] is due 5/30/25. Status report due 6/9/25. The Clerk is directed to unseal any previously sealed documents in this matter. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 5/7/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Response to the motion for default that was filed on 4/21/25 38 is due 6/3/25. Status report due 6/13/25. Mailed notice.

STATUS Report per [42] by Merch Traffic, LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report. [45]. No defendant has responded to Plaintiff's motion for default. [38]. Motion for default is granted. Enter Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 6/10/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: The twenty-four thousand dollars ($24,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Mailed notice.

NOTICE of withdrawal of bond 26 by John Summerfield.