2025-cv-08126

2025-cv-08126 Merch Traffic, LLC v. The Partnerships Ldentified On Schedule A

Date :7/17/2025
BrandMadonna 麦当娜
Court :Northen District of Illinois
Law FirmSULLIVAN

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Date

Document

1

July 17, 2025

COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23763364.

(Exhibit 1)

Exhibit 1

2

July 17, 2025

SEALED DOCUMENT by Plaintiff Merch Traffic, LLC Exhibit 2 - Schedule A

3

July 17, 2025

CIVIL Cover Sheet

4

July 17, 2025

MOTION by Plaintiff Merch Traffic, LLC for leave to file Certain Documents under Seal

5

July 17, 2025

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Alison K Carter

6

July 17, 2025

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Ann Marie Sullivan (Sullivan, Ann Marie)

7

July 17, 2025

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by John Joseph Mariane, IV

July 17, 2025

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

8

July 18, 2025

ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Gouthami Vanam Tufts

11

Aug. 22, 2025

AMENDED complaint by Merch Traffic, LLC against The Partnerships ldentified on Schedule A

15

Aug. 28, 2025

MOTION by Plaintiff Merch Traffic, LLC for leave to file certain documents under seal (Amended) [4]

16

Aug. 28, 2025

MOTION by Plaintiff Merch Traffic, LLC for temporary restraining order

19

Aug. 28, 2025

MOTION by Plaintiff Merch Traffic, LLC for electronic service of process

22

Sept. 8, 2025

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal [15], motion for electronic service of process [19], and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery [16] are granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and 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 effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Mailed notice

23

Sept. 8, 2025

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 9/8/2025. Mailed notice

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