2025-cv-12495

COMPLAINT filed by Pit Viper, LLC; Filing fee $ 405, receipt number AILNDC-24190459.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 3 regarding complaint[1]

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Pit Viper, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Pit Viper, LLC

Notice of Claims Involving Trademarks by Pit Viper, LLC

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Trevor Christian Talhami

MAILED Trademark report to Patent Trademark Office, Alexandria VA

((List of Trademarks, Ex. 1))

MAILED Copyright report to Registrar, Washington DC

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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.)

((List of Copyrights Ex. 2))

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal 4 is granted. Mailed notice.

MOTION by Plaintiff Pit Viper, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Pit Viper, LLC in support of motion for temporary restraining order 14

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 15

DECLARATION of Vance Lommen regarding memorandum in support of motion 15

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 3 regarding declaration 17

MOTION by Plaintiff Pit Viper, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Pit Viper, LLC in support of motion for miscellaneous relief 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Additionally, to the extent Plaintiff also makes a motion for expedited discovery or for an order permitting electronic service of process, Plaintiff should submit a proposed order for that relief that is separate from the proposed order for the TRO and asset restraint. The proposed order for the TRO and asset restraint should name the relevant defendants directly in the order, without reference to Schedule A. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 19 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 10/17/2025. Mailed notice.

SEALED Order Authorizing Expedited Discovery and Electronic Service of Process. Signed by the Honorable Thomas M. Durkin on 10/17/2025. Mailed notice.

Registry Deposit Information Form by Pit Viper, LLC

SUMMONS Submitted (Court Participant) for defendant(s) Amr Wang and all other Defendants identified in the Complaint by Plaintiff Pit Viper, LLC

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

SURETY BOND in the amount of $13,000.00 posted by Pit Viper, LLC (Document not scanned). (bi,)