Merch Traffic, LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A
| Merch Traffic, LLC |
| The Partnerships and Unincorporated Associations Identified on Schedule A, DesignbyMaSim, Bejsknf, DORFALNE, CHUNTIANRAN, Quanzhou Xinqihang E-Commerce Co., Ltd., EUR 2024, chengduweitinghuishangmaoyouxiangongsi, A29K5HJ2LRB8WC, AMWIPE, Guangzhou Shanghe Clothing Co., Ltd., Earlymemb, drfgdersthysedtr, banrimant, DaHeng-, AOEGFKC3MQ46C, CHENGFUHONG ART SHOP, DECLAREYAO Flagship Store, Zhejiang Weiyi Trade Co., Ltd., AIMITGE, Dressesmary, chenzhenhaibao, CHENXUANUS, CZCAH(7-15DAYS), halingshangmao, huaiwenguo666, jin rong thriving poster, JIOFIJNFO, guoyuliandianpu, gelishuo us poster, GJART, HT zhung, jiaxinyimaoyiyouxiangongsi, HRUKNOW, hongcai usa, Hamlen, Jendisett-US, Huo Wa, HongTongXianHongBoShangMaoDian, he yu art poster, FEI-DA, GuangZhouFeiLuShangMao, Guangzhoulanhangshangmaoyouxiangongsi, fython Poster us, huoyanrui, fu xin Happiness poster, FCDIED, Hyparkson, Fashella Store, jiqin post, kayaoshangmao, Keepons, Kerry-dober, Kim Mingi, Koibo-us, langfangshiayishacanyinyouxiangongsi, LANMERTREE Clothing Store, LANMERTREE STAR, lanxuanmaoyi, LE VAN HA VP2, LETISR US ART, Lewiscott, LIIUFoCoCo, LIN Art shop, liushuaifengggg, Liuxiaoyong, LONGPAXZ, lumancctv, makangbo, MAO SIGN, MaoGen.T.Zhu, MEIZIAHL, MIMORES, MNLYBABY, MYCHTE, Pyzzrs, Qbily Co., Ltd, rong yu, ROROFU, sedgqiubao, sesdrdrggteQ, Shangguanshounian and SHAOLIND |
| 1:2024cv10920 |
| October 23, 2024 |
| U.S. District Court for the Northern District of Illinois |
| Manish S Shah |
| Trademark |
| 15 U.S.C. § 1125 Trademark Infringement (Lanham Act) |
| None |
Docket Report
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| Filing 41 FULL SATISFACTION of Judgment regarding order #40 in the amount of $50,000 as to certain defendants (Halpern, Kahlia) |
| Filing 40 DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/17/2024. Notices Mailed. (psm, ) |
| Filing 39 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 #33 is granted. Enter Default Judgment Order. Terminate civil case. Notices Mailed. (psm, ) |
| Filing 38 ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Andrew Daniel Burnham (Burnham, Andrew) |
| Filing 37 NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to certain defendant (Halpern, Kahlia) |
| Filing 36 NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment #33 before Honorable Manish S. Shah on 12/17/2024 at 09:45 AM. (Attachments: #1 Exhibit A)(Halpern, Kahlia) |
| Filing 35 DECLARATION of Justin R. Gaudio regarding memorandum in support of motion #34 (Attachments: #1 Exhibit 1)(Gaudio, Justin) |
| Filing 34 MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default, motion for default judgment #33 (Attachments: #1 Exhibit 1)(Halpern, Kahlia) |
| Filing 33 MOTION by Plaintiff Merch Traffic, LLC for entry of default , MOTION by Plaintiff Merch Traffic, LLC for default judgment as to all Defendants (Attachments: #1 Exhibit A)(Halpern, Kahlia) |
| Filing 32 NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to Certain Defendants (Halpern, Kahlia) |
| Filing 31 NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to certain defendants (Halpern, Kahlia) |
| Filing 30 NOTICE of Voluntary Dismissal by Merch Traffic, LLC as to certain defendants (Halpern, Kahlia) |
| Filing 29 PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 11/13/2024. Notices Mailed. (psm, ) |
| Filing 28 MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction #24 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. (psm, ) |
| NEW PARTIES: Guangzhou Shanghe Clothing Co., Ltd., Quanzhou Xinqihang E-Commerce Co., Ltd., Zhejiang Weiyi Trade Co., Ltd., A29K5HJ2LRB8WC, AIMITGE, AMWIPE, AOEGFKC3MQ46C, banrimant, Bejsknf, chengduweitinghuishangmaoyouxiangongsi, CHENGFUHONG ART SHOP, CHENXUANUS, chenzhenhaibao, CHUNTIANRAN, CZCAH(7-15DAYS), DaHeng-, DECLAREYAO Flagship Store, DesignbyMaSim, DORFALNE, Dressesmary, drfgdersthysedtr, Earlymemb, EUR 2024, Fashella Store, FCDIED, FEI-DA, fu xin Happiness poster, fython Poster us, gelishuo us poster, GJART, GuangZhouFeiLuShangMao, Guangzhoulanhangshangmaoyouxiangongsi, guoyuliandianpu, halingshangmao, Hamlen, he yu art poster, hongcai usa, HongTongXianHongBoShangMaoDian, HRUKNOW, HT zhung, huaiwenguo666, Huo Wa, huoyanrui, Hyparkson, Jendisett-US, jiaxinyimaoyiyouxiangongsi, jin rong thriving poster, JIOFIJNFO, jiqin post, kayaoshangmao, Keepons, Kerry-dober, Kim Mingi, Koibo-us, langfangshiayishacanyinyouxiangongsi, LANMERTREE Clothing Store, LANMERTREE STAR, lanxuanmaoyi, LE VAN HA VP2, LETISR US ART, Lewiscott, LIIUFoCoCo, LIN Art shop, liushuaifengggg, Liuxiaoyong, LONGPAXZ, lumancctv, makangbo, MAO SIGN, MaoGen.T.Zhu, MEIZIAHL, MIMORES, MNLYBABY, MYCHTE, Pyzzrs, Qbily Co., Ltd, rong yu, ROROFU, sedgqiubao, sesdrdrggteQ, Shangguanshounian and SHAOLIND added to case caption. (Gaudio, Justin) |
| Filing 27 SUMMONS Returned Executed by Merch Traffic, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/7/2024, answer due 11/28/2024. (Attachments: #1 Declaration of Luana Faria de Souza, #2 Exhibit A)(Faria De Souza, Luana) |
| Filing 26 NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction #24 before Honorable Manish S. Shah on 11/13/2024 at 09:45 AM. (Attachments: #1 Exhibit A)(Halpern, Kahlia) |
| Filing 25 MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction #24 (Attachments: #1 Declaration of Kahlia R. Halpern, #2 Exhibit 1)(Halpern, Kahlia) |
| Filing 24 MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction (Attachments: #1 Exhibit A)(Halpern, Kahlia) |
| Filing 23 SURETY BOND in the amount of $ 50,000 posted by Merch Traffic, LLC. (Document not scanned) (aee, ) |
| SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (smb, ) |
| Filing 22 Registry Deposit Information Form by Merch Traffic, LLC (Halpern, Kahlia) |
| Filing 21 TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/30/2024. Notices Mailed. (psm, ) Modified on 12/19/2024 (smb, ). |
| Filing 20 MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 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, account information would be redirected, defeating plaintiff's interests in identifying defendants and stopping the infringement. 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 limited asset freeze (limited to proceeds traceable to sales of infringing products). 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 $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed. (psm, ) |
| Filing 19 NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file #3 , motion for miscellaneous relief #16 , motion for temporary restraining order #11 before Honorable Manish S. Shah on 10/31/2024 at 09:45 AM. (Gaudio, Justin) |
| Filing 18 DECLARATION of Justin R. Gaudio regarding memorandum in support of motion #17 (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Gaudio, Justin) |
| Filing 17 MEMORANDUM by Merch Traffic, LLC in support of motion for miscellaneous relief #16 (Gaudio, Justin) |
| Filing 16 MOTION by Plaintiff Merch Traffic, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) (Gaudio, Justin) |
| Filing 15 EXHIBIT by Plaintiff Merch Traffic, LLC Exhibit 2 - Parts 1-2 regarding declaration #14 (Attachments: #1 Exhibit 2-1, #2 Exhibit 2-2)(Gaudio, Justin) Modified on 12/19/2024 (smb, ). |
| Filing 14 DECLARATION of Emily Holt regarding memorandum in support of motion #12 (Attachments: #1 Exhibit 1)(Gaudio, Justin) |
| Filing 13 DECLARATION of Justin R. Gaudio regarding memorandum in support of motion #12 (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Gaudio, Justin) |
| Filing 12 MEMORANDUM by Merch Traffic, LLC in support of motion for temporary restraining order #11 (Gaudio, Justin) |
| Filing 11 MOTION by Plaintiff Merch Traffic, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery (Gaudio, Justin) |
| Filing 10 ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Luana Faria De Souza (Faria De Souza, Luana) |
| Filing 9 ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Kahlia Roe Halpern (Halpern, Kahlia) |
| Filing 8 ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Amy Crout Ziegler (Ziegler, Amy) |
| Filing 7 ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Justin R. Gaudio (Gaudio, Justin) |
| Filing 6 Notice of Claims Involving Trademarks by Merch Traffic, LLC (Gaudio, Justin) |
| Filing 5 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Merch Traffic, LLC (Gaudio, Justin) |
| Filing 4 CIVIL Cover Sheet (Gaudio, Justin) |
| Filing 3 MOTION by Plaintiff Merch Traffic, LLC for leave to file under seal (Gaudio, Justin) |
| Filing 2 SCHEDULE A by Plaintiff Merch Traffic, LLC Schedule A regarding complaint #1 (Gaudio, Justin) Modified on 12/19/2024 (smb, ). |
| Filing 1 COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-22644665. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Gaudio, Justin) |
| CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. Case assignment: Random assignment. (Civil Category 2). (lcd, ) |
| 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. (lcd, ) |
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