原告律所:Sullivan & Carter, LLP
品牌:Madonna 麦当娜
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# | Date | Description |
15 |
09/04/2025
|
ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by John Joseph Mariane, IV 翻译 |
14 |
08/29/2025
|
MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff's motion to seal 4 is denied. "The court may for good cause shown enter an order directing that one or more documents be filed under seal." L.R. 26.2(b). "[A] district court must be sensitive to the rights of the public in determining whether any particular document, or class of documents, is appropriately filed under seal." United States v. Corbitt, 879 F.2d 224, 228 (7th Cir. 1989). Here, the plaintiff seeks to temporarily seal the list of defendants it has sued and exhibits to a declaration in support of a temporary restraining order that it has yet to file. The plaintiff argues that it intends to seek temporary ex parte relief and that sealing is necessary to prevent the defendants from learning of these proceedings prior to execution of the temporary restraining order. The plaintiff claims that the defendants would destroy evidence and hide or transfer assets, which would frustrate the plaintiff's ability to secure relief. But the plaintiff has not presented any evidence to support these claims. And the Court declines to join in the plaintiff's rampant speculation. Therefore, Dkt. No. 2 is unsealed. In fact, the plaintiff's claims are so speculative and generalized that the Court questions whether the plaintiff conducted an inquiry reasonable under the circumstances and whether the factual contentions have any evidentiary support. The Court has similar concerns about allegations in the complaint, including "Defendants operate in a collective and organized manner, often monitor trademark infringement litigation alert websites, are in continuous and active concert with one another, are in frequent communication with each other utilizing online chat platforms and groups, and use these collective efforts in an attempt to avoid liability and intellectual property enforcement efforts," and "Defendants go to great lengths to conceal their identities often using fictitious names and addresses to register and operate their massive network. For example, many of Defendants' names and physical addresses used to register the Defendant Internet Stores are incomplete. Other Defendants use privacy services that conceal the owners' identity and contact information. Upon information and belief, Defendants regularly create new websites and online marketplace accounts on various platforms using the identities listed on Schedule A as well as other unknown fictitious names and addresses. These are some of the common tactics used by Defendants to conceal their identities, the full scope and interworking of their massive infringing operation, and to avoid being shut down." Consequently, the Court orders the plaintiff to show cause why it has not violated Fed. R. Civ. P. 11(b) by making generalized assertions not specific to the defendants named in this lawsuit or making allegations that have no evidentiary support. The rule to show cause hearing is set for September 18, 2025, at 9:30 a.m. Mailed notice. 翻译 |
13 |
08/29/2025
|
MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff has filed a complaint alleging infringement by 67 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 20 is rarely appropriate in Schedule A cases. See, e.g., Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27 (N.D. Ill. Nov. 18, 2024). Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder on or before September 12, 2025. Alternatively, by the same date, the plaintiff may file an amended complaint naming one or more defendants; however, if the plaintiff names multiple defendants, the plaintiff must show that joinder of those defendants is proper. All pending motions are hereby stayed pending resolution of the joinder issue. Further, should the plaintiff (1) file an amended complaint naming fewer defendants in this case, (2) file a separate complaint naming one or more of the remaining defendants originally named in this case, and (3) assert the same claims against those defendants, the Court reminds the plaintiff of Local Rule 40.3(b)(2), which requires the plaintiff to indicate the number of the this case and the name of the judge to whom it was assigned. Mailed notice. 翻译 |
12 |
08/29/2025
|
MAILED to plaintiff(s) counsel Lanham Mediation Program materials 翻译 |
11 |
08/29/2025
|
MAILED trademark report to Patent Trademark Office, Alexandria VA 翻译 |
10 |
08/28/2025
|
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. 翻译 |
9 |
08/28/2025
|
CASE ASSIGNED to the Honorable Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 2). 翻译 |
8 |
08/27/2025
|
ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Alison K Carter 翻译 |
7 |
08/27/2025
|
Notice of Claims Involving Trademarks by Merch Traffic, LLC 翻译 |
6 |
08/27/2025
|
NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Merch Traffic, LLC 翻译 |
5 |
08/27/2025
|
ATTORNEY Appearance for Plaintiff Merch Traffic, LLC by Gouthami Vanam Tufts 翻译 |
4 |
08/27/2025
|
MOTION by Plaintiff Merch Traffic, LLC for leave to file Certain Documents Under Seal 翻译 |
3 |
08/27/2025
|
CIVIL Cover Sheet 翻译 |
2 |
08/27/2025
|
SEALED DOCUMENT by Plaintiff Merch Traffic, LLC Exhibit 2-Schedule A 翻译 |
1 |
08/27/2025
|
COMPLAINT filed by Merch Traffic, LLC; Filing fee $ 405, receipt number AILNDC-23950501. 翻译 |