NRRM, LLC v. Consumers Unified, LLC et al
| Oklahoma Northern District Court | |
| Judge: | Gregory K Frizzell |
| Referred: | Christine D Little |
| Case #: | 4:25-cv-00066 |
| Nature of Suit | 840 Property Rights - Trademark |
| Cause | 15:1125 Trademark Infringement (Lanham Act) |
| Case Filed: | Feb 10, 2025 |
| Last checked: Monday Feb 10, 2025 6:06 PM CST |
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Defendant
ConsumerAffairs.com Holdings, LLC
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Represented By
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Defendant
Consumers Unified Insurance Agency LLC
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Represented By
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Defendant
Consumers Unified, LLC
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Represented By
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Plaintiff
NRRM, LLC
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Represented By
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| TERMINATED PARTIES | |
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Defendant
John Doe
Terminated: 10/08/2024
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| Docket last updated: 11 hours ago |
| Monday, February 10, 2025 | ||
| 46 | 46
misc
Letter re: Local Counsel Requirement
Mon 02/10 3:17 PM
LETTER re: Local Counsel Requirement sent to Jeffrey H Kass (atn, Dpty Clk) |
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| 45 | 45
order
02 - Minute Order Case - Number Changed
Mon 02/10 3:13 PM
MINUTE ORDER by Court Clerk , changing case number to 25-cv-66-GKF-CDL (This entry is the Official Order of the Court. No document is attached.) (atn, Dpty Clk) |
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| 44 | 44
order
02 - Minute Order Directing - Party(ies) to File Disclosure Statement
Mon 02/10 3:12 PM
MINUTE ORDER by Court Clerk , directing NRRM, LLC; Consumers Unified, LLC; ConsumerAffairs; ConsumerAffairs.com Holdings, LLC; and Consumers Unified Insurance Agency LLC to file a Disclosure Statement pursuant to FRCvP 7.1 and LCvR 7.1-1, if applicable. The parties shall use the form entitled Disclosure Statement available on the Courts website. (This entry is the Official Order of the Court. No document is attached.) (atn, Dpty Clk) |
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| 43 | 43
transfer
Case Transferred from Another District
Mon 02/10 2:48 PM
CASE TRANSFERRED IN from Missouri Eastern 4:23-cv-1333 |
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| Monday, January 27, 2025 | ||
| 42 | 42
ORDER OF TRANSFER TO OTHER DISTRICT to: Northern District of Oklahoma... IT IS HEREBY ORDERED that the stay previously imposed in this case is LIFTED. IT IS FURTHER ORDERED that defendants' Motion to Dismiss or Transfer Under the First-Filed Rule [34 ] is GRANTED to the extent defendants seek to transfer this case to the Northern District of Oklahoma. The motion is DENIED to the extent defendants seek to dismiss this case. IT IS FURTHER ORDERED that this case is transferred to the United States District Court for the Northern District of Oklahoma. All motions currently pending in this case are reserved for ruling by that court. ( Case to be transferred after 2/10/2025.). Signed by Sr. District Judge Catherine D. Perry on 1/27/2025. (NEP) [Transferred from Missouri Eastern on 2/10/2025.]
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| Monday, November 25, 2024 | ||
| 41 | 41
REPLY to Response to Motion re34 MOTION to Dismiss Case or Transfer Under the First-Filed Rule filed by Defendants Consumers Unified, LLC, Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| Monday, November 18, 2024 | ||
| 40 | 40 Docket Text ORDER: Re:38 MOTION for Leave to File in Excess of Page Limitation of Memorandum by Plaintiff NRRM, LLC. (Kass, Jeffrey) filed by NRRM, LLC ; ORDERED GRANTED. Signed by Sr. District Judge Catherine D. Perry on 11/18/2024. (KRZ) [Transferred from Missouri Eastern on 2/10/2025.] | |
| Thursday, November 14, 2024 | ||
| 39 | 39
22
pgs
MEMORANDUM in Opposition re34 MOTION to Dismiss Case or Transfer Under the First-Filed Rule filed by Plaintiff NRRM, LLC.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Exhibit Exhibit A - Declaration of Jeffrey Kass,
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Att: 2
Exhibit Exhibit B - Barbara Moschovidis' 11/5 email
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| 38 | 38
MOTION for Leave to File in Excess of Page Limitation of Memorandum by Plaintiff NRRM, LLC. (Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| Monday, November 04, 2024 | ||
| 37 | 37 Docket Text ORDER: Re:35 MOTION for Leave to File Over Length Memorandum by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David); ORDERED GRANTED. Signed by Sr. District Judge Catherine D. Perry on 11/04/2024. (KRZ) [Transferred from Missouri Eastern on 2/10/2025.] | |
| Thursday, October 31, 2024 | ||
| 36 | 36
18
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MEMORANDUM in Support of Motion re34 MOTION to Dismiss Case or Transfer Under the First-Filed Rule filed by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC.(Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Exhibit 1 - Excerpt of Factual and Procedural Background,
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Att: 2
Exhibit 2 - Colo Dismissal,
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Att: 3
Exhibit 3 - Md Dismissal,
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Att: 4
Exhibit 4 - 10 7-2024 Email Exchange,
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Att: 5
Exhibit 5 - 10 8-2024 Email Exchange,
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Att: 6
Exhibit 6 - Okla Lawsuit Answers,
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Att: 7
Exhibit 7 - Okla Lawsuit Disc Reqs,
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Att: 8
Exhibit 8 - CarShield MTD Reply,
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Att: 9
Exhibit 9 - CarShield Supp MTD Reply
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| 35 | 35
MOTION for Leave to File Over Length Memorandum by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| 34 | 34
MOTION to Dismiss Case or Transfer Under the First-Filed Rule by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| Thursday, October 10, 2024 | ||
| 33 | 33
2
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SCHEDULING ORDER: IT IS HEREBY ORDERED that defendants shall have to October 31, 2024, to answer or otherwise file a motion directed to plaintiff's First Amended Complaint. In the event defendants file a motion, plaintiff's opposition must be filed within fourteen (14) days of the motion, or November 14, 2024, whichever is later. Any reply brief may be filed within ten (10) days of the opposition, or November 25, 2024, whichever is later. IT IS FURTHER ORDERED that, except for the limited purpose of defendants' filing an answer or a motion directed to the First Amended Complaint and briefing thereon, this case remains STAYED. Signed by Sr. District Judge Catherine D. Perry on 10/10/2024. (KEK) [Transferred from Missouri Eastern on 2/10/2025.]
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| Tuesday, October 08, 2024 | ||
| 32 | 32
STATUS REPORT CORRECTED Joint Status Report by NRRM, LLC.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Exhibit A - Amended Opinion and Order (Case No. 23-436 NDOK)
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| 31 | 31
STATUS REPORT Joint Status Report by NRRM, LLC. (Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| 30 | 30
27
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AMENDED COMPLAINT against defendant Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC,Terminating John Doe Amendment to1 Complaint, , filed by NRRM, LLC. Related document:1 Complaint, filed by Consumeraffairs.com Holdings, LLC, ConsumerAffairs.com Holdings, LLC, NRRM, LLC.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| Monday, February 05, 2024 | ||
| 29 | 29
NOTICE of Change of Address filed by David P. Niemeier. (Niemeier, David) Address was updated in CMECF (CMC). [Transferred from Missouri Eastern on 2/10/2025.]
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| Monday, December 11, 2023 | ||
| 28 | 28
RESPONSE TO ORDER TO SHOW CAUSE re18 Order to Show Cause, by Plaintiff NRRM, LLC filed by Plaintiff NRRM, LLC. (KEK) [Transferred from Missouri Eastern on 2/10/2025.]
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| 27 | 27
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pgs
MEMORANDUM AND ORDER: IT IS HEREBY ORDERED that plaintiff NRRM, LLC's Motion for Leave to File Response to Order to Show Cause Out of Time25 is GRANTED, and the Clerk of Court shall docket NRRM's Response (ECF 25-1) forthwith. To the extent NRRM asks that I vacate my Order staying this case in its entirety, that request is DENIED. IT IS FURTHER ORDERED that the Motion to Appear Pro Hac Vice by attorney Barbara M. Moschovidis26 is GRANTED. [SEE ORDER FOR FULL DETAILS] Signed by Sr. District Judge Catherine D. Perry on 12/11/2023. (KEK) [Transferred from Missouri Eastern on 2/10/2025.]
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| Friday, December 08, 2023 | ||
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MOTION for Leave to Appear Pro Hac Vice Barbara M. Moschovidis. The Certificate of Good Standing was attached.(Filing fee $150 receipt number AMOEDC-10316639) by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Moschovidis, Barbara) [Transferred from Missouri Eastern on 2/10/2025.]
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| Thursday, December 07, 2023 | ||
| 25 | 25
Emergency MOTION for Leave to File a Response to Show Cause Out of Time by Plaintiff NRRM, LLC.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Exhibit Plaintiff Response
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ORDER STAYING CASE...IT IS HEREBY ORDERED that defendants' Motion for Immediate Stay and to Dismiss, Transfer, or Stay Under the First-Filed Rule [15 ] is GRANTED to the extent defendants seek to stay this action during the pendency of the motion to dismiss or to transfer that is presently before the United States District Court, Northern District of Oklahoma, in a related case. In all other respects, defendants motion is DENIED without prejudice. IT IS FURTHER ORDERED that this action is STAYED pending the district court's decision in Consumers Unified, LLC, et al. v, NRRM, LLC, et al., Case No. 4:23CV436 JFJ (N.D. Okla.), on the motion to dismiss or transfer now pending in that case. The parties shall file a joint status report within five (5) days of the district court's decision on the motion. IT IS FURTHER ORDERED that defendants' Motion for Status Conference [17 ] on pending motions and briefing deadlines is DENIED without prejudice. Signed by Sr. District Judge Catherine D. Perry on 12/7/2023. (NEP) [Transferred from Missouri Eastern on 2/10/2025.]
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| 23 | 23
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MEMORANDUM re18 Order to Show Cause,, by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| 22 | 22
ENTRY of Appearance by Craig A Fitzgerald for Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Fitzgerald, Craig) [Transferred from Missouri Eastern on 2/10/2025.]
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| Wednesday, December 06, 2023 | ||
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NOTICE of Filing Exhibit with the Clerk's Office in paper format by Plaintiff NRRM, LLC re6 MOTION for Preliminary Injunction . 1 CD received and maintained in the Clerk's Office. (KEK) [Transferred from Missouri Eastern on 2/10/2025.]
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| 20 | 20 Docket Text ORDER: Re:19 MOTION for Leave to Appear Pro Hac Vice Craig Alan Fitzgerald. The Certificate of Good Standing was attached.(Filing fee $150 receipt number AMOEDC-10307879) by Defendant Consumers Unified, LLC, Consumeraffairs.com Holdings, LLC, Consumers United Insurance Agency, LLC. (Fitzgerald, Craig) Modified on 12/6/2023 (CBL). filed by Consumeraffairs.com Holdings, LLC, ConsumerAffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC; ORDERED GRANTED. Signed by Sr. District Judge Catherine D. Perry on 12/6/2023. (KEK) [Transferred from Missouri Eastern on 2/10/2025.] | |
| Tuesday, December 05, 2023 | ||
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MOTION for Leave to Appear Pro Hac Vice Craig Alan Fitzgerald. The Certificate of Good Standing was attached.(Filing fee $150 receipt number AMOEDC-10307879) by Defendant Consumers Unified, LLC, Consumeraffairs.com Holdings, LLC, Consumers United Insurance Agency, LLC. (Fitzgerald, Craig) Modified on 12/6/2023 (CBL). [Transferred from Missouri Eastern on 2/10/2025.]
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ORDER TO SHOW CAUSE: IT IS HEREBY ORDERED that plaintiff NRRM, LLC, shall show cause not later than Thursday, December 7, 2023, at 12:00 noon CST why this action should not be immediately stayed for the reasons stated in defendants' Motion for Immediate Stay, etc. (ECF 16), and particularly during the pendency of the motion to dismiss or to transfer that is presently before the United States District Court, Northern District of Oklahoma, in a related case. Defendants may file a reply not later than Friday, December 8, 2023, at 10:00 a.m. CST. Show Cause Response due by 12/7/2023. Signed by Sr. District Judge Catherine D. Perry on 12/5/2023. (KEK) [Transferred from Missouri Eastern on 2/10/2025.]
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MOTION for Hearing by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| 16 | 16
16
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MEMORANDUM in Support of Motion re15 MOTION to Stay and to Dismiss, Transfer, or Stay Under the First-Filed Rule and Request for Expedited Consideration filed by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC.(Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Exhibit 1 - Okla Lawsuit First Am Compl,
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Att: 2
Exhibit 2 - Carchex Email Chain,
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Att: 3
Exhibit 3 - CarShield HomeSafe Email Chain,
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Att: 4
Exhibit 4 - 9-25-23 Email Chain,
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Att: 5
Exhibit 5 - 10-4-23 Demand Letter,
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Att: 6
Exhibit 6 - CarShield HomeSafe Termination Notice,
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Att: 7
Exhibit 7 - Carchex Termination Notice,
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Att: 8
Exhibit 8 - Colo Lawsuit Compl,
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Att: 9
Exhibit 9 - Okla Lawsuit Mot to Dismiss,
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Att: 10
Exhibit 10 - Resp to Okla Mot to Dismiss,
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Att: 11
Exhibit 11 - Okla Lawsuit Docket Sheet,
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Att: 12
Exhibit 12 - Colo Lawsuit Docket Sheet,
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Att: 13
Exhibit 13 - gowizardcom Compl,
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Att: 14
Exhibit 14 - gowizardcom Docket Sheet,
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Att: 15
Exhibit 15 - Bing Search Results
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| 15 | 15
MOTION to Stay and to Dismiss, Transfer, or Stay Under the First-Filed Rule and Request for Expedited Consideration by Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| 14 | 14
DISCLOSURE STATEMENT by Consumers Unified Insurance Agency LLC, Consumers Unified, LLC.. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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DISCLOSURE STATEMENT by Consumeraffairs.com Holdings, LLC. No corporate parents or affiliates identified. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| 12 | 12
DISCLOSURE STATEMENT by Consumers Unified, LLC, ConsumerAffairs.com Holdings, LLC.. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| 11 | 11
ENTRY of Appearance by David P. Niemeier for Defendants Consumeraffairs.com Holdings, LLC, Consumers Unified Insurance Agency LLC, Consumers Unified, LLC. (Niemeier, David) [Transferred from Missouri Eastern on 2/10/2025.]
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| Thursday, November 30, 2023 | ||
| 10 | 10 Docket Text ORDER: Re:9 MOTION for Leave to File in Excess of 15 pages by Plaintiff NRRM, LLC. (Kass, Jeffrey) filed by NRRM, LLC ; ORDERED GRANTED. SO ORDERED. Signed by Sr. District Judge Catherine D. Perry on 11/30/2023. (ANR) [Transferred from Missouri Eastern on 2/10/2025.] | |
| Wednesday, November 29, 2023 | ||
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MOTION for Leave to File in Excess of 15 pages by Plaintiff NRRM, LLC. (Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| Tuesday, November 28, 2023 | ||
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NOTICE of Filing Exhibit with the Clerk's Office in paper format by Plaintiff NRRM, LLC re6 MOTION for Preliminary Injunction ,7 Memorandum in Support of Motion,, (Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| 7 | 7
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MEMORANDUM in Support of Motion re6 MOTION for Preliminary Injunction Pursuant to Rule 65 filed by Plaintiff NRRM, LLC.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Exhibit Exhibit A-Consumeraffairs Advertisements,
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Att: 2
Exhibit Exhibit B-Website Emails and Texts,
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Att: 3
Exhibit Exhibit C-Declaration of Nick Hamilton,
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Att: 4
Exhibit Exhibit D-Declaration of Phil McCall,
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Att: 5
Exhibit Exhibit E-Termination,
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Att: 6
Exhibit Exhibit F-Cease and Desist Letter,
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Att: 7
Exhibit Exhibit G-FCC Article,
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Att: 8
Exhibit Exhibit H-FTC Article
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| 6 | 6
MOTION for Preliminary Injunction by Plaintiff NRRM, LLC. (Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| Tuesday, October 24, 2023 | ||
| 5 | 5
REPORT to Commissioner of filing or determination of an action regarding trademark. (JBH) [Transferred from Missouri Eastern on 2/10/2025.]
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| 4 | 4
WAIVER OF SERVICE Returned Executed filed by NRRM, LLC Consumeraffairs.com Holdings, LLC waiver signed on 10/24/2023, answer due 12/26/2023; Consumers Unified Insurance Agency LLC waiver signed on 10/24/2023, answer due 12/26/2023; Consumers Unified, LLC waiver signed on 10/24/2023, answer due 12/26/2023.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Waiver of Service Consumeraffairs.com,
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Att: 2
Waiver of Service Consumers Unified Insurance
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| 3 | 3
DISCLOSURE STATEMENT by NRRM, LLC. No corporate parents or affiliates identified. (Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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| 2 | 2 NOTICE of Filing Deficiency. In accordance with Eastern District of Missouri Local Rules and the Case Management/Electronic Case Filing (CM/ECF) Procedures Manual, a filing deficiency has been identified as follows: Notice of Process Server form not filed and a Summons not filed. This deficiency must be filed in the case record immediately. (JBH) [Transferred from Missouri Eastern on 2/10/2025.] | |
| Case Opening Notification. Judge Assigned: Honorable Catherine D. Perry. 3 Waiver(s) of Service issued. Pursuant to Local Rule 2.09, every nongovernmental corporate party or nongovernmental corporation that seeks to intervene in any case, and every party or intervenor in an action in which jurisdiction is based upon diversity, must file a Disclosure Statement immediately upon entering its appearance in the case. Please complete and file the certificate as soon as possible.[LINK:(moed-0001.pdf)] . (JBH) [Transferred from Missouri Eastern on 2/10/2025.] | ||
| Monday, October 23, 2023 | ||
| 1 | 1
18
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COMPLAINT against defendant d/b/a Consumeraffair Consumers Unified LLC with receipt number AMOEDC-10229836, in the amount of $402 Jury Demand,, filed by NRRM, LLC, d/b/a Consumeraffair Consumers Unified LLC.(Kass, Jeffrey) [Transferred from Missouri Eastern on 2/10/2025.]
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Att: 1
Civil Cover Sheet Civil Cover Sheet,
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Att: 2
Original Filing Form Original Filing Form
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