UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 

AUSTIN DIVISION 

UNITED STATES OF AMERICA, 

 Plaintiff, 

v. 

JOHN DOE, a/k/a 

“coronavirusmedicalkit.com,” 

 Defendant. 

Case No. A-20-CV-306 

[PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO 

SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE 

This matter comes before the Court on the United States’ Motion for a Temporary 

Restraining Order and Order to Show Cause Why a Preliminary Injunction Should Not Issue (the 

“Motion”). Upon consideration of the Motion pursuant to 18 U.S.C. § 1345, the Complaint for 

Temporary Restraining Order and Preliminary and Permanent Injunctions (the “Complaint”), and 

the Declaration of Supervisory Special Agent Jordan T. Loyd, the Court finds that: 

1. This Court has jurisdiction over the subject matter of this case, there is good cause 

to believe that it will have jurisdiction over all the parties hereto, and venue in this district is 

proper. 

2. There is probable cause to believe that Defendant Doe is violating and, unless 

enjoined, will continue to violate 18 U.S.C. § 1343. 

3. The domain name “coronavirusmedicalkit.com,” which is registered by 

NameCheap, Inc., 4600 East Washington Street Suite 305. Phoenix, AZ 85034, is being used as 

an instrumentality of Defendant’s crimes. 

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4. Injunctive relief to protect the public interest is expressly authorized by 18 U.S.C. 

§ 1345. As such, neither a specific finding of irreparable harm, a showing of the inadequacy of 

other remedies at law, nor a balancing of the parties’ interests is necessary prior to the issuance 

of a temporary restraining order. 

5. Even though a showing of irreparable harm is not necessary under Section 1345 

in order to obtain injunctive relief, the Court has found that permitting Defendant to continue to 

perpetrate the alleged wire fraud would constitute irreparable harm. 

6. The statutory conditions for granting a permanent or temporary injunction or 

restraining order under 18 U.S.C. § 1345 are therefore met. 

7. Defendant’s violations 18 U.S.C. § 1343 will continue unless a temporary 

restraining order is issued. 

THEREFORE, IT IS HEREBY ORDERED that, pursuant to 18 U.S.C. § 1345, the 

United States’ Motion for Temporary Restraining Order and Order to Show Cause Why a 

Preliminary Injunction Should Not Issue is GRANTED. 

IT IS FURTHER ORDERED that Defendant Doe, his or her agents, officers, and 

employees, and all other persons and entities in active concert or participation with them, are 

temporarily restrained, pending a hearing on the United States’ application for a preliminary 

injunction, from (A) committing wire fraud, as defined by 18 U.S.C. § 1343; (B) maintaining and 

doing business through the use of the domain “coronavirusmedicalkit.com;” (C) destroying 

business records related to Defendant’s business, financial, or accounting operations; and 

(D) taking actions designed to interfere with any additional Court orders regarding the domain 

“coronavirusmedicalkit.com.” 

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IT IS FURTHER ORDERED that NameCheap, Inc., upon receiving notice of this Order, 

shall take such steps as are necessary to prevent the public from accessing Defendant Doe’s 

“coronavirusmedicalkit.com” website, including by changing the Domain Name System (DNS) 

record to remove any named server and leave it blank, and shall impose a registry lock on the 

“coronavirusmedicalkit.com” domain name and lock any accounts associated with the registrant 

of the domain name to prevent any change, transfer, or deletion of such domain name or 

accounts without the previous authorization of this Court. 

IT IS FURTHER ORDERED that NameCheap, Inc., upon receiving notice of this Order, 

shall serve a copy of this Order to Defendant Doe by certified mail to the mailing address and/or 

by email to the email address associated with the registrant of the “coronavirusmedicalkit.com” 

domain name as reflected in its files, and shall promptly notify counsel for the United States in 

writing once such service has been accomplished. 

IT IS FURTHER ORDERED that this temporary restraining order shall remain in force 

until the _____ day of _______________, 2020, or until such later date as may be extended by 

the Court or agreed upon by the parties. Pursuant to Rule 65(d) of the Federal Rules of Civil 

Procedure, Defendants shall appear before this Court on _______________ _____, 2020, at 

___________, for a hearing to show cause, if there is any, why the preliminary injunction 

requested by the United States should not be granted. Defendant shall serve and file any 

response to the application for a preliminary injunction on or before __________ _____, 2020, 

and the United States shall serve and file any reply on or before __________ _____, 2020. 

 

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4th April March 31 10:00am March 27 March 30

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Pursuant to 18 U.S.C. § 1345(a)(3) and Rule 65(c) of the Federal Rules of Civil 

Procedure, the United States shall not be required to post security for this action. 

SO ORDERED, this the _____ day of _______________, 2020. 

___________________________________ 

UNITED STATES DISTRICT JUDGE 

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22nd March

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