2025-cv-21754

COMPLAINT against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18374592, filed by FCA US LLC.

Exhibit 1

(Civil Cover Sheet)

Clerk's Notice of Judge Assignment to Judge Roy K. Altman. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Enjolique A. Lett is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

(Complaint w/ Exhibits) (caw)

ORDER IN CASES WITH MULTIPLE DEFENDANTS. Signed by Judge Roy K. Altman on 4/18/2025. See attached document for full details.

Plaintiff's Corporate Disclosure Statement by FCA US LLC identifying Corporate Parent Stellantis N.V. for FCA US LLC

MOTION to Seal per Local Rule 5.4 by FCA US LLC.

(Text of Proposed Order)

ORDER granting 6 Motion to File Under Seal. Signed by Judge Roy K. Altman on 4/23/2025. See attached document for full details.

Schedule A to the Complaint re DE# 7 Order on Motion to Seal by FCA US LLC. Modified to unseal on 5/12/2025 per DE#22.

Motion for Entry of Temporary Restraining Order and Preliminary Injunction, Including Temporary Injunction, Temporary Asset Restraint and Expedited Discovery by FCA US LLC.

Declaration of David Wokoun, Esq.

Declaration of Thomas Hipelius

Exhibit 1 to the Declaration of Thomas Hipelius

Exhibit 2 to the Declaration of Thomas Hipelius

(Text of Proposed Order) Added MOTION for Temporary Restraining Order, MOTION for Preliminary Injunction on 4/29/2025 (scn). Modified to unseal on 5/12/2025 per DE#22. (scn)

Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) by FCA US LLC.

Declaration of David Wokoun, Esq.

(Text of Proposed Order) Modified to unseal on 5/12/2025 per DE#22. (scn)

ORDER GRANTING PLAINTIFF'S EX PARTE 9 MOTION FOR ENTRY OF TEMPORARY RESTRAINING: Responses due by 5/13/2025. Replies due by 5/20/2025. Preliminary Injunction Hearing set for 5/27/2025 3:00 PM in Miami Division before Judge Roy K. Altman. Signed by Judge Roy K. Altman on 4/30/2025. (scn) Modified to unseal on 5/12/2025 per DE#22.

ORDER AUTHORIZING ELECTRONIC SERVICE OF PROCESS ON DEFENDANTS PURSUANT TO FED. R. CIV. P. 4(f)(3): Granting 10 Ex Parte Motion for Electronic Service of Process. Signed by Judge Roy K. Altman on 4/30/2025. (scn) Modified to unseal on 5/12/2025 per DE#22.

NOTICE of Filing Proposed Summons(es) by FCA US LLC

(Summon(s))

Summons Issued as to The Partnerships and Unincorporated Associations Identified on Schedule A.

BOND on Injunction in the amount of $10,000 posted by FCA US LLC. Approved by DEPUTY CLERK 5/7/2025.

MOTION to Unseal Document by FCA US LLC. Responses due by 5/23/2025.

(Text of Proposed Order)

Notice of Entry of Parties Listed on 7 Order on Motion to Seal into CM/ECF. NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): BoldStitch Co., fuyangbeixiongshangmaoyouxiangongsi, gaoruidi2022, syingzhi, TSUNG, YICHUAN-Official, 0iahiul2, Accfuns, autoooparts, BTSWSTORE, funcarparts, Gabriauto, HUAN VEHICLES, landscape-plus, lihongyun0086, luoyi000096, Motoa_auto, nuanen_802, refitfullrange, switch-supplier, thefoxlover-auto, Todo-auto, A real mans wardrobe, BAOBANEOE, Boy Go, chenaihua, Chill Tee Co, Chuaii, Cirrinaa, Deepshop, DFRC, Dream big clothing two, Emilycup, HiHypermarket, Hobue, HYM tang, JAGGER AUTO, jdm collections, Keep Growing, maizishihao, Meyli, Pink whale, PTXLGJL, Stylu, T Blast, The Sartorialist, VERTICES HAT, YINHE decal, zhangTshirt, GenuineGoodsHub and GuangZhouYiWuShangMaoYouXianGongSi.

(Exhibit 1)

SUMMONS (Affidavit) Returned Executed on 1 Complaint with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by FCA US LLC. 0iahiul2 served on 5/9/2025, response/answer due 5/30/2025; A real mans wardrobe served on 5/9/2025, response/answer due 5/30/2025; Accfuns served on 5/9/2025, response/answer due 5/30/2025; BAOBANEOE served on 5/9/2025, response/answer due 5/30/2025; BTSWSTORE served on 5/9/2025, response/answer due 5/30/2025; BoldStitch Co. served on 5/9/2025, response/answer due 5/30/2025; Boy Go served on 5/9/2025, response/answer due 5/30/2025; Chill Tee Co served on 5/9/2025, response/answer due 5/30/2025; Chuaii served on 5/9/2025, response/answer due 5/30/2025; Cirrinaa served on 5/9/2025, response/answer due 5/30/2025; DFRC served on 5/9/2025, response/answer due 5/30/2025; Deepshop served on 5/9/2025, response/answer due 5/30/2025; Dream big clothing two served on 5/9/2025, response/answer due 5/30/2025; Emilycup served on 5/9/2025, response/answer due 5/30/2025; Gabriauto served on 5/9/2025, response/answer due 5/30/2025; GenuineGoodsHub served on 5/9/2025, response/answer due 5/30/2025; GuangZhouYiWuShangMaoYouXianGongSi served on 5/9/2025, response/answer due 5/30/2025; HUAN VEHICLES served on 5/9/2025, response/answer due 5/30/2025; HYM tang served on 5/9/2025, response/answer due 5/30/2025; HiHypermarket served on 5/9/2025, response/answer due 5/30/2025; Hobue served on 5/9/2025, response/answer due 5/30/2025; JAGGER AUTO served on 5/9/2025, response/answer due 5/30/2025; Keep Growing served on 5/9/2025, response/answer due 5/30/2025; Meyli served on 5/9/2025, response/answer due 5/30/2025; Motoa_auto served on 5/9/2025, response/answer due 5/30/2025; PTXLGJL served on 5/9/2025, response/answer due 5/30/2025; Pink whale served on 5/9/2025, response/answer due 5/30/2025; Stylu served on 5/9/2025, response/answer due 5/30/2025; T Blast served on 5/9/2025, response/answer due 5/30/2025; TSUNG served on 5/9/2025, response/answer due 5/30/2025; The Sartorialist served on 5/9/2025, response/answer due 5/30/2025; Todo-auto served on 5/9/2025, response/answer due 5/30/2025; VERTICES HAT served on 5/9/2025, response/answer due 5/30/2025; YICHUAN-Official served on 5/9/2025, response/answer due 5/30/2025; YINHE decal served on 5/9/2025, response/answer due 5/30/2025; autoooparts served on 5/9/2025, response/answer due 5/30/2025; chenaihua served on 5/9/2025, response/answer due 5/30/2025; funcarparts served on 5/9/2025, response/answer due 5/30/2025; fuyangbeixiongshangmaoyouxiangongsi served on 5/9/2025, response/answer due 5/30/2025; gaoruidi2022 served on 5/9/2025, response/answer due 5/30/2025; jdm collections served on 5/9/2025, response/answer due 5/30/2025; landscape-plus served on 5/9/2025, response/answer due 5/30/2025; lihongyun0086 served on 5/9/2025, response/answer due 5/30/2025; luoyi000096 served on 5/9/2025, response/answer due 5/30/2025; maizishihao served on 5/9/2025, response/answer due 5/30/2025; nuanen_802 served on 5/9/2025, response/answer due 5/30/2025; refitfullrange served on 5/9/2025, response/answer due 5/30/2025; switch-supplier served on 5/9/2025, response/answer due 5/30/2025; syingzhi served on 5/9/2025, response/answer due 5/30/2025; thefoxlover-auto served on 5/9/2025, response/answer due 5/30/2025; zhangTshirt served on 5/9/2025, response/answer due 5/30/2025.

(Exhibit A)

NOTICE of Compliance by FCA US LLC

(Exhibit A)

MOTION To Extend TRO by FCA US LLC.

(Text of Proposed Order)

ORDER Granting 16 Motion to Unseal. The Clerk is directed to UNSEAL this case and return all docket entries to the public record. Signed by Judge Roy K. Altman on 5/9/2025. See attached document for full details.

PAPERLESS ORDER granting 20 Motion to Extend Temporary Restraining Order ("TRO"). The TRO entered on April 30, 2025, see Order Granting Motion for TRO [ECF No. 11], shall remain in effect until May 28, 2025. Signed by Judge Roy K. Altman on 5/12/2025.

NOTICE of Compliance re 22 Order on Motion to Unseal. The Clerk has unsealed all documents in this case per order at DE#22.

NOTICE of Attorney Appearance by Diego Fernando Bobadilla on behalf of FCA US LLC. Attorney Diego Fernando Bobadilla added to party FCA US LLC(pty:pla).

NOTICE of Voluntary Dismissal as to a Certain Defendant by FCA US LLC

PAPERLESS Minute Entry for proceedings held before Judge Roy K. Altman. A preliminary injunction hearing was held on May 27, 2025. The preliminary injunction was GRANTED. A written order will follow. Total time in court: 0 hours, 2 minutes. Attorney Appearance(s): Diego Fernando Bobadilla, Court Reporter: Patricia Diaz, 305-523-5178 / Patricia_Diaz@flsd.uscourts.gov.

ORDER granting 9 Motion for Preliminary Injunction. Signed by Judge Roy K. Altman on 5/27/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants by FCA US LLC

PAPERLESS ORDER. On May 9, 2025, the Plaintiff served all of the Defendants listed on Schedule "A" of its Complaint. See Declaration of Service [ECF No. 18 ]. Federal Rule of Civil Procedure 12 provides that a defendant must serve an answer within 21 days after being served with the summons and complaint. The Defendants' responses to the Complaint, therefore, were due on May 30, 2025. That deadline has passed, and the Defendants haven't responded to the Complaint, requested an extension of time, or otherwise appeared in the case at all. See generally Docket. So, by June 9, 2025, the Plaintiff must do one of two things: either move for Clerk's Entry of Default to begin default final judgment procedures against all remaining Defendants or file a notice of voluntary dismissal. Signed by Judge Roy K. Altman on 6/3/2025.

NOTICE of Voluntary Dismissal as to Certain Defendants by FCA US LLC

MOTION for Extension of Time to file motion for clerk's entry of default or notice of voluntary dismissal as to Defendants Tsung and Accfuns re 29 Order, by FCA US LLC. Responses due by 6/20/2025.

(Exhibit Email Address List)

PAPERLESS ORDER granting 31 Motion for Extension of Time. The deadline to file a motion for Clerk's default against Defendants No. 5 and 8 shall be extended to June 29, 2025. The Clerk shall administratively CLOSE the case. Signed by Judge Roy K. Altman on 6/6/2025.

NOTICE of Voluntary Dismissal as to Certain Defendants by FCA US LLC

MOTION for Clerk's Entry of Default as to 0iahiul2, A real mans wardrobe, BAOBANEOE, BTSWSTORE, BoldStitch Co., Boy Go, Chill Tee Co, Chuaii, Cirrinaa, DFRC, Deepshop, Dream big clothing two, Emilycup, Gabriauto, GenuineGoodsHub, GuangZhouYiWuShangMaoYouXianGongSi, HUAN VEHICLES, HYM tang, HiHypermarket, Hobue, JAGGER AUTO, Keep Growing, Meyli, Motoa_auto, PTXLGJL, Pink whale, Stylu, T Blast, The Sartorialist, Todo-auto, VERTICES HAT, YICHUAN-Official, YINHE decal, chenaihua, funcarparts, fuyangbeixiongshangmaoyouxiangongsi, gaoruidi2022, jdm collections, lihongyun0086, luoyi000096, maizishihao, nuanen_802, syingzhi, zhangTshirt by FCA US LLC.

Exhibit 1

Exhibit A

Declaration of David Wokoun, Esq.

Clerk's Entry of Default as to The Partnerships and Unincorporated Associations Identified on Schedule A - Motions Terminated: 34 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 6/10/2025.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE. Therefore, the Court hereby ORDERS and ADJUDGES that the Plaintiff must file either a motion for default final judgment or a notice of joint liability by June 25, 2025. Administratively closing Case. Signed by Judge Roy K. Altman on 6/11/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to a Certain Defendant by FCA US LLC

NOTICE of Voluntary Dismissal as to Certain Defendants by FCA US LLC

NOTICE of Voluntary Dismissal as to Certain Defendants by FCA US LLC

MOTION for Default Judgment as to all Defendants by FCA US LLC.

Exhibit 1

Exhibit 2

Exhibit A

Text of Proposed Order

Text of Proposed Order

ORDER granting [40] Motion for Final Default Judgment. Signed by Judge Roy K. Altman on 7/8/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT in favor of FCA US LLC against BoldStitch Co.; in favor of FCA US LLC against fuyangbeixiongshangmaoyouxiangongsi; in favor of FCA US LLC against 0iahiul2; in favor of FCA US LLC against gaoruidi2022; in favor of FCA US LLC against BTSWSTORE; in favor of FCA US LLC against Gabriauto; in favor of FCA US LLC against HUAN VEHICLES; in favor of FCA US LLC against lihongyun0086; in favor of FCA US LLC against luoyi000096; in favor of FCA US LLC against Motoa_auto; in favor of FCA US LLC against Todo-auto; in favor of FCA US LLC against A real mans wardrobe; in favor of FCA US LLC against Chill Tee Co; in favor of FCA US LLC against Chuaii; in favor of FCA US LLC against Deepshop; in favor of FCA US LLC against DFRC; in favor of FCA US LLC against HiHypermarket; in favor of FCA US LLC against HYM tang; in favor of FCA US LLC against Keep Growing; in favor of FCA US LLC against maizishihao; in favor of FCA US LLC against Meyli; in favor of FCA US LLC against VERTICES HAT; in favor of FCA US LLC against YINHE decal; in favor of FCA US LLC against zhangTshirt; in favor of FCA US LLC against GenuineGoodsHub, PERMANENT INJUNCTION Signed by Judge Roy K. Altman on 7/8/2025. See attached document for full details.