2022-cv-02952

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 402, receipt number AILNDC-19536207.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Volkswagen Group of America, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Volkswagen Group of America, Inc.

Notice of Claims Involving Trademarks by Volkswagen Group of America, Inc.

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Allyson M. Martin

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Gary Feinerman. Designated as Magistrate Judge the Honorable David Weisman. Case assignment: Random assignment.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Gary Feinerman:Motion for leave to file under seal [3] is granted.Mailed notice.

MINUTE entry before the Honorable Gary Feinerman: Status hearing set for 6/23/2022 at 9:00 a.m. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MOTION by Plaintiff Volkswagen Group of America, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for temporary restraining order 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Dana A. Cizmadia regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Exhibit 3 - Parts 1-8 regarding declaration 18

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

(Exhibit 3-8)

MOTION by Plaintiff Volkswagen Group of America, Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Gary Feinerman:Motions 15 and 20 are entered and continued to 6/23/2022 at 9:00 a.m. Attorneys/Parties should appear for the 6/23/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Mailed notice.

MINUTE entry before the Honorable Gary Feinerman:Status hearing held and continued to 7/7/2022 at 9:00 a.m. Motion hearing held. For the reasons stated on the record, Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 15 and Plaintiff's motion for electronic service of process 20 are granted. Enter sealed TRO order. Attorneys/Parties should appear for the 7/7/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 10,000 posted by Volkswagen Group of America, Inc. (document not imaged)

MOTION by Plaintiff Volkswagen Group of America, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Volkswagen Group of America, Inc. in support of extension of time 27

(Declaration of Allyson M. Martin)

MINUTE entry before the Honorable Gary Feinerman:Motion for extension of time 27 is granted. The TRO 25 is extended to 7/21/2022 at Noon. The status hearing set for 7/7/2022 24 is stricken and re-set for 7/21/2022 at 9:00 a.m. Attorneys/Parties should appear for the 7/21/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MOTION by Plaintiff Volkswagen Group of America, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for preliminary injunction[30]

Declaration of Allyson M. Martin

Exhibit 1

SUMMONS Returned Executed by Volkswagen Group of America, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/18/2022, answer due 8/8/2022.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Gary Feinerman:Motion for preliminary injunction [30] is entered and continued to 7/21/2022 at 9:00 a.m. Attorneys/Parties should appear for the 7/21/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MINUTE entry before the Honorable Gary Feinerman:Status hearing held and continued to 9/13/2022 at 9:00 a.m. Motion hearing held. For the reasons stated on the record, Plaintiff's motion for entry of preliminary injunction [30] is granted. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain, Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the Court's website at www.ilnd.uscourts.gov/instructions. Attorneys/Parties should appear for the 9/13/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Gary Feinerman on 7/21/2022.Mailed notice.

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NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to a certain Defendant

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to a certain Defendant

MOTION by Plaintiff Volkswagen Group of America, Inc. for entry of default, MOTION by Plaintiff Volkswagen Group of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for entry of default, motion for default judgment[42]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

MINUTE entry before the Honorable Gary Feinerman:Motion for entry of default and default judgment 42 is entered and continued to 9/13/2022 at 9:00 a.m. Attorneys/Parties should appear for the 9/13/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Mailed notice.

MINUTE entry before the Honorable Gary Feinerman:The status/motion hearing set for 9/13/2022 at 9:00 a.m. [34][45] is re-set for 9:15 a.m. TIME CHANGE ONLY. Attorneys/Parties should appear for the 9/13/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Mailed notice.

MINUTE entry before the Honorable Gary Feinerman:Status hearing held and continued to 9/28/2022 at 9:00 a.m. Motion hearing held. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 42 is granted in part (as to the Rule 55(a) entry of default) and entered and continued in part (as to the Rule 55(b) default judgment). Enter Rule 55(a) default order as to certain defendants. If any defendant wishes to oppose Plaintiff's Rule 55(b) motion for default judgment, that defendant should file a written opposition by 9/26/2022 or appear at the 9/28/2022 hearing; otherwise, the court will rule on the Rule 55(b) motion on the papers at the 9/28/2022 hearing. Plaintiffs shall electronically serve a copy of this order on all remaining defendants. Attorneys/Parties should appear for the 9/28/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendants

MINUTE entry before the Honorable Gary Feinerman:Status hearing held. For the reasons stated on the record, Plaintiff's motion for default judgment [42] is granted. Enter order. Enter judgment order. Civil case closed.Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Gary Feinerman on 9/28/2022.Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Gary Feinerman on 9/28/2022.Mailed notice.

MAILED trademark report with certified copy of final judgment order to Patent Trademark Office, Alexandria VA

NOTICE of withdrawal of surety bond 26 in the amount of $ 10,000 posted by Volkswagen Group of America, Inc. by John Summerfield. (Received for docketing on 11/7/2022) Modified on 11/8/2022.

FULL SATISFACTION of Judgment regarding entered judgment 50 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding entered judgment[50] in the amount of $200,000 as to certain defendant