2022-cv-03002

2022-cv-03002 General Motors LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :6/8/2022
Court :Northen District of Illinois
Law FirmGBC

#

Date

Document

1

June 8, 2022

COMPLAINT filed by General Motors LLC; Filing fee $ 402, receipt number AILNDC-19544323.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

2

June 8, 2022

EXHIBIT by Plaintiff General Motors LLC Schedule A regarding complaint 1 Modified on 7/13/2022.

3

June 8, 2022

MOTION by Plaintiff General Motors LLC for leave to file under seal

4

June 8, 2022

CIVIL Cover Sheet

5

June 8, 2022

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by General Motors LLC

6

June 8, 2022

Notice of Claims Involving Trademarks by General Motors LLC

7

June 8, 2022

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin R. Gaudio

8

June 8, 2022

ATTORNEY Appearance for Plaintiff General Motors LLC by Amy Crout Ziegler

9

June 8, 2022

ATTORNEY Appearance for Plaintiff General Motors LLC by Jake Michael Christensen

10

June 8, 2022

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin Tyler Joseph

CASE ASSIGNED to the Honorable Ronald A. Guzman. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment.

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.

11

June 9, 2022

MAILED trademark report to Patent Trademark Office, Alexandria VA

12

June 9, 2022

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

13

June 14, 2022

MOTION by Plaintiff General Motors LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

14

June 14, 2022

MEMORANDUM by General Motors LLC in support of motion for temporary restraining order 13

15

June 14, 2022

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

16

June 14, 2022

DECLARATION of Andrea Ankawi regarding memorandum in support of motion 14

(Exhibit 1)

17

June 14, 2022

EXHIBIT by Plaintiff General Motors LLC Exhibit 2 - Parts 1 - 6 regarding declaration 16 Modified on 7/13/2022.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

(Exhibit 2-6)

18

June 14, 2022

MOTION by Plaintiff General Motors LLCfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

19

June 14, 2022

MEMORANDUM by General Motors LLC in support of motion for miscellaneous relief 18

20

June 14, 2022

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

21

June 14, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Plaintiff's motions for leave to file under seal 3 and electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13 is granted. Mailed notice.

22

June 14, 2022

TEMPORARY Restraining Order. Signed by the Honorable Ronald A. Guzman on 6/14/2022. Mailed notice. Modified on 7/13/2022.

23

June 15, 2022

SURETY BOND in the amount of $ 10,000 posted by General Motors LLC. (Document not imaged)

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

24

June 24, 2022

MOTION by Plaintiff General Motors LLC for extension of time of Temporary Restraining Order

25

June 24, 2022

MEMORANDUM by General Motors LLC in support of extension of time 24

(Declaration of Jake M. Christensen)

26

June 24, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Plaintiff's ex parte motion to extend the temporary restraining order 24 by a period of fourteen (14) days until 7/12/2022 is granted. Mailed notice.

27

June 24, 2022

EXTENSION OF TEMPORARY RESTRAINING ORDER. Signed by the Honorable Ronald A. Guzman on 6/24/2022. Mailed notice.

28

June 28, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

29

July 1, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

30

July 6, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

31

July 8, 2022

MOTION by Plaintiff General Motors LLC for preliminary injunction, MOTION by Plaintiff General Motors LLC for extension of time of Temporary Restraining Order

(Exhibit A)

32

July 8, 2022

MEMORANDUM by General Motors LLC in support of motion for preliminary injunction, extension of time 31

Declaration of Jake M. Christensen

(Exhibit 1)

33

July 8, 2022

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/8/2022, answer due 7/29/2022.

Declaration of Justin T. Joseph

(Exhibit A)

34

July 8, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Motion hearing set for 7/12/2022 at 9:45 a.m. for Plaintiff's motion for entry of a preliminary injunction 31. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. 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.

35

July 12, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Telephonic motion hearing held on 7/12/2022 regarding motion for preliminary injunction 31. Motion for preliminary injunction 31 is granted. Enter preliminary injunction order. Status hearing set for 9/8/2022 at 10:15 a.m. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. 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. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm 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 located at https://www.ilnd.uscourts.gov /_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

36

July 12, 2022

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Ronald A. Guzman on 7/12/2022. Mailed notice.

NEW PARTIES: Aa sweety 666 Store, AEING Official Store, AK01 Store, ALTA ACCESSORIES Store, B Emblem Store, baidun Store, BSTGS Auto Supplies Factory Store, burnthebeans Store, caoxiangjuan, Car decoration industry Store, CAR LOGOS Store, China Discount Factory Store, cuichenwei0168, Decorate our House Store, Driver Wardrobe Store, EDG Store, EK-shubuzhi Store, Fayshow88 Store, Fidelity Store, Gaopin Store, Global Personalized Trend Shoe Store, Good Brother Car Clothing and Shoe Store, High quality auto parts 2009, High-quality Car Shoe Store, HOUDE Store, huamian signs Store, Hyperreal Store, JJLL Store, lancedy Store, LightConer Store, liminhao fashion, Linluu6 Store, liubingbing8321, LoveCars Store, maxiaoqin3276, Max-Modified Car Accessories Store, N-FLY Flags Store, niceflag Store, PAKER-SHARK Store, Riders Wardrobe Store, Ruizhong Auto Parts Co., Shop1100085116 Store, Shop1100085235 Store, Shop1100218748 Store, Shop1100221320 Store, Shop3189069 Store, Shop4540024 Store, Shop5068516 Store, Shop5365309 Store, Shop5587073 Store, Shop5607298 Store, Shop5967037 Store, Shop900246429 Store, Shop910335050 Store, Shop910361314 Store, Shop911134268 Store, Shop911137095 Store, Shop911391240 Store, Shop911899999 Store Store, shop912168537 Store, Shop912626290 Store, shuaigirl knight supplies, sports bra store Store, SuperQirui Store, Tailor-made Store, Tejanq Store, thevideobarn Store, Tin decorative painting Store, wall sign 0002 Store, wangruiting875465, wangying3462, weihaojie7506, wn1119, XLSYDLSD Global Store, xummman, YIN ZI Store, yitai Store, zhubaolai39283, 111, Amare-us, Aomeika, ASIALI, Auto NewLife, AXUS751AADIBG, ayongShop, Azxc, Bftfyht, CARIZI, ColorSays, Day UP, DJYQFC, Doart Direct-US, DriveSporty, Drmkfly, EmbsPro, fcyyds, FearlessMu, Fsdva, Ganzai Store, Good forcar, Guangzhou Jiamaoxin Auto Accessories Co., Guangzhou Nansha Liangao Trading Co., guangzhoushixiaomaomaoyiyouxiangongsi, HAOFENG, hbh-global, HBXA, hefeishiliejiaodianzishangwuyouxiangongsi, hgfddf, JDopption, Jinan taifenggu e-commerce Co., jokmoest, JqdXbpL, kaisekunshangmaoyouxiangongsi, LANJAY, liansen1967, mcsygzs, Mesport, mzgsjp, naisimi, PENTAGON TOOLS, Peta Meng, qinhuangdaomutaishengwukejiyouxiangongsi, RAYSPEED, sailuobaihuoshanghang, SCYYDS, SenSiJie, SERY, SFOALN, Shengbang, shenzhenshizhanyangmaoyiyouxiangongsi, Soondar Direct, sunday1122, sunyidedian, tai66, Tolohas, TOZOTOZO-US, USAToysGifts, Vekwena, Weekeight, xinxiangshigaoxinquhaohaishangmaodian, yadian shop, YHH.MMO, Yisii, Yousthka, 1212111, AELA100, Amazingui, Amecoore, aoxinhui, Auteal, Boyuer, Bruce Jason, CarDecorationKingdom and Carfiltery added to case caption.

37

July 22, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

38

July 25, 2022

ATTORNEY Appearance for Defendant Guangzhou Jiamaoxin Auto Accessories Co. by Ruoting Men

39

July 25, 2022

ATTORNEY Appearance for Defendant Guangzhou Jiamaoxin Auto Accessories Co. by Tianyu Ju

40

July 26, 2022

MOTION by Defendant Guangzhou Jiamaoxin Auto Accessories Co. for extension of time First, Unopposed, extend to August 8, 2022

41

July 27, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Counsel Ruoting Men and Tianyu Ju have filed appearances for a client listed as "jiamaoxin." 38 39 It is the Court's understanding that "jiamaoxin" may refer to the operating name of an online e-commerce store or seller. A plaintiff alleging a violation of its intellectual property rights is permitted to proceed against a pseudonym (like a website or operating name of an e-commerce store or seller) for the actual entity alleged to have violated its rights because plaintiffs allegedly being damaged by internet stores have no way of ascertaining the legally recognized owners and so would otherwise have no legal mechanism for vindicating their rights. The Court requires plaintiffs to amend their pleadings to reflect the true names of the owners of such stores whenever they are able to do so. Counsel for "jiamaoxin" has no such need for the use of a pseudonym, as counsel is aware of the client's identity. Given the foregoing, the appearances 38 39 are stricken, as is the corresponding motion for extension of time 40. Counsel are given leave to file amended appearances to reflect their client's identity--whether an individual, corporation, or other legally recognized entity--within seven days of the entry of this order. After they file proper appearances, they may renew the motion for extension of time. Mailed notice.

42

Aug. 1, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

43

Aug. 5, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

44

Aug. 8, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

45

Aug. 15, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to a Certain Defendant

46

Aug. 15, 2022

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all Defendants

(Exhibit A)

47

Aug. 15, 2022

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment 46

(Exhibit 1)

48

Aug. 15, 2022

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 47

(Exhibit 1)

49

Aug. 16, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Motion hearing set for 8/24/2022 at 10:15 a.m. as to Plaintiff's motion for entry of default and default judgment 46. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. 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.

50

Aug. 19, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

51

Aug. 19, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

52

Aug. 24, 2022

ATTORNEY Appearance for Defendant Guangzhou Jiamaoxin Auto Accessories Co. by Tianyu Ju

53

Aug. 24, 2022

ATTORNEY Appearance for Defendant Guangzhou Jiamaoxin Auto Accessories Co. by Ruoting Men

54

Aug. 24, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Telephonic motion hearing held on 8/24/2022 regarding motion for entry of default and default judgment 46 is granted as to all defendant's with the exception of Defendant Guangzhou Jiamaoxin Auto Accessories Co. Enter default judgment order. As stated in open court, plaintiff's motion for voluntary dismissal as to defendant Guangzhou Jiamaoxin Auto Accessories Co. is due no later than 9/7/2022. Status hearing set for 9/7/2022 at 10:00 a.m. The status hearing will be cancelled if a proper notice of voluntary dismissal is filed before the status hearing date as to the defendant. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. 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.

55

Aug. 24, 2022

DEFAULT JUDGMENT ORDER. Signed by the Honorable Ronald A. Guzman on 8/24/2022. Mailed notice.

56

Aug. 29, 2022

FULL SATISFACTION of Judgment regarding order 55 in the amount of $500,000 as to certain defendants

57

Aug. 29, 2022

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

58

Aug. 30, 2022

MINUTE entry before the Honorable Ronald A. Guzman: Plaintiff's notice of voluntary dismissal as to Guangzhou Jiamaoxin Auto Accessories Co., Ltd. 57 effects a dismissal of the only remaining defendant to this case. See Nelson v. Napolitano, 657 F.3d 586, 587-88 (7th Cir. 2011). Accordingly, this civil case is terminated. All future dates are stricken. Mailed notice.

59

Sept. 30, 2022

FULL SATISFACTION of Judgment regarding order 55 in the amount of $500,000 as to certain defendants

60

June 22, 2023

FULL SATISFACTION of Judgment regarding order 55 in the amount of $500,000 as to certain defendants

61

July 13, 2023

FULL SATISFACTION of Judgment regarding order 55 in the amount of $500,000 as to certain defendant

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