2023-cv-03171

COMPLAINT filed by General Motors LLC; Filing fee $ 402, receipt number AILNDC-20657394.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff General Motors LLC Schedule A regarding complaint 1 Modified on 7/10/2023.

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

CIVIL Cover Sheet

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

Notice of Claims Involving Trademarks by General Motors LLC

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

ATTORNEY Appearance for Plaintiff General Motors LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff General Motors LLC by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff General Motors LLC by Rachel S Miller

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Text entry; no document attached.)

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. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

(Part 2)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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

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

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Andrea Ankawi regarding memorandum in support of motion 14

(Exhibit 1)

EXHIBIT by Plaintiff General Motors LLC Exhibit 2 - Parts 1 - 10 regarding declaration 16 Modified on 7/10/2023.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

Exhibit 2-8

Exhibit 2-9

(Exhibit 2-10)

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

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

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

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: 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. Plaintiff's motion for electronic service of process 18 and motion for leave to file under seal 3 are granted. Enter Sealed Temporary Restraining Order. Telephonic status hearing set for 6/23/23 at 9:00am. Parties should call 866-434-5269; access code 3751971. Mailed notice.

TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 6/8/2023. Mailed notice. Modified on 7/10/2023.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ 183,000 posted by General Motors LLC. (Document not Scanned)

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

MEMORANDUM by General Motors LLC in support of extension of time 23

(Declaration of Jake M. Christensen)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' motion for extension 23 is granted. Enter Order. Telephonic status hearing set for 6/23/23 is stricken. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 6/16/2023. Mailed notice.

MOTION by Plaintiff General Motors LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by General Motors LLC in support of motion for preliminary injunction 28

Declaration of Jake M. Christensen

(Exhibit 1)

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/5/2023, answer due 7/26/2023.

Declaration of Rachel S. Miller

(Exhibit A)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion for entry of a preliminary injunction 28 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff 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. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Telephonic status hearing set for 9/8/23 at 9:15am. Parties shall call 866-434-5269; access code 3751971. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Mary M. Rowland on 7/7/2023. Mailed notice.

NEW PARTIES: A2K77YE0R2DTD5, A2RV2L8EYMN6A6, A6I1TXW83O5E4, ACToy, AEIWZREO5C4GO, AICZHKW3V31XD, AJO9S3KTL3044, AlbertRy, anqinghuinushangmaoyouxiangongsi, AOWIFT, aunspace, AUTOFLYING, bianchunyubkeogo, BYB Co.,Ltd., chendedianpu, chendongjiang, chengxiyunsiqiao, DAFANYIXING, DianYu Store, DIAO&DIAN, dongshicheng, dsfsdiop, ENMOON Direct-JS, ewatdsg, fanzetao2223, FHKHGFGKH, FLFL, focom shop, Foshan Nanhai Pingyu Trade Co., Ltd, foshanshiliandongyamaoyiyouxiangongsi, FULAILA, GEEKER-US, GuLiNaEr.WuSiManUS, Guma63, haikoushililingfukejiyouxiangongsi, Hefengyuan, hh9288, huanglingxianlaiwanXiangheleguan, INDASLI-MAN77, jiajiafustore, jialufushangmaoxiaodian, jiaosonglin, Jikay, jiwenchishangmaoyouxi, Junruriyongpin, KEFULDA Allprettyall US, linadedianya, linhong1982, LiShaoHuiUS, Lishengjia, lixinxianqueqiaohuibaihuoyouxiangongsi, LuoXiangBao, maiertengjingpinxiaodian, MCZ Pro Flag, minglongxiaodian, Minisoso, Nasavalo, NATUBAS, ongcyk8, Pangjiang, PartsForCar, pingtangfujiuyyds, pingtanhuifeifeidianzishangwugongzuoshi, pingtanliushudandianzishangwugongzuoshi, pingtanmaoxiufangdianzishangwuzhonxin, Pursue a better life, QDTrade, qi dian qi che zu lin fu wu you xian gong si, qianxileshangmaoyouxi, qianyuanlong, qiaogu, qiazius, rdf845dfgr, RZSLYSMYX, sacvsfddsabvfd, Sanrily Brand Store US and Shangshuixianshengcaishangmaoyouxiangongsi added to case caption. (Text entry; no document attached.)

NEW PARTIES: ShenJiJingMao, shiyuanjingpinxiaodian, shuaijing, Song Direct, songshanqumuyanbaihuochaoshi, Songshanquxiaoyingbaihuochaoshi, Sunset Tech, tangpuyuededianpu, taoyijieSMyouxiangongsi, tingtingdianpu, TunChangRongSui, Tutugs, VEEE, WangwenhaoG, wangxinhao, wanningtangyankejiyouxiangongsi, wei luo xin xi, wei.9, weiwangluojixiangongzhouwangwei, wenjiexx, xiamen jin qian shuang an, XiangXueNIJSADO, xiaolvdian, xiariyangguangshop, xiaxiajiaohededainpu, xuayangyangdedian, XYHGM, Yangao7, YangChaoJie BaSa, YangLifengAFSWWER, yangxinjunlidian, yangyangqinghuidianpu, YingZhang88, Yisenkeji, YSH Auto Parts, YUANSHi, Yuanxi Electronics, yundouus, YUNONG, yuyuzhiwudian, zhangkuigdsdsba, ZhangPiduoJIDOASHO, zhangweiwei0215, ZhangWenWenChengDuLu, ZHAWEI, zhengzhoumairouwangluokejiyouxiangongsi, zhenzhongdedianpu, ZhuZhenWu--AMZ001, ZWQ store, Zxmcry, ac-autoparts_aftermarket, air.digital999, all-carb, allroo-us, autoparts-ck, dainslef-market, flarestar, guwu_goodwill, gzmotormall, gzrubbertrade, gzxiangchu, hager_8531, haiarchite0, iseatcover7, ouzewl, starbest-auto, sun1596-86, turbo-ty, ulusky, wanghao_6, wangyingming23012, wytjfb, zw-motor-parts, Bear civet, Beauty Closet, BTOER HOME, Goodhd, Hayafir, HpLive, Lucky Day, Mduoduo, Mingyiq Inc, Ruibeauty, Safini, Shaohao Household Products, Spring, Sufanic, Suyin, The Green Market, Yafix, aoonuauto.com, AnKcoo, ArchieFoster, Bruceaqga, Clara Smith, crojkigo, denim fitting, Derek Brown, dongyuqin89054, fugang fashion, gaochengshan2580, haisheng fashion, Heather McCann, HUANGDONGYUE520, Kevin Parrish and Lihua department store added to case caption. (Text entry; no document attached.)

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

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

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

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

MOTION by Plaintiff General Motors LLC to approve consent judgment as to Defendant No. 162

(Exhibit A)

MEMORANDUM by General Motors LLC in support of motion to approve consent judgment 37

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all Defendants with the Exception of a Certain Defendant

(Exhibit A)

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment, 39

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 40

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff General Motors LLC's motion to approve consent judgment 37 is granted. Enter Consent Judgment. Mailed notice.

CONSENT JUDGMENT Signed by the Honorable Mary M. Rowland on 8/30/2023. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff General Motors LLC's motion for entry of default and default judgment 39 is granted. Telephonic status hearing set for 9/8/23 is stricken. Enter Final Judgment Order. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 8/30/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding order 45 in the amount of $50,000 as to certain defendants

MOTION by Defendant The Green Market to vacate Judgement dated August 30, 2023 (ECF 45) because Good Cause Exists to Vacate the Default since The Green Market Quickly Appear and has Presented a Meritorious Defense

(Text of Proposed Order)

MEMORANDUM by The Green Market in support of motion to vacate, 47

AFFIDAVIT by Defendant The Green Market in Support of MOTION by Defendant The Green Market to vacate Judgement dated August 30, 2023 (ECF 45) because Good Cause Exists to Vacate the Default since The Green Market Quickly Appear and has Presented a Meritorious Defense 47

Exhibit A - Docket in General Motors LLC v. The Partnerships, et al., 1:23-cv-3171 (N.D. Ill.)

Exhibit B - Docket in Purple Innovation v. Chuang Fan Handicraft, et al., 2:22-cv-00620 (D.Utah)

Exhibit C - Screenshots from chinafirewalltest.com

Exhibit D - Order in Mwami v. U.S., et al., 1:99-cv-125 (D.D.C.)

Exhibit E - Order in Langford v. Jurez Cartel, et al., 1:20-cv-132 (D.N.D.)

Exhibit F - Proof of Service in Purple Innovation v. Chuang Fan Handicraft, et al., 2:22-cv-00620 (D.Utah)

(Exhibit G - Brief of Amici Curiae in Palace Skateboards Grp. v. Aimeey, et al., 1:21-cv-05860 (S.D.N.Y.))

ATTORNEY Appearance for Defendant The Green Market by Baruch Simcha Gottesman

MINUTE entry before the Honorable Mary M. Rowland: Defendant The Green Market's motion to vacate 47 is under advisement. Plaintiff shall file a response brief of no more than 10 pages on or before 9/22/23. Mailed notice

MOTION by Plaintiff General Motors LLC for leave to file excess pages in light of the Court's September 14, 2023 Order

Notice of Withdrawal of Plaintiff's Motion to Exceed Page Limitation in Light of the Court's September 14, 2023 Order 52 by General Motors LLC

RESPONSE by General Motors LLCin Opposition to MOTION by Defendant The Green Market to vacate Judgement dated August 30, 2023 (ECF 45) because Good Cause Exists to Vacate the Default since The Green Market Quickly Appear and has Presented a Meritorious Defense 47

Declaration of Rachel S. Miller

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

(Exhibit 8)

MINUTE entry before the Honorable Mary M. Rowland: In light of the Notice of Withdrawal 53, Plaintiff's Motion to Exceed Page Limitation in Light of the Court's September 14, 2023, Order 52 is withdrawn. Mailed notice.

FULL SATISFACTION of Judgment regarding order 45 in the amount of $50,000 as to certain defendants

ATTORNEY Appearance for Defendant Sanrily Brand Store US by Christopher Paul Keleher

MOTION by Defendant Sanrily Brand Store US to vacate order 45 Default Judgment

Exhibit Declaration

(Exhibit Product Listing)

MINUTE entry before the Honorable Mary M. Rowland: Any response to Defendant Sanrily Brand Store's motion to vacate 58 is due 10/24/23. Mailed notice.

RESPONSE by General Motors LLCin Opposition to MOTION by Defendant Sanrily Brand Store US to vacate order 45 Default Judgment 58

Declaration of Rachel S. Miller

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

NOTICE by General Motors LLC of Recent Related Decision

(Exhibit 1)

REPLY by Sanrily Brand Store US to response in opposition to motion, 60 To Vacate Default Judgment

Notice of Recent Related Decision by General Motors LLC

(Exhibit Exhibit 1)

FULL SATISFACTION of Judgment regarding order 45 in the amount of $50,000 as to certain defendant

MINUTE entry before the Honorable Mary M. Rowland: Defendant Green Market's motion to vacate default 47 and Defendant Sanrily Brand Store US's motion to vacate default 58 are granted. Plaintiff is to file a status report by 3/29/24 regarding the status of the matter against these two defendants. Mailed notice.

MOTION by Defendant The Green Market for extension of time to file answer or otherwise repond to the Complaint until April 5, 2024

(Text of Proposed Order)

STATUS Report per 65 by General Motors LLC

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 67. Plaintiff is to file a status report 4/15/24 regarding the status of the case against Green Makers. Defendant Green Makers motion for extension of time 66 is granted. This defendant is to respond to the complaint by 5/5/24. Mailed notice.

MOTION by Defendant The Green Market for extension of time to file answer regarding complaint 1 Second Motion on Consent of all relevant Parties Extending time to Answer or otherwise Respond to the Complaint from April 5, 2024 to May 6, 2024, to allow parties time to complete settlement negotiations

(Text of Proposed Order)

MINUTE entry before the Honorable Mary M. Rowland: Green Market's motion for extension 69 is granted. Answer due 5/6/24. Status report remains due 4/15/24. Mailed notice.

STATUS Report per 68 by General Motors LLC

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the status update. This matter is closed. By 5/15/24, Plaintiff is to file a final status report and indicate that the (1) parties resolved their dispute or (2) Plaintiff will file a separate complaint identifying Green Market as a single defendant. Mailed notice.

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

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

STATUS Report per 72 by General Motors LLC

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report. 75. The matter remains closed. Mailed notice