2023-cv-03304

COMPLAINT filed by FCA US LLC; Filing fee $ 402, receipt number AILNDC-20673231.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff FCA US LLC Schedule A regarding complaint[1]

MOTION by Plaintiff FCA US LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FCA US LLC

Notice of Claims Involving Trademarks by FCA US LLC

ATTORNEY Appearance for Plaintiff FCA US LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff FCA US LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff FCA US LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff FCA US LLC by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Robert W. Gettleman. 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.

MOTION by Plaintiff FCA US LLC for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by FCA US LLC in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion 12

(Exhibit 1)

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-7 regarding declaration 14

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

(Exhibit 2-7)

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

MEMORANDUM by FCA US LLC in support of motion for miscellaneous relief 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Motion for Leave to File Under Seal 3, Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) 16, and Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery 11 are granted. Telephonic hearing set for 6/8/2023 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Members of the public and media may listen to these proceedings by dialing (650) 479-3207 the meeting number, access code, or PIN/ID is 1809883385. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 5/26/2023. 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 FCA US LLC. (Document Not Scanned.)

MOTION by Plaintiff FCA US LLC for extension of time of Temporary Restraining Order

MEMORANDUM by FCA US LLC in support of extension of time[24]

Declaration of Kahlia R. Halpern

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's ex parte motion to extend the Temporary Restraining Order 25 is granted. Enter order. Telephonic hearing set for 6/8/2023 is stricken and reset to 6/15/2023 at 9:15 a.m. on the Webex platform. (The court will not be holding hearings the week of June 19, 2023) Parties will not be asked to start their video. Members of the public and media may listen to these proceedings by dialing (650) 479-3207 the meeting number, access code, or PIN/ID is 1809883385. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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

EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable Robert W. Gettleman on 6/6/2023. Mailed notice

MOTION by Plaintiff FCA US LLC for preliminary injunction

Exhibit A

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction[28]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/12/2023, answer due 7/3/2023.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 6/15/2023. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's motion for entry of a Preliminary Injunction [29] is granted. Enter order. 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 located at www.ilnd.uscourts.gov/instructions. The Clerk is directed to unseal Schedule A to the Complaint [2], Exhibit 2 to the Declaration of Thomas H. Hipelius [15], and the TRO [22]. Telephonic hearing set for 8/3/2023 at 9:30 a.m. Plaintiff is directed to submit a brief status report by 7/28/2023. Parties will not be asked to start their video. Members of the public and media may listen to these proceedings by dialing (650) 479-3207 the meeting number, access code, or PIN/ID is 1809883385. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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 Robert W. Gettleman on 6/15/2023. Mailed notice

NEW PARTIES: Cross-border Car Products Store, DAAR Belt Store, GYM SUPERMAN Store, JEEPJack Store, Jitty Store, Private Custom Auto Parts Store Store, Shop1102406559 Store, Shop1102602703 Store, Shop1102646208 Store, Shop1102649210 Store, Shop1102676658 Store, Shop910351312 Store, Shop911150014 Store, SUNNY-OuO Store, VEHICAR AUTO Store, VEHICAR Global Store, Women's Accessories Store, XUMOLI03 Store, A18JRFNMRAC0P4, A1BQ3BZVI9RMWX, A1E2C3CUOVJM5R, A25TTW8HU5M5IO, A2NVXTZU3TUVNV, A2SVSLDCK4PBHU, A3FT5A6M22QFTY, A3RWS5RGMOY7Q2, AA5E13LQE7GKF, airundianzishangwu, AJS-U, alivoda US, AlonzoPHinojosa, ALTRUB, anqingguiquanshangmaoyouxiangongsi, anqingqingchongshangmao, artsocianal, Autohome store, AVH4P2M3D6ZU7, AWD0BR2I8CW0R, BayyonDirect, BENSALOR, binzhoudashawanglaokeji, bluemood-baby, Boseyway Auto Shop, BuLuManSiDianZiShangWuYouXianGongSi, camelliasd, CarTIAN, Cayyon shop, Cheeks of the car, chenaoranjingpin, chengduyouchangmeishangmaoyouxiangongsi, Cisshop, Dafony SHOP, dongfangyezhouwangluokejiyouxiangongsi, DONGGUA, dongguanchangqingshangmao, dongguanfeifengmaoyi, DouChangXianYueYanShangMao, DSFAFEWREWR, Dutern Sign, EAL Design, fancdd5, FangFang Zhang, FUTA-FUTA, fYoudZhsiWei, ganganwoxci, GENMENGSHANGMAO, GodState, Golfsportsgardenflags, G-o-r-o-t-a, guangzhoukaikeshangmaoyouxiangongsi, guangzhoushienyuanshangmaoyouxiangongsi546, gukaikai, GuozhuHuang, GZHGMY, HANNHAI, haohaoxiaojingping, haqushangmao, HARBILLION, HeFeiNieZenMaoYiYouXianGongSi, HeFeiQiTingShangMaoYouXianGongSi, Helen Autoparts, hezezhihuidianzishangmaoyouxianzerengongsi, HongWanQIChePeiJianYouXianGongSi, huilungongmao, JEEPLPF, JiaoMin, jiashimei, JinMingHeShu, jinquanjingping, JiuJiangHongDaiLianMaoYiYouXianGongSi, junyishuhua, Just-AutoTrims, Kai sign, kaihuism, kaisinn, Kangzhen Store, kediwangluoxiaoshou, King-fang313, KunMingLouJianShangMaoYouXianGongSi, LAN-us, Lequ Inc, liangshanmaxiangzhibaihuoshangdian, lianyuanshifukouzhenheshenglibaihuoshangdian, lijiangshant, limaoshanjingpin, LinFengYiWangLuoKeJi (LinGao) YouXianGongSi, LinlStore, lizhihuibp, LOVEMYFLAGS, Lucky Lucky car, LUO'Bo, Man Tianxing, meipingdianzixiaopu, meizhoudaoshangdechibaibaihuodian, mengchengxianbingjunshangmao, menglabenshanshangmaoyouxiangongsi513, mengxiangguojimaoyi, Merryking, Moolily, MYBESTFURN, NanWanDU, NIANXIIN, nuteor, nzhouchenji, Owesoe, PAJSF, PanJinSongNkdiegakndgL, Peta Meng, philipzhu, Pvnoocy, qdsrtyuuhhggfhjj, QianXiuWangLuoKeJi, qinqiuyunbaihuodian, quhashangmao, qujinglexiaoyushangmaoyouxiangongsi, QUNSUNUS, renpingdedianpuha, Richyoneerator, shang US, ShengFuYunBeiJingShangMaoYouXianGongSi, ShiBangWeingWeiSh, shihandedianpu, Shinea, shizhinankaixin, shuangbaixianguangqishangmaoyouxiangongsi4387, shuifudeqiuwangluokejiyouxiangongs11299, shuifufeisaiwangluokejiyouxiangongsi, sttubw2, SUNSEN STORE and SUORTYVB added to case caption.

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

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

MOTION by Plaintiff FCA US LLC for entry of default as to all Defendants, MOTION by Plaintiff FCA US LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by FCA US LLC in support of motion for entry of default, motion for default judgment 38

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 39

(Exhibit 1)

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

STATUS Report per 31 by FCA US LLC

(Exhibit A)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 8/3/2023. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 38 is granted. Enter order. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 8/3/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order 44 in the amount of $500,000 as to certain defendant

MOTION by Plaintiff FCA US LLC to amend/correct order[44] Default Judgment Order

Exhibit A

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Motion to Correct Default Judgment Order 46 is granted. Enter amended final judgment order. Mailed notice

AMENDED FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 9/1/2023. Mailed notice

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Minute Entry dated 8/3/2023)

NOTICE of Removal Material from the Custody of the Clerk's Office by Justin R. Gaudio of the firm of Greer Burns & Crain Ltd. regarding Surety Bond 23. (Received at the Intake Counter on 3/29/2024)