2023-cv-03308

COMPLAINT filed by FCA US LLC; Filing fee $ 402, receipt number AILNDC-20673946.

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 Andrea R. Wood. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

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 13

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-8 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

(Exhibit 2-8)

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 18

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

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 6/6/2023 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 6/6/2023. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2] and (2) Exhibit 2, Parts 1-8 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 6/6/2023 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 6/20/2023 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 6/6/2023.

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

INJUNCTION BOND in the amount of $ $10,000.00 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[25]

Declaration of Kahlia R. Halpern

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 25 is granted. The Court finds good cause to extend the Temporary Restraining Order until 7/5/2023. Telephonic status hearing set for 6/20/2023 is stricken and reset for 7/5/2023 at 10:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

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

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

MOTION by Plaintiff FCA US LLC for preliminary injunction

Exhibit A

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction[30]

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 6/29/2023, answer due 7/20/2023.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction 30 is set for a telephonic motion hearing on 7/5/2023 at 10:30 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 7/5/2023. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 30 is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint 2, (2) Exhibit 2, Parts 1-8 17, and (3) the sealed temporary restraining order 23. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 8/22/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 7/5/2023. Mailed notice

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

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

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 defendant

ATTORNEY Appearance for Defendants autopartsnearme, bbgsauto, bulingparts, carpartsengr, carpartshub by Christopher Paul Keleher

MOTION by Defendants autopartsnearme, bbgsauto, bulingparts, carpartsengr, carpartshub for extension of time to file answer regarding complaint 1

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

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

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

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/22/2023. Only Plaintiff appeared. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 38 is granted. Enter Order. Defendants autopartsnearme, bbgsauto, bulingparts, carpartsengr, and carpartshub's motion for an extension of time to answer or otherwise plead 43 is terminated as moot as those Defendants were voluntarily dismissed 44, 45. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 8/22/2023. Mailed notice

MAILED trademark report with certified copy of minute order dated 8/22/2023 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 49 in the amount of $500,000 as to certain defendant

NOTICE of withdrawal of Surety Bond 24 by John Summerfield (received for docketing 4/5/2024) (received at the Intake Counter 3/29/2024).