2023-cv-03547

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 402, receipt number AILNDC-20708222.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Toyota Motor Sales, U.S.A., Inc.

Notice of Claims Involving Trademarks by Toyota Motor Sales, U.S.A., Inc.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. 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 Toyota Motor Sales, U.S.A., Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. 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 Teena Bohi regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 3 - Parts 1-5 regarding declaration[14]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for miscellaneous relief[16]

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

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for temporary restraining order[11], motion for miscellaneous relief[16] before Honorable Elaine E. Bucklo on 6/14/2023 at 09:45 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 3 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 11 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 16 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 6/28/2023, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 6/21/2023. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. 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. The case is set for a status hearing on 7/28/2023 at 9:45 a.m. (to track the case only, no appearance is required). By 7/21/2023, plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 6/14/2023. 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 Toyota Motor Sales, U.S.A., Inc. (Document not scanned.)

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for extension of time of Temporary Restraining Order Ex Parte Motion to Extend the Temporary Restraining Order Modified on 6/22/2023 (jk2,).

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of extension of time 24

(Declaration of Justin T. Joseph)

NOTICE of Motion by Justin Tyler Joseph for presentment of extension of time 24 before Honorable Elaine E. Bucklo on 6/28/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 24 is granted to 7/12/2023. Mailed notice.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction 30

Declaration of Justin T. Joseph

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 30 before Honorable Elaine E. Bucklo on 7/12/2023 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/7/2023, answer due 7/28/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction as to certain defendants [30] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Teena Bohi [15], and the TRO [23]. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 7/11/2023. Mailed notice.

NEW PARTIES: Anhui Pingyao Trading Co., Ltd., Chongqing Xiyue Auto Parts Co., Ltd., Dongguan Blaze Sportswear Co., Ltd., Dongguan Dongli Xingsheng Plastic Co., Ltd., Dongguan Shanhao Technology Co., Ltd., Guangzhou Kulite Automotive Products Co., Ltd., Guangzhou Yitao Trading Co., Ltd., Guangzhou Zhimeng Industrial Co., Ltd., Guangzhou Zhuocai Auto Parts Co., Ltd., Hebei Dongjie Auto Parts Co., Ltd., Jiujiang Baead Photoelectric Technology Co., Ltd., Shenzhen Longzhiyu Crafts Co., Ltd., BOBO Official Store, Hengyunxing Auto Supplies Store, JacketClothing 7 Stores Store, liubowen8886 Store, Lucky Rider 1688 Store, Minespeed Store, MONCERS Store, Shop1102553449 Store, Shop1102605174 Store, Shop1102626768 Store, Shop1102636847 Store, Shop1102650970 Store, Shop1102660651 Store, Shop1102661463 Store, Shop1102665644 Store, Shop1102683041 Store, Shop1102701147 Store, Shop1102709352 Store, Shop1102710371 Store, Shop1102710465 Store, Shop1102713338 Store, Shop1102714300 Store, Shop1102733123 Store, Shop1102735993 Store, Shop1102749119 Store, Shop1102751223 Store, Shop1102766271 Store, Shop1102770436 Store, Shop1102773399 Store, Shop911601018 Store, ZQ High End Boutique Clothing Store, A1IL0LN94PWCL2, A1WWYGF7VX1GL6, A27E42V6AH5AQ, A6JWZS8UB1UAH, aran, CAIJUN-AUTO, Didithes, DingYouPeng, DongJunWen, Emeenie, GIVEme5, GUANGPENG, guangzhouhuangmiaoshangmaoyouxiangongsi, guangzhoushimiyakejigongzuoshi, haiboqihaiboqi, hefeikouyuxuzhanshangmaoyouxiangongsi, jiaruidedianpujingpin, Jike Uk, liyunSDF45, Lxjyr, MiaoZhun JieYa, Minzhou, qiyikuajing US, rongmindedianpu, Ry song hui xin, shuifujuantuwangluokejiyouxiangongsi1, wenbinbinshangmaoxiaodian, WuHuaYu, xiamaojp, xingchundedianpu, Yonwait-Auto-US, zhaoxinyanjingpin, ZhuFuYuXiaoDian, elena2012168, autwaus, candys18, Century Old Store, eacoopart, fiya-auto2, fsyibo, great-gadget-zonee, greatsale2020, haofuqi181818_2, imhkseller, marieduoduotech549, mlyp202209, qiongshi, shuaishuyu1996, us-rex, yourauto19, zhouzhouworld and Proactive Discount Sellers added to case caption.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/14/2023, answer due 8/4/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

STATUS Report pursuant to 22 by Toyota Motor Sales, U.S.A., Inc.

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report, plaintiff reports active settlement negotiations with multiple defendants. Plaintiff will move for default judgment at a later date where appropriate. Status hearing is reset for 9/19/2023 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 9/12/2023. The court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain Defendants

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for entry of default, MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment[43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment[43] before Honorable Elaine E. Bucklo on 8/11/2023 at 09:45 AM.

Exhibit A

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendant

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment as to all remaining defendants 43 is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Toyota Motor Sales, U.S.A., Inc. or its counsel, Greer Burns & Crain, Ltd. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 8/11/2023. Mailed notice.

MAILED trademark report and certified copies of order and judgment dated 8/11/2023 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 49 in the amount of $250,000 as to certain defendant

NOTICE of withdrawal of Surety Bond 27 by John Summerfield (received for docketing 4/5/2024) (received at the intake counter on 3/29/2024).

FULL SATISFACTION of Judgment regarding order[49] in the amount of $250,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[49] in the amount of $250,000 as to certain defendant