2023-cv-03555

COMPLAINT filed by FCA US LLC; Filing fee $ 402, receipt number AILNDC-20709119.

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 Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeffrey Cummings. 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.

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 1-6 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

(Exhibit 2-6)

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)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 13, motion for leave to file 3, motion for miscellaneous relief 18 before Honorable Jorge L. Alonso on 6/13/2023 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 6/13/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff FCA US LLC by Jake Michael Christensen

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for leave to file under seal [3] is 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. Enter Sealed Temporary Restraining Order. Plaintiff's Motion for electronic service of process pursuant to Fed.R.Civ.P.4(f)(3) [18] is granted. Telephonic status hearing set for 6/27/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 6/13/2023. Notice mailed by Judge's staff

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 $ 10,000 posted by FCA US LLC. (Document not scanned.)

MOTION by Plaintiff FCA US LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction 27

Declaration of Kahlia R. Halpern

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 27 before Honorable Jorge L. Alonso on 6/27/2023 at 09:30 AM.

(Exhibit A)

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/22/2023, answer due 7/13/2023.

Declaration of Quinn B. Guillermo

(Exhibit A)

ATTORNEY Appearance for Defendant The Partnerships and Unincorporated Associations Identified on Schedule A by Robert Michael Dewitty Defendant Bestaoo

ATTORNEY Appearance for Defendant The Partnerships and Unincorporated Associations Identified on Schedule A by Robert Michael Dewitty Sukemichi

RESPONSE by The Partnerships and Unincorporated Associations Identified on Schedule A in Opposition to MOTION by Plaintiff FCA US LLC for preliminary injunction [27]

Exhibit Exhibit A

Exhibit Exhibit B

Exhibit Exhibit C

REPLY by FCA US LLC to response in opposition to motion, [33]

DECLARATION of Kahlia R. Halpern regarding reply to response to motion[34]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 8/10/23 at 9:30 a.m. The parties are directed to file a joint status report by 8/7/23. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction as to Defendant Nos. 21-153 [27] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal all previously sealed documents. 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 at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order Signed by the Honorable Jorge L. Alonso on 6/27/2023. Notice mailed by Judge's staff

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

NEW PARTIES: A+ Car Accessories Store, China Number Two Store, FDIK Autoparts Store, Gold Gym Store, jakae Store, lasting charm Official Store, MUCHKEY AutoParts Store, rqzae Store, Shop1102134088 Store, Shop1102336621 Store, Shop1102374418 Store, Shop1102460117 Store, Shop1102721032 Store, Shop1102725226 Store, Shop1102735725 Store, Shop1102778106 Store, Sun car Store, TOUREEMIN Official Store, Wan Ta Store, WIND MH Store, A2OKGXPBT9MKGW, A708ACJ4587P5, Adullaner, Annebal Jean, AnQingZengGenShangMaoYouXianGongSi, Barrfen, bestaoo, Boyuqian, caiyuankaiyushangmao, ChezMaxmall, chongqingchengyuluobangongjiajuyouxiangongsi, Cynbaark, Dery Mick, dngxianghudb, dongyang123, Drefen Mety, FEIFIE, fuyangshiguiyulewangluokejiyouxiangongsi, GETYDY MOSSTER, gexishangmao1, Gorgeriie, huangchaodedianpu12, HuaRongDianZiShangWu, Jian Hert, JiaoYiKaiYiWangLuo, Koreyeeshi, Leng Ford, liaobai, lingxiaohui, LiShiQidedian, LongJi 4, luoshaohua123, Merry Yue, mianyu, Minerve Dizney, Mrrlty Jison, Nkoinem, OfficialCarLightsStore, PaintingFLIPPing, PEI's Warehouse, renguoqingngshanuojiajuyoux, Ry Cao Bo Wen, Sajewel, shanxiyongbaqitongshangmaoyouxiangongsi, sukemichi, Support Liu Jie, Van Sibhawmi, WeiTianHuaXiaoDian, wenshangxiansuyuefushishangmaodian, xiamenshanyimaoyiyouxian, xianhaokaikewangluokejiyouxiangongsi, xionglangweidexiaodian, XIXIANXINQU KONGGANGXINCHENG YUWENRUOTU BAIHUODIAN, YanYanXianShop, Yestech Store, YUNFX, Yuxxis, Zanoiker, 2speedup, abright-usa, aconn-moto, aentuo879, allesgut2017, auto_wheel, autocoolingseller, automotive-maker, bestautoparts, best-selling16, bigdream-0790, billy0sun, blues-store, byan-2479, carpart777, carsensor-usa, cotee101, coyle666, crazycarcar, deyifly3, ducenting, factoryvipstore, faraway-parts, goldengu-13, haley123, hefeigankuoshang-0, hengpei-auto-parts-store, humeiliwanliu, innertube, iyonghong, jetjeep, kansuide-65, langtonparts, lihuake-6019, lingtafa4782, lunzh022, matsmall, mdt-0103, motors-coyle, padance, panguruwarehouse, pickup-mall, podol-au, podol-uk, podol-us, pwbf8830, qr-home, qr-sports, sunealy, superautopart67, talos-parts, teilelager-2010, vapourparts, verd-37, wanwu789, wisenews, wuhuaq_94, xunzamotors, yihuihjg, zekendc, ahedianzishangwu, SHICANDING STORE, Shuifengshu Store, Womingchen and YKAPE Co.Ltd added to case caption. (Text entry; no document attached.)

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

MOTION by Plaintiff FCA US LLC for entry of default, 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[43]

Exhibit 1

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

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment[43] before Honorable Jorge L. Alonso on 7/25/2023 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Defendants Gorgeriie, Shuifengshu Store, Womingchen, Yuxxis by Timothy Tiewei Wang

ATTORNEY Appearance for Defendants PEI's Warehouse, sukemichi by Adam Edward Urbanczyk

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 7/25/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Defendant bestaoo by Adam Edward Urbanczyk

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment [43] is granted. Enter Final Judgment Order. Defendant PEI's Warehouse's oral motion for an extension of time to answer is granted to 8/8/23. Telephonic status hearing previously set for 8/10/23 is stricken and reset to 8/15/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

FINAL Judgment Order. Signed by the Honorable Jorge L. Alonso on 7/25/2023. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order[53] in the amount of $200,000 as to certain defendants

STATUS Report per [36] by FCA US LLC

ANSWER to Complaint by PEI's Warehouse

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by PEI's Warehouse

FULL SATISFACTION of Judgment regarding order[53] in the amount of $200,000 as to certain defendant

ATTORNEY Appearance for Plaintiff FCA US LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 8/29/23 at 9:30 a.m. The parties are directed to file a joint status report by 8/24/23 if this case is not resolved before the next court date. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order[53] in the amount of $200,000 as to certain defendants

STATUS Report per [60] by FCA US LLC

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. The deadline for amendment of pleadings and joinder of parties is 10/2/23. All fact discovery shall be noticed in time to be completed by 1/31/24. This case is referred to the magistrate judge for discovery supervision, with the authority to set and extend deadlines, and a settlement conference. Notice mailed by Judge's staff

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Jeffrey Cummings for the purpose of holding proceedings related to: discovery supervision; settlement conference. Notice mailed by Judge's staff.

MINUTE entry before the Honorable Jeffrey Cummings: This case has been referred for discovery supervision and settlement. The Court has reviewed the parties' recent joint status report [62] and the District Court Judge's order setting a fact discovery deadline of 1/31/24. To the extent they have not already done so, the parties shall issue Rule 26(a)(1) disclosures by 9/20/23. Parties shall issue initial written discovery requests by 10/6/23. The parties are advised that they may contact this Court's courtroom deputy if at any point they are mutually interested in scheduling a settlement conference with the Court. By 10/20/23, the parties shall file a joint status report setting forth what discovery has been completed, what discovery remains, and whether any discovery disputes require the Court's attention. Mailed notice.

FULL SATISFACTION of Judgment regarding order[53] in the amount of $200,000 as to certain defendant

ATTORNEY Appearance for Plaintiff FCA US LLC by Berel Yonathan Lakovitsky

STIPULATION of Dismissal

STATUS Report per [65] by FCA US LLC Presented before Magistrate Judge

MINUTE entry before the Honorable Jorge L. Alonso: Pursuant to the stipulation of dismissal [68], this case is dismissed with prejudice with each party to bear its own costs and fees. Civil case terminated. Mailed notice

GENERAL ORDER 23-0041: Executive Committee Order: It appearing that Jeannice Appenteng has entered on duty as a Magistrate Judge for the Northern District of Illinois, with a duty station in Chicago, Illinois, effective October 27, 2023; and It further appearing that Internal Operating Procedure 17 provides for the creation of an initial calendar for a newly appointed magistrate judge; therefore It is hereby ordered that the attached list of civil consent, civil referrals, and criminal cases are hereby reassigned to form the initial calendar of the Honorable Jeannice Appenteng; and It is furthered ordered pursuant to Local Rule 72.1 that Magistrate Judge Appenteng is to become the designated magistrate judge in any pending civil or criminal cases where Magistrate Judge Jeffrey I. Cummings was the designated magistrate judge as of October 26, 2023; and It is further ordered pursuant to Local Rule 73.1 (e), the attached list of civil cases where the parties previously consented to proceed before the judge, pursuant to Local Rule 72.1, the parties may object within 21 days of reassignment. If a timely objection is filed by any party, the case will be reassigned to the district judge before whom it was last pending; and It is further ordered that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new magistrate judge for twelve months from the date of this Order; and It is further ordered that, unless otherwise ordered by Magistrate Judge Appenteng, all hearing dates, deadlines, and schedules set by the magistrate judges in the attached list of cases are to remain in effect. Case referred to the Honorable Jeannice W Appenteng for all further proceedings. Honorable Jeffrey -MagJud Cummings no longer assigned to the case. Signed by Honorable Rebecca R. Pallmeyer on 10/27/23.

FULL SATISFACTION of Judgment regarding order 53 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 53 in the amount of $200,000 as to certain defendant

NOTICE of Removal of Material from the Custody of the Clerk's Office by John Summerfield (Received for docketing 4/5/2024)