2023-cv-04882

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 402, receipt number AILNDC-20868942.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Volkswagen Group of America, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Volkswagen Group of America, Inc.

Notice of Claims Involving Trademarks by Volkswagen Group of America, Inc.

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Matthew F. Kennelly. 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 Volkswagen Group of America, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Volkswagen Group of America, Inc. 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 Dana A. Cizmadia regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Exhibit 3 - Parts 1-5 regarding declaration[16]

MOTION by Plaintiff Volkswagen Group of America, Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Volkswagen Group of America, Inc. 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 Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 18 are granted. Plaintiff's motion for entry of an ex parte temporary restraining order (etc.) 13 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Preliminary injunction hearing is set for 8/18/2023 at 8:50 AM. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. Any motion to extend the TRO or motion for preliminary injunction must be filed by 8/15/2023. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 8/4/2023.

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

SURETY BOND in the amount of $ 10,000 posted by Volkswagen Group of America, Inc. (Document Not Scanned)

MOTION by Plaintiff Volkswagen Group of America, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Volkswagen Group of America, Inc. in support of extension of time 24

(Declaration of Kahlia R. Halpern)

EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable Matthew F. Kennelly on 8/15/2023: Motion for extension of temporary restraining order 24 is granted; the ex parte temporary restraining order previously entered by the Court is extended through 9/1/2023. Telephonic preliminary injunction hearing set for 8/18/2023 is vacated and reset to 9/1/2023 at 8:55 AM, using call-in number 888-684-8852, access code 746-1053.

MINUTE entry before the Honorable Matthew F. Kennelly: The preliminary injunction hearing previously set for 8/18/2023 is vacated. Any motion for preliminary injunction must be filed by no later than 8/29/2023.

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain Defendants

MOTION by Plaintiff Volkswagen Group of America, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for preliminary injunction[30]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Volkswagen Group of America, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/29/2023, answer due 9/19/2023.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of a preliminary injunction is granted 30. Enter Preliminary Injunction Order. The telephonic preliminary injunction hearing set for 9/1/2023 is vacated. The case is set for a telephonic status hearing on 11/3/2023 at 8:50 AM. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. Plaintiff is directed to file a status report on 10/27/2023. The Clerk is directed to unseal all documents that were previously filed under seal. 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. 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. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 8/30/2023. Mailed notice.

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NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendants

LETTER from Defendant, kexikele.

MOTION by Plaintiff Volkswagen Group of America, Inc. for entry of default, MOTION by Plaintiff Volkswagen Group of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for entry of default, motion for default judgment, [36]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[37]

Exhibit 1

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default 36 is granted. Final Default Judgment Order to follow. Any hearing dates and deadlines before this Court are vacated. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 9/22/2023. Mailed notice.

MINUTE entry before the Honorable Matthew F. Kennelly: The Court has received a letter from a defendant in this case, kexikele, that apparently was received by the Clerk before the Court entered default judgment but not entered on the docket until after entry of the default judgment. If the Court had had this letter prior to the entry of judgment it likely would have excluded this defendant, at least at that time. The Court will take the letter as a motion to vacate the default judgment. Plaintiff is directed to communicate with the defendant (kexikele) promptly regarding a possible agreed-upon resolution and is to file a status report with the Court by no later than 10/6/2023.

FULL SATISFACTION of Judgment regarding order[41] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 41 in the amount of $100,000 as to certain defendant

STATUS Report pursuant to 42 by Volkswagen Group of America, Inc.

NOTICE of Removal of Material from the Custody of the Clerk's Office 23 by Greer, Burns & Crain Ltd. (Attachment).

FULL SATISFACTION of Judgment regarding order[41] in the amount of $100,000 as to certain defendants