2023-cv-05874

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 402, receipt number AILNDC-20957598.

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 Jeremy C. Daniel. Designated as Magistrate Judge the Honorable M. David Weisman. 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 1-8 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

(Exhibit 3-8)

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 temporary restraining order 11, motion for miscellaneous relief 16, motion for leave to file 3 before Honorable Jeremy C. Daniel on 8/29/2023 at 09:00 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing set for 8/29/2023 at 9:00 a.m is reset to 9:30 a.m. (TIME CHANGE ONLY) Mailed notice

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, and expedited discovery [11] and electronic service of process [16] are granted. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 8/29/2023. Mailed notice

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

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

SURETY BOND in the amount of $ 10,000.00 posted by Toyota Motor Sales, U.S.A., Inc. (Document not imaged)

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of extension of time[25]

Declaration of Justin T. Joseph

NOTICE of Motion by Justin Tyler Joseph for presentment of extension of time[25] before Honorable Jeremy C. Daniel on 9/12/2023 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion to extend the Temporary Restraining Order until 9/26/2023 25 is granted. Motion hearing set for 9/12/2023 is stricken. 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 preliminary injunction

(Exhibit A)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction 31

Declaration of Justin T. Joseph

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 31 before Honorable Jeremy C. Daniel on 9/26/2023 at 09:30 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 9/21/2023, answer due 10/12/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Kahlia Roe Halpern

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 9/26/2023. Motion hearing held. Motion for preliminary injunction [31] is granted. Status hearing set for 11/14/2023 at 9:30 a.m. The law firm of Greer, Burns & Crain, Ltd. is hereby 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. Mailed notice

NEW PARTIES: Guangzhou Youstar Technology Co., Ltd., Guangzhou Youtes Electronic Technology Co., Ltd., Shenzhen Kuriharden Trading Co., Ltd., Kiddo Store, Shiny Waves Store, Shop1102579236 Store, (7-15) day the arrival, A2SK1RE5OUDZIX, A37CTMC301P3WR, angzhouqingxin, Auto Car Store, BLUECHARM, Foshan Zhou Surprise Trading Co., gemingweidedianpu, guangzhoushaorangshangmaoyouxiangongsi271, haiyanmaoyi, huangchaodedianpu12, HUANGYAN88, HuJianbft, iSuperguys, JUNYI AUTOPARTS, MaJher, mingfouqijingpinxiaopu, Qonyv Auto, Rarido, RefitEco, shanxizongquanjunyanshangmaoyouxiangongsi, Tcuisuy., tianrenxindedian, WangHaodedian, ZhangWenWenChengDuLu, zhijiangshizhuotingdianzishangwuyouxiangongsi, buydhgate11 Store, dafu01 Store, joseph_store Store, qiuti18, accoun488, autodream_home, autoli66, businessseller_0, charmingglobal0, cheech9, do107222, easy-driv, effort-rageman, fast-furious, franli-75, gameworldw, haly_auto, hamait-19, high-quality-service, huitengyue-5, liufei-6583, maijiale, nguy8220, parts-field, parts-multi, pengjinzan3, phuluong_27, pinegateinvestme0, prich-auto, r-miraclestore, small_target-auto, springtimeairc-0, taihungindustri0, topsa25, wenqiuna-3, xuli003, xuridongsheng, xxshch369ok, yuchao5_86, zhengqi828, ziqidonglai, Car Emblem, JSDauto, Ok Auto Supplies, OMO car, Parity cart, Simon Master, xiangxiangchepin, Zoe car stickers, Austin Alumni Association, Bailamo123, chenqinlin520, chenzhibin1987, Filing susunten, goodfine, HeatherArt, Hoyingya, IKOHJOLISDH, jianhuaxie, Little sunspot, LLOUYANG, mayuanyuan1386, minghuahm6, prettypinkart, qiuyun, shining952, SPower accessories, wangwangliang, zhouchuanshe and zhuidancuifeng added to case caption.

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

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[40]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[41]

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment[40] before Honorable Jeremy C. Daniel on 10/19/2023 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Defendant BLUECHARM by Shengmao Mu

MOTION by Defendant BLUECHARM for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Motion for entry of default and default judgment, excluding defendant Bluecharm, [40] is granted. Motion for extension of time to respond to complaint by 10/31/2023 [45] is granted. Mailed notice

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 10/19/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order[47] in the amount of $10,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[47] in the amount of $10,000 as to certain defendant

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

MINUTE entry before the Honorable Jeremy C. Daniel: Pursuant to the Notice of Dismissal Under Rule 41(a)(1), the case is dismissed with leave to reinstate on or before 8/9/2024. If not reinstated on or before 8/9/2024, the dismissal becomes with prejudice. Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order 47 in the amount of $10,000 as to certain defendants

MAILED trademark report with certified copy of minute order dated 11/13/2023 to Patent Trademark Office, Alexandria VA.

NOTICE of Removal of Material from the custody of the Clerk's Office 24 by Plaintiff's counsel.

FULL SATISFACTION of Judgment regarding order 47 in the amount of $10,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[47] in the amount of $10,000 as to certain defendant

MINUTE entry before the Honorable Jeremy C. Daniel: Any party to this action has until October 3, 2025, to justify the continued need to seal any documents in this case. The Court intends to unseal all documents in this case after that date. Mailed notice.