2023-cv-14327

COMPLAINT filed by General Motors LLC; Filing fee $ 402, receipt number AILNDC-21167602.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff General Motors LLC Schedule A regarding complaint 1

MOTION by Plaintiff General Motors LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by General Motors LLC

Notice of Claims Involving Trademarks by General Motors LLC

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff General Motors LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff General Motors LLC by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff General Motors LLC by Rachel S Miller

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2).

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 General Motors LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by General Motors LLC 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 Andrea Ankawi regarding memorandum in support of motion 12

(Exhibit 1)

SEALED EXHIBIT by Plaintiff General Motors LLC Exhibit 2 - Parts 1 - 7 regarding declaration 14

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

(Exhibit 2-7)

MOTION by Plaintiff General Motors LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by General Motors LLC 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 leave to file 3, motion for miscellaneous relief 16 before Honorable Manish S. Shah on 10/10/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motions for leave to file under seal [3], for entry of temporary restraining order [11], and for electronic service of process [16] are taken under advisement. Plaintiff is directed to resubmit the proposed order including only the trademarks allegedly infringed by defendants. Notices mailed.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process [3] [11] [16] are granted. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, although the court has some reservations with respect to some of the defendants' alleged infringement, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement, and they are free to raise any defenses or arguments on the merits. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/10/2023. Notices mailed.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (mek,)

SURETY BOND in the amount of $50,000 posted by General Motors LLC. (Document not scanned.)

MOTION by Plaintiff General Motors LLC for extension of time of Temporary Restraining Order

MEMORANDUM by General Motors LLC in support of extension of time[24]

Declaration of Jake M. Christensen

NOTICE of Motion by Jake Michael Christensen for presentment of extension of time[24] before Honorable Manish S. Shah on 10/24/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 24 is granted, and no appearance on the motion is necessary. The TRO is extended to 11/7/23. Notices mailed.

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MOTION by Plaintiff General Motors LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by General Motors LLC in support of motion for preliminary injunction 29

Declaration of Jake M. Christensen

(Exhibit 1)

NOTICE of Motion by Jake Michael Christensen for presentment of motion for preliminary injunction 29 before Honorable Manish S. Shah on 11/7/2023 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/2/2023, answer due 11/23/2023.

Declaration of Rachel S. Miller

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [29] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 11/7/2023. Notices mailed.

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

NEW PARTIES: AUTOPARTS G, Beautiful palace, dsacxzdqfdsbvfd, Hongyan Shopping Mall, junjuninping, shashadedianpu, shuoan-shop, tangjunjieUS, Thanks#, TianxiaWZ, Tlades, weiweiLL, woyangxianpianhuamaoyiyouxiangongsi, XIACHUNCN, xiangchengshiqunyaoshangmaoyouxiangongsi, XIEJINNANSHEN, xindedianpuha, XMhyq, xuchunm llc, yangkuou, yangxinxianyansudubaihuodian, yaYySUA, yiyouhuo, YUNUVE, Zhangzhou Awesome Commercial Company, zhouqinlan876534, ZUILING POSTER, ai791, ai831, blessmeat2022, piao05, tytradeshop, xovke, ab_partstore, alles-geschaft_bm, amyl-2552, autoparts_wholesalers, autoparts188, autoparts-hotspot1, awesensor, bestore_king, cggt3030, clkjab, desirableshop2022, draweater, dynamo-coyle, essen_k, ghs_globalshopping, hellohishop, hotspot-accessory88, jialin12651, jiongjewelry2014, jxc20-7, lingyuekeji2, llive, makuanghome, mangotong, modigt_18, mokuangoa, mokuanguk, nectarinetw, nuliya, oz_tool_it, powerzbirds, professional-auto, qingt8329, selleryal, shippinghouse22, successhop, tesco-car, tianyidianzi, tradeasy2020, uoulol, v-gaint, wenya68-45, wflu-73, ybytechsales, ztek012, Auto Hause, GOOD OK, NiceAuto Accessoice, Leachwood Co. Ltd, NEGOO STORE, Smart Team, obd16shop.com, obd2.ltd, obd2eshop.com, ChenYing02, Cozy Craftsmanship, EvyGlobal, nvhtfc supper-market, SHAWNA OHL, TeeCorner, Twister market, wangyanbin, wangyuchen8049, wangyuting fashion, Welby, William Jaeger, wqangguolonger, wuchuan fashion, wueirotp, wuhuil, wupenghua, xiaoxiaoming fashion, xiexuran8215, xijnmv fashion store, Xilaigthy Danceclothes, yangkai5574, yangxiaolug, yanshuihongshi, YaochouchenguP, yaosongtaosn, yinshuangxiong0089, YM car decoration, ynkjhj plaza, youknowit, YuQin Fashion Apparel Co. Ltd, yuxiaoshaui2921, zhaixue24327, zhanchaoyue, zhangchunyana, zhangfukang6073, zhanghui Store me, zhangjian3698, zhangkai001, zhangkaiyang8655, zhangmingli6107, zhangting1576, zhangxiangyuen, zhangxubo7464, zhangyh, zhangzhaotuan, Zhaoyangen, zhengsanlian, zhongdawen Store, zhoukangrong7490, Zhoumin0586, zhulijiu, zhuzhuluu, ZL CAR COMPETITIVE, Zting1458 and ZX Valkiri Store added to case caption.

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

ATTORNEY Appearance for Defendant uoulol by Christopher Paul Keleher

MOTION by Defendant uoulol for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer [38] is granted. Defendant uoulol has until 12/13/23 to respond to the complaint. Notices mailed.

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all Defendants with the Exception of a Certain Defendant

Exhibit A

MEMORANDUM by General Motors LLC 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 Jake Michael Christensen for presentment of motion for entry of default, motion for default judgment, [40] before Honorable Manish S. Shah on 12/6/2023 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Defendants awesensor, professional-auto, selleryal, tradeasy2020, xuchunm llc by Adam Edward Urbanczyk

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment [40] is granted. Enter Default Judgment Order. Plaintiff shall file a status report as to the remaining defendant by 12/14/23. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/6/2023. Notices mailed.

FULL SATISFACTION of Judgment regarding order[46] in the amount of $50,000 as to certain defendants

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

FULL SATISFACTION of Judgment regarding order[46] in the amount of $50,000 as to certain defendants

STATUS Report per [45] by General Motors LLC

MINUTE entry before the Honorable Manish S. Shah: All of plaintiff's claims having been resolved, this case is dismissed. Civil case terminated. Notices mailed.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $50,000 as to certain defendants

NOTICE of Removal of Material [23] by John Summerfield from Greer, Burns & Crain, Ltd. (Exhibits).

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED trademark report Part 2 to Patent Trademark Office, Alexandria VA.

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

MAILED trademark report with certified copy of minute order dated 12/15/2023 to Patent Trademark Office, Alexandria VA.

MAILED trademark report with certified copy of minute order dated 12/15/2023 Part 2 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $50,000 as to certain defendants