2023-cv-15256

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 402, receipt number AILNDC-21253053.

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 Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2). (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 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[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Teena Bohi regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 3 - Parts 1-9 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

(Exhibit 3-9)

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[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

Exhibit 1

Exhibit 2

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Rebecca R. Pallmeyer on 10/26/2023. Mailed notice.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for leave to file under seal [3] is granted. Plaintiff's ex parte motion for entry of temporary restraining order, including a temporary injunction [13] is granted. Plaintiff's motion for electronic service of process [18] is granted. Mailed notice.

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 $ 50,000 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

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

(Declaration of Justin T. Joseph)

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Ex Parte Motion to extend the temporary restraining order 24 is granted. Order to enter. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 11/6/2023. 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

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction[29]

Declaration of Justin T. Joseph

Exhibit 1

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/20/2023, answer due 12/11/2023.

Declaration of Trevor C. Talhami

Exhibit A

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Motion for entry of a preliminary injunction 29 is granted. Order to enter. The Law Firm of Greer, Burns & Crain, Ltd. is ordered to add all defendant names listed in 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.

NEW PARTIES: Shenzhen Kuriharden Trading Co., Ltd., Fashion Hot Stamping Specialty Store, Fayshow88 Store, SHAYU06 Store, A10L19TM8GH8D8, A2QHWHPU6XSEF5, A3ND76RN88NKQV, AAUTOOKK, ANHMINIVA, Auto Rover, Casinlo, CHBDXD, DKeYe, enochrose, fuqingshihonglujiedaoxiaolonghuiriyongpinshanghang, G MIJIN STORE, Greenery Boutique, GTPASSRAY, hanyaozhongzhuoling, HaobinUS, Hiquashop, HuanChuoShangMao, Jim33Geoffrey, JinLinXi, LiaominyiUS, liuoxs, LORYVAN, mutong shop, Pcaron Direct, Qonyv, ruiruiqipu, shenzhenshiayunbaozhuangyouxiangongsi, shuquandianzishangwu, suizhoushicaomimaoyiyouxiangongsi, suizhoushigouqimaoyiyouxiangongsi, Sumaite, tuoruishanghang, vivicenter, wanghuonan123, WenBishengDHBSKFKHDJS, WindFee Inn, wuhunuanjieshangmaoyouxiangongsi, XingBoShangMao, xinjinquyoubailibianlidian, xuantong store, yafeidengzhoudianzixiaopu, YaojinUS, at-partaccforcarindustry, auto_wheel, bb2cshops, bing-7553, ck17753321220, comsu2005, gudexidianshang, hesol3966, iaxh31441_5, imcmers, infiniteinc_us, innertube, jetjeep, joyyear-auto, koreanpine, lim_mac, qihangmaoyi, shtdlsp-us, skycitys, thing-fast, top-carlights, ulpp1296, vbv9-26, wellharvestinternat0, yangke20020523, yydsca-0, zhurenshu, CC Art shop, shen zhen ou fei tong dian zi ji shu you xian gong si, 2124182259, Goodyouufenxdian, lihongying147, Milan shoes, TLBSS and wuyuqing4932 added to case caption. (Text entry; no document attached.)

PRELIMINARY INJUNCTION Order signed by the Honorable Rebecca R. Pallmeyer on 11/21/2023. 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[36]

Exhibit 1

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

Exhibit 1

ATTORNEY Appearance for Defendant enochrose by Christopher Paul Keleher

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

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion of Defendant enochrose for extension of time to answer or otherwise plead [40] is granted. Defendant enochrose to respond to Plaintiff's complaint on or before January 4, 2024. Mailed notice.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/28/2023: Mailed notice.

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

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

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Motion for entry of default and default judgment as to all remaining defendants 36 is granted. Order to enter. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 2/1/2024. Mailed notice.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 46 in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 46 in the amount of $500,000 as to certain defendant