2025-cv-00117

2025-cv-00117 Toyota Motor Sales, U.S.A., Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :1/6/2025
Court :Northen District of Illinois
Law FirmGBC

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Date

Document

1

Jan. 6, 2025

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-22915032.

Exhibit 1

2

Jan. 6, 2025

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A regarding complaint[1]

3

Jan. 6, 2025

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for leave to file under seal

4

Jan. 6, 2025

CIVIL Cover Sheet

5

Jan. 6, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Toyota Motor Sales, U.S.A., Inc.

6

Jan. 6, 2025

Notice of Claims Involving Trademarks by Toyota Motor Sales, U.S.A., Inc.

7

Jan. 6, 2025

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin R. Gaudio

8

Jan. 6, 2025

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Amy Crout Ziegler

9

Jan. 6, 2025

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Trevor Christian Talhami

10

Jan. 6, 2025

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Lucas Allen Peterson

Jan. 6, 2025

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

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

NEW PARTIES: Foshan Shicheng Furniture Accessories Co., Ltd., Huizhou Yuekeda Technology Limited, Shenzhen Premium Promo Imp. & Exp. Co., Ltd., Wenzhou Xinxu Light Industry Co., Ltd., A3FNMQ3U1COER5, dongguandingzidianzikejiyouxiangongsi, guizhouqiaqiajinfuqiyeguanliyouxiangongsi, HusbandAndWife, STXDAUTO, 2023deyi10, automation-win, auto-parts-321, bella6800, biul6422, bright-auto-0, buwei315, caiyungun-888, CrossingIndustries, david-295, deals-plc, firs6633, fleaplc, GearIndustrial, Gray Wolf-parts, gszdhpf, hanparts, industrialpart88, jiakun-1688, jianfeng01, jiecana69, kuramaukdepot, Kxdstar, ldrdm54, long2-4591, MaticOEMmotor, mwkyyh273, onlinesupports, partshop15, q-6095, RevTek Auto, tobey-wait, Ushonorparts, wxiuli2012, xianyoushikaibe, AAPLZYNBLJ, aifashionmart, Billion Sell, Black horse costume a, BOY TWO, emoderns, Fashioner Style, Green Grass Pavilion, IKMENParts, Lion mens clothingo, Mr wardrobe M, Open field menswear, Rain Waters, Ruitai Small Shop, SayEL Clothing, Shopping harbor, Shulan studio, Strongest mens clothing factory, Sumatran Tiger, TOliu, Trend Mark, Trender Pub, Vogue Vanguard Shop, WDDBBHD, XY main line, LSC74 and ZXL89 added to case caption.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Plaintiff's Counsel, Justin R. Gaudio Greer at Law Firm, Burns & Crain Ltd., 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail #9589 0710 5270 0579 7806 83.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Plaintiff's Counsel, Justin R. Gaudio Greer at Law Firm, Burns & Crain Ltd., 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail #9589 0710 5270 0579 7806 83.

11

Jan. 7, 2025

MAILED trademark report to Patent Trademark Office, Alexandria VA.

12

Jan. 7, 2025

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

13

Jan. 9, 2025

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

14

Jan. 9, 2025

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for temporary restraining order 13

15

Jan. 9, 2025

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

16

Jan. 9, 2025

DECLARATION of Teena Bohi regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

17

Jan. 9, 2025

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 3 Parts 1-2 regarding declaration 16

Exhibit 3-1

(Exhibit 3-2)

18

Jan. 9, 2025

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

19

Jan. 9, 2025

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for miscellaneous relief 18

20

Jan. 9, 2025

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

21

Jan. 9, 2025

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 18, motion for leave to file 3, motion for temporary restraining order 13 before Honorable Elaine E. Bucklo on 1/15/2025 at 09:45 AM.

22

Jan. 15, 2025

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 3 ; Plaintiffs' Ex Parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 13 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 18 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 1/29/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 1/22/2025. 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 of the expiration of the TRO. 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. The case is set for a status hearing on 3/3/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 2/24/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

23

Jan. 15, 2025

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 1/15/2025. Mailed notice.

24

Jan. 22, 2025

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

25

Jan. 22, 2025

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

26

Jan. 22, 2025

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 25

27

Jan. 22, 2025

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time 24 before Honorable Elaine E. Bucklo on 1/29/2025 at 09:45 AM.

28

Jan. 22, 2025

Registry Deposit Information Form by Toyota Motor Sales, U.S.A., Inc.

30

Jan. 24, 2025

Surety BOND in the amount of $ 10,000 posted by Toyota Motor Sales, U.S.A., Inc.(Document not Imaged)

29

Jan. 28, 2025

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 24 is granted to 2/12/2025. Mailed notice.

31

Feb. 5, 2025

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction

(Exhibit A)

32

Feb. 5, 2025

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

33

Feb. 5, 2025

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 32

34

Feb. 5, 2025

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 31 before Honorable Elaine E. Bucklo on 2/12/2025 at 09:45 AM.

(Exhibit A)

35

Feb. 5, 2025

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/5/2025, answer due 2/26/2025.

Declaration of Lucas A. Peterson

(Exhibit A)

36

Feb. 13, 2025

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for entry of preliminary injunction 31 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint 2, Exhibit 3 to the Declaration of Teena Bohi 17, and the TRO 23 are unsealed. Mailed notice.

37

Feb. 13, 2025

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 2/13/2025. Mailed notice.

38

Feb. 20, 2025

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

39

Feb. 21, 2025

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Yu Hin Jeffrey Tsai (Tsai, Yu Hin)

40

Feb. 24, 2025

STATUS Report Pursuant to [22] by Toyota Motor Sales, U.S.A., Inc.

Exhibit A

41

Feb. 27, 2025

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

42

Feb. 27, 2025

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Thomas Joseph Juettner

43

Feb. 28, 2025

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

44

Feb. 28, 2025

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 Remaining Defendants

Exhibit A

45

Feb. 28, 2025

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment, [44]

Exhibit 1

46

Feb. 28, 2025

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

47

Feb. 28, 2025

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, [44] before Honorable Elaine E. Bucklo on 3/5/2025 at 09:45 AM.

Exhibit A

48

March 4, 2025

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment as to all remaining defendants [44] is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Toyota Motor Sales, U.S.A., Inc. or its counsel Greer Burns & Crain Ltd. Civil case terminated. Civil case terminated. Mailed notice.

49

March 4, 2025

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 3/4/2025. Mailed notice.

50

March 6, 2025

MAILED Closing Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Patent Minute Entry dated 3/4/2025)

51

March 13, 2025

FULL SATISFACTION of Judgment regarding order 49 in the amount of $100,000 as to certain defendants

52

March 13, 2025

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7806 83.

53

March 20, 2025

FULL SATISFACTION of Judgment regarding order 49 in the amount of $100,000 as to certain defendants

54

April 3, 2025

FULL SATISFACTION of Judgment regarding order 49 in the amount of $100,000 as to certain defendants

55

Aug. 29, 2025

FULL SATISFACTION of Judgment regarding order[49] in the amount of $100,000 as to certain defendant

56

Sept. 4, 2025

FULL SATISFACTION of Judgment regarding order[49] in the amount of $100,000.00 as to a certain Defendant

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