2025-cv-00932

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-23009303.

(Exhibit 1)

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 Trevor Christian Talhami

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

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Maria Valdez. 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.

NEW PARTIES: Dongguan Hui Sui Jewelry Co., Ltd., AYEIBKU8WJSO2, chaolili shop, Katorn-US, Liqingfeng123, NingtaiBeiMei, amkerda, AutoFashionista, beautmei1, breeze-online, brightlyauto, CarDecalBest, CARSAUTOPARTS, chengaoshop, citicelectronic, CL-Repair Parts, DaBrightAuto, DazzleAuto, elova-parts, evasnuk, f14chuanglin2023, fjy19-33, gadgett_uk, gf5689er, HENZIKON AUTO PARTS, HL-Repair Parts, industrialparts-stor, JazzCar, jiu903, kunminggaoremiaosh0, mowerparts24, OE PARTS LLC, paddie-auto, pioneerx, relang34717, sevengdstore, sunday_83, SunshineMOWER, toyotaautopartsllc, vehicleelegance, XH parts shop, zhj916, Allure Apparel, AMEEL, ARCTERYX ACADEMY, Arixmed, BAMELIAHFE, CottonCraft, DEFU sticker, enjoy your shirt, FancyMM, Fovlrclh mens clothing, Green Maple Leafs, HipsterFactory, Infinity Auto Parts, JayusTee, Lampard shop, LOKEFN, LoKin, Lovely Girl Sop, maizisanhao, Meadow Makers, MenQzdWear, Mike Fashion Clothess, MKKEFGU, okay shops, Pink Freesia, PinnacleShirts, PMGHWN, Potees, QIMI EE, Qukteparts, QXDDBFF, SANSSE, Solar Steed, Tshirt Explorer, VividWears, wdexian, Winter begins, WONDERGIFT, ZephyrTee, ZephyrTee (1), Auto Parts Store, CozyNestShop, hongruibang, shunquan fu, TAIFU DE SHOP, tanqianhe and Yazstars added to case caption.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Andrea R. Wood for all further proceedings pursuant to 28 USC 294(b). Mailed notice

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

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 1-3 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

(Exhibit 3-3)

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

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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 3/4/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/4/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A regarding complaint [2], and (2) Exhibit 3 Parts 1-3 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:45 a.m. on 3/4/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 3/18/2025 at 10:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 3/4/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Toyota Motor Sales, U.S.A., Inc.

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

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

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 29

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 30

SURETY BOND in the amount of $ 10,000.00 posted by Toyota Motor Sales, U.S.A., Inc.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order [29] is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 4/1/2025. Telephonic status hearing set for 3/18/2025 is stricken and reset for 4/1/2025 at 10:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

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[34]

Declaration of Trevor C. Talhami

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

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/18/2025, answer due 4/8/2025.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction 34 will be heard at the telephonic hearing set for 4/1/2025 at 10:30 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Rachel S Miller

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 4/1/2025. Telephonic motion hearing held on 4/1/2025. As stated on the record, Plaintiff's motion for preliminary injunction [34] is granted. Telephone status hearing is set for 5/15/2025 at 9:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Andrea R. Wood on 4/1/2025. 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 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[43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [43] will be heard at the telephonic hearing set for 5/15/2025 at 9:15 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. 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

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/15/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [43] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 5/21/2025. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 52 in the amount of $500,000 as to certain defendant