2025-cv-02577

COMPLAINT filed by National Association for Stock Car Auto Racing, LLC; Filing fee $ 405, receipt number AILNDC-23196699.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff National Association for Stock Car Auto Racing, LLC Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Christopher Romero

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Monica Rita Martin

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff National Association for Stock Car Auto Racing, LLC by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by National Association for Stock Car Auto Racing, LLC

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable M. David Weisman. 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: 33uoii, Aimaruiwal, Alex Group, angyang1, AOC ORGANIC VIETNAM COMPANY LIMITED, asafafdsgs, AYUS SHOP, Bathtub and shower, BestieGifts, BFYSFBAIG, bikaidianzimaoyi, bppmkin, BYwenjv, CaoMeiJianJian, CCH, CFJKF, changshashibiankai, Chbrstore, Chen Fangfang Toys, CHEXPEL, Clearance-HIBRO, Dengyli, Diansi, DIEU KHANG LTD, Diling, Din699h, DSXenun, DYWADE, FAN XI, Fashionab, flameee, Funny Kitty Shirts, funnytoylimited, GARENAS, gdfgdvc, GGofunny, GTYYNNMTTG and GuangZhou xiangbeiankejiyouxiangongsi added to case caption.

NEW PARTIES: guangzhoujinchenghongmaoyiyouxiangongsi, guangzhouruixinyikejiyouxiangongsi, guangzhouyurenlimaoyiyouxiangongsi, GUIhp, GuoLiangyong254, GUYUIIEI, hainanbaichuandongdaohai, hanghairenrenzhishi, HASUN VN LTD, HAZOEDPRIN, hefumensh, HITAEEAI, huachenyuexikeji, huayue, huizhoushihuajingshengkeji, HWTuang, Interesting DIY, invdc, JEYXGSQ, JianLog, jiezaoshumaoyi, Jingxiu, jinyuanfu, JINZHAOYOUJIU, JPGIF, jungdeepe, Juqian Store, KIM TA LTD, KKFF, kuangyao, lafuge, LanBenQ, lijinqingqw, LilyDiyShirt and Lisaac added to case caption.

NEW PARTIES: little home, LiuLiuMaoYi, lmmilan, LUODU, Lux Outlet Store, LuZiMaoRn, LYBALYBO, LYs store, MengJing, Mieusa, MINGS, Minsida, Mirthy Merch, MLFoif, MOGjc, MQjiaju, MtsDJSKF, MUYAN, nanyuezhipin, NITA, Opulent Odyssey, peixiaodianzishangwu, Posh Palette, PQBWAFI, puchongmaoyi, PUISBXS, PuTianShiLiChengQuXiTaDa, qingfengxulaidianzishangwu, qizhihua, QuanHanJi, quanzhouxizhengshangmaoyouxiangongsi, Retro Rhythms, SAKIOIOU, SANG NHANG LTD, Sengyong, shanghaiweiyoucaimaoyiyouxiangongsi, shanghaiyuxinqiye, shanghaizhongshushiye, shenzhenshimingchengleikeji, shenzhenshimuyunkejiyouxiangongsi, shenzhenshiyachengjinghua, SHNKGYL, SHongao, SHPENGMEI, shunfa, SHUNYIKEJI, SHXDSXX, SMOO FASHLOVE, Suave Tees and Suonuo added to case caption.

NEW PARTIES: 33uoii, Aimaruiwal, Alex Group, angyang1, AOC ORGANIC VIETNAM COMPANY LIMITED, asafafdsgs, AYUS SHOP, Bathtub and shower, BestieGifts, BFYSFBAIG, bikaidianzimaoyi, bppmkin, BYwenjv, CaoMeiJianJian, CCH, CFJKF, changshashibiankai, Chbrstore, Chen Fangfang Toys, CHEXPEL, Clearance-HIBRO, Dengyli, Diansi, DIEU KHANG LTD, Diling, Din699h, DSXenun, DYWADE, FAN XI, Fashionab, flameee, Funny Kitty Shirts, funnytoylimited, GARENAS, gdfgdvc, GGofunny, GTYYNNMTTG and GuangZhou xiangbeiankejiyouxiangongsi added to case caption.

NEW PARTIES: TAIANST, Tailored Trends, TAM AN LTD, Thenews, Three grass trade, ThusFar Store, TINGTINGSFAAR, UEBXS, UrbanElegance yu, Vivay, Vogue Vestige, wei yi, WEIQIER, Wenwu, WHBanen, WHDen, Wonderful Bazaar, WoXShop, WTGERcdsfv, wujiaxinjiaxs, WULANLA, Xiamen MaifengfengMaoyi Youxiangongsi, xiamenluochuangkejiyouxiangongsi, xiamenmindongsemaoyiyouxiangongsi and xiamensongbiaomaoyiyouxiangongsi added to case caption.

NEW PARTIES: xiamenyihecaimaoyiyouxiangongsi, xiangtangongxi, Xiangyi Trading, Xiasspert, Xiheng Street, xinbomaoyi, Xindingxi, Xinduolei Fashion Center, Xiujin, xiuyinxiamenxinxikejiyouxiangongsi, XJJinin, XMLAFMY, XMTAIMO, XMXLYX, XMZHIZI, Xuwuluo E-Commerce Co., Ltd., YaErRui, Yangli, yanpeishangmao, YinFengBeauty, yingxinizhinengjiaju, yiqineng, YMBeeio, yongganniuniuwenhuakeji, yrycsq, Yuxi Store, Zardenal, Zeqouiuo, Zhang Culvert Toys, ZhangFengShan, zhanglicaiwudi, Zhangpiled dress, zhangping, zhangyuankeji, Zhaolaibao Store, zhengshijia, ZjjPlus, Zjurshop, ZRAKCHER, ZXCMnby, ZXCouiao, Zyuis, ZZF-DIY, Defendant 4 and Defendant 23 added to case caption.

MAILED the One Hundred Ninety-Three Thousand Dollar ($193,000) surety bond posted by NASCAR to its counsel, Keith A. Vogt at Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W, Chicago, Illinois, 60604 via certified mail #7001 2510 0005 7681 7273.

MOTION by Plaintiff National Association for Stock Car Auto Racing, LLC for leave to file under seal

MOTION by Plaintiff National Association for Stock Car Auto Racing, LLC for leave to file excess pages

MEMORANDUM in Support of [14] Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Megan Malayter

Exhibit 1, of Megan Malayter's Declaration

SEALED EXHIBIT by Plaintiff National Association for Stock Car Auto Racing, LLC Sealed Exhibit 2, Declaration of Megan Malayter regarding memorandum in support of motion, [15]

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and or electronic publication [14] is granted. Plaintiff's motion for leave to file under seal [12] and motion for leave to file excess pages [13] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 4/2/2025.

SUMMONS Submitted (Court Participant) for defendant(s) 33uoii and all other defendants identified in the Complaint by Plaintiff National Association for Stock Car Auto Racing, LLC

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

MOTION by Plaintiff National Association for Stock Car Auto Racing, LLC for preliminary injunction

MEMORANDUM by National Association for Stock Car Auto Racing, LLC in support of motion for preliminary injunction[23]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's Declaration

SUMMONS Returned Executed by National Association for Stock Car Auto Racing, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/9/2025, answer due 4/30/2025.

Declaration of Service

INJUNCTION BOND in the amount of $193,000 posted by National Association for Stock Car Auto Racing, LLC (Document not scanned).

MINUTE entry before the Honorable Mary M. Rowland: Any response to motion for preliminary injunction 23 due 4/24/25. Status report due 5/1/2025. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MOTION by Plaintiff National Association for Stock Car Auto Racing, LLC for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by National Association for Stock Car Auto Racing, LLC in support of motion for default judgment[29]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

STATUS Report by National Association for Stock Car Auto Racing, LLC

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 31. Without objection, the motion for preliminary injunction 23 is granted. Enter Preliminary Injunction Order. Any response to the motion for default 29 is due 5/19/25. Status report due 5/27/25. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff is 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Mary M. Rowland on 5/2/2025. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 75 Lisaac

MINUTE entry before the Honorable Mary M. Rowland: Response to Plaintiff's motion for default judgment 29 due 6/6/25. Status report due 6/16/25. Mailed notice.

STATUS Report Pursuant to [35] by National Association for Stock Car Auto Racing, LLC

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report. [35]. No defendant has responded to Plaintiff's motion for default. [29]. Motion for default is granted. Enter Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 6/10/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: The One Hundred Ninety-Three Thousand Dollar ($193,000) surety bond posted by NASCAR is hereby released to NASCAR or its counsel, Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W, Chicago, Illinois, 60604. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to NASCAR or its counsel. Mailed notice.

MAILED final trademark report with a copy of minute entry 37 and default judgment order 38 to Patent Trademark Office, Alexandria VA