2025-cv-02616

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-23200230.

Exhibit 1

(Exhibit 1)

Exhibit 2-1

Exhibit A

Declaration of Trevor C. Talhami

Declaration of Thomas J. Juettner

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit A

Exhibit A

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

Exhibit 2-2

Exhibit A

Exhibit B

Exhibit 2-1

Exhibit B

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

(Exhibit 2-3)

Exhibit 2-2

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 Thomas Joseph Juettner

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Maria Valdez. 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.)

NEW PARTIES: A1OCWYFM9NATBS, A2C8GWSOJ90W0O, A3HL1HH1C31WU8, Binhui, edgtrfhyb, FFKITCHEN, JMT-WM, Knomix, LOWEEY, meibo story buy, NanasayMall, Shenzhenshiguanfeimaoyiyouxiangingsi, SHINIANSHANGPU, TrdFrame, UPHTEH, XIANmeimeiYE, zhenhaimaoyiyouxiangongsi, 895iorejkgfuio, a611liujian70, alfabrakepads, ansders_auto, auto arts-Moti, beishenhuan-0, bestoparts, brilliant8888, caitlyn-auto, Car Attachment, CHANGXIAO1028, CHANGXIAO1120, CHANGXIAO1128, cletantan_999, clouxee, constant514, CrazyGolferr, dancemen, domestic5, dsharparts, Duckmm, elegant-475, Ella-in-japan, excellent005, fashion-mall, fcth-584087, hansanllc, hebkparts, HENZIKON AUTO PARTS (1), honbrieautos, hope-part, hs-autopart, httehllkk568, Ideal auto parts shop, Industrial Control Automation, Industrial Control PLC Supply Mall, Industrial control specialty store, inRobots_fanucparts, jgkfio89032, jkgfiore90, joyear-parts, karustoree, ktslater, kummpart, mh-us365, Missplc66 automated store, Module-Driver, pipeeautoss, postshow, qpjian, red Car modification badge shop, SAIWEITE SHOP, SalesAutomation, shangwuyouxiangongsi, speedp_19, suokai2024, superpartss, tairuispart, titan-story, WenT-0912, whosfactoryparts, xbmfbeauto, YLControl, yunhefly, yzx555, zhichunzunzhe11, zyyf1986, abkgabab, ANGPO, BeihanTshirt, BSDAACHA, ChangmingLY Trade, ChicTeeGent, Cxuehua, DABAOHTLA, DFFFSHOP, Elegance Vault, Graphic Grind, Hip hop brand, HSEGHS, Inspiration Storm, IRONMAM, JNBVD, ke ke dou, Milk Candy Queen, momoteee, Pings Tshirt Shop, Trend hat Customized, UGSLW, VIVITT, Walk By No Miss, weilongt, xindayue, YYTAT, zouxunyu, ZUIWANGA, ZUIWANGB, ZUIWANGC, ZUIWANGE, ZUIWANGH, ZUIWANGI, Junshangstars and JXSW-US added to case caption. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable John J. Tharp, Jr:By 3/20/2025, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. The plaintiff's motion for leave to file under seal [3] is granted. Schedule A to the complaint [2], filed provisionally under seal, is permitted to remain under seal. Mailed notice

RESPONSE by Plaintiff Toyota Motor Sales, U.S.A., Inc. to order on motion for leave to file, text entry, terminate motions, 13

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 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

DECLARATION of Teena Bohi regarding memorandum in support of motion 16

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 2 Parts 1-3 regarding declaration 18

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 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for a temporary restraining order 15 is taken under advisement. By 3/24/2025, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. The plaintiff's motion for electronic service of process 20 is granted. Mailed notice

SUPPLEMENT to motion for temporary restraining order[15] per [23]

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 1 Parts 1-3 regarding supplement[24]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [15] is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 3/25/2025. 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 (Court Participant) as to A1OCWYFM9NATBS and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 121,000 posted by Toyota Motor Sales, U.S.A., Inc. (Document not scanned).

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

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

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction[32]

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/3/2025, answer due 4/24/2025.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [31], and pursuant to Fed. R. Civ. P. 96, defendant no. 96 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [32] is taken under advisement. Any objection or response is due before 4/8/2025. Upon review of the certificate of service, the Court directs the plaintiff, by 4/6/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 4/8/2025. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by Plaintiff Toyota Motor Sales, U.S.A., Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, [36]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction 32 is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 4/14/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 4/9/2025. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 41, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 1, 6, 15, 86, 89, and 90 are dismissed from this case. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [43], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 25, 33, 36, 54, 80, 83, 94, 98, 101, 108, 109, 113, 114, 115, 116, 117, 118, and 119 are dismissed from this case.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 remaining Defendants

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment, [46]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[47]

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [46] is taken under advisement. Any objections or responses are due by 5/12/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 5/9/2025. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this Order, and containing a link to the updated website. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Minute entry [49] is corrected as follows: Plaintiff's motion for entry of default and default judgment [46] is taken under advisement. Any objections or responses are due by 5/12/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 5/2/2025. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this Order, and containing a link to the updated website.Mailed notice

CERTIFICATE of Service by Plaintiff Toyota Motor Sales, U.S.A., Inc. regarding text entry, [50]

ATTORNEY Appearance for Defendants Industrial Control Automation, Missplc66 automated store by Ni Xue

MOTION by Defendants Industrial Control Automation, Missplc66 automated store for extension of time to file answer

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Industrial Control Automation

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Missplc66 automated store

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

MINUTE entry before the Honorable John J. Tharp, Jr:The defendants Industrial Control Automation and Missplc66's motion for an extension of time to answer the plaintiff's complaint [53] is granted. The deadline for those defendants to answer is now 5/29/2025. Mailed notice

ATTORNEY Appearance for Defendants hebkparts, hs-autopart by Christopher Paul Keleher

MOTION by Defendants hebkparts, hs-autopart for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [56], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 21, 24, 37, 38, 47, 59, 61, 64, 65, 66, 74, 75, and 79 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant hebkparts and hs-autopart's motion for an extension of time to answer or otherwise respond to the complaint [59] is granted. The deadline for those defendants to answer or otherwise respond is now 5/29/2025. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defaulting defendant having objected, the plaintiff's motion for default judgment [46] is granted. Enter default judgment order as to defaulting defendants. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 5/13/2025. Mailed notice

FULL SATISFACTION of Judgment regarding order[63] in the amount of $250,000 as to certain defendant

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [64], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 9. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [65], and pursuant to Fed. R. Civ. P. 41(a)(1), defendant nos. 52 (Industrial Control Automation) and 63 (Missplc66 automated store) are dismissed from this case. Mailed notice

FULL SATISFACTION of Judgment regarding order[63] in the amount of $250,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [68], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 8. Mailed notice

ATTORNEY Appearance for Defendants Hip hop brand, SAIWEITE SHOP, SalesAutomation, WenT-0912, a611liujian70, elegant-475, hebkparts, hs-autopart, ktslater, speedp_19, weilongt, whosfactoryparts, yunhefly, 1128gregowiwjjs by Timothy Tiewei Wang

MOTION by Defendants 1128gregowiwjjs, Hip hop brand, SAIWEITE SHOP, SalesAutomation, WenT-0912, a611liujian70, elegant-475, hebkparts, hs-autopart, ktslater, speedp_19, weilongt, whosfactoryparts, yunhefly for extension of time to file answer regarding complaint[1] Unopposed

MINUTE entry before the Honorable John J. Tharp, Jr:The defendants' unopposed motion for an extension of time to answer or otherwise respond to the complaint [71] is granted. The deadline for those defendants to answer or otherwise respond to the complaint is now 6/12/2025. Mailed notice

FULL SATISFACTION of Judgment regarding order[63] in the amount of $250,000 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 Release of Bond

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 73, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant nos. 19, 30, 39, 60, 69, 70, 72, 77, 78, 81, 97, and 110. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 74, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 45 (hebkparts) and 49 (hs-autopart) are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:With all defendants having been dismissed or defaulted, this case is dismissed. All pending deadlines are stricken. The plaintiff's motion for release of bond 75 is granted. Enter disbursement order. Civil case terminated. Mailed notice

ORDER to Release Bond to Plaintiff signed by the Honorable John J. Tharp, Jr on 6/16/2025. Mailed notice