2025-cv-03173

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 405, receipt number AILNDC-23257787.

Exhibit 1

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

Notice of Claims Involving Trademarks by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Lucas Allen Peterson

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.

AMENDED complaint by Harley-Davidson Motor Company, Inc. against KaiDaJianZhuGongCheng, the Individuals and Entities Operating KaiDaJianZhuGongCheng and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Amended Schedule A regarding amended complaint, [13]

Withdrawal of Motion [3] by Harley-Davidson Motor Company, Inc.

MINUTE entry before the Honorable Jeremy C. Daniel: Plaintiff's motion to seal 3 is withdrawn. Mailed notice.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Rachel Meira Ackerman

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for discovery (Expedited)

(Exhibit 1)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for miscellaneous relief 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

NOTICE of Motion by Justin R. Gaudio for presentment of motion for discovery 18, motion for miscellaneous relief 19 before Honorable Jeremy C. Daniel on 6/24/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: The plaintiff's motion for expedited discovery [18] is granted as follows: the plaintiff may serve third-party Amazon with a subpoena seeking documents sufficient to identify the individuals and entities associated with the online marketplace identified in Schedule A, to include all names, addresses, telephone numbers, and email addresses associated with the online marketplace. The plaintiff's motion for electronic service of process [19] is denied without prejudice. At this point, the plaintiff does not know what identifying information the defendant provided to the third-party platform and only suspects that the defendant is located overseas. The Court sees no reason to allow the plaintiff's speculation to prevail when the plaintiff has discovery tools available to it that will allow it to answer some of those questions. The June 24, 2025, motion hearing is stricken. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: There is no indication that the plaintiff has served the defendant within 90 days of filing the complaint. See Fed. R. Civ. P. 4(m). Failure to serve the defendant and provide proof of service on or before July 31, 2024, will result in dismissal of the complaint. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: The order entered on 7/16/2025 [24] is amended as follows: Failure to serve the defendant and provide proof of service on or before July 31, 2025, will result in dismissal of the complaint. Other than the amendment stated, the order previously entered shall stand. Mailed notice.

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for miscellaneous relief[26]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[27]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[26] before Honorable Jeremy C. Daniel on 7/23/2025 at 09:30 AM.

Exhibit A

ORDER. Signed by the Honorable Jeremy C. Daniel on 7/21/2025. Plaintiff's motion for electronic service of process [26] is granted. The motion hearing is stricken. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) KaiDaJianZhuGongCheng and the Individuals and Entities Operating KaiDaJianZhuGongCheng by Plaintiff Harley-Davidson Motor Company, Inc.

SUMMONS Issued (Court Participant) as to Defendants KaiDaJianZhuGongCheng, the Individuals and Entities Operating KaiDaJianZhuGongCheng

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to KaiDaJianZhuGongCheng on 7/22/2025, answer due 8/12/2025; the Individuals and Entities Operating KaiDaJianZhuGongCheng on 7/22/2025, answer due 8/12/2025.

Declaration of Rachel M. Ackerman

Exhibit A

MINUTE entry before the Honorable Jeremy C. Daniel: Status hearing set for September 2, 2025, at 9:30 a.m. Mailed notice.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to Defendant KaiDaJianZhuGongCheng and the Individuals and Entities Operating KaiDaJianZhuGongCheng

MINUTE entry before the Honorable Jeremy C. Daniel: Pursuant to the Notice of Dismissal [35], this case is dismissed without prejudice. Civil case terminated. Mailed notice.

MAILED trademark report with order dated 8/27/2025 to Patent Trademark Office, Alexandria VA