2025-cv-04029

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-23345680.

(Exhibit 1)

SCHEDULE A by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A regarding complaint 1 Modified on 5/12/2025.

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 Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Young B. Kim. 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: butnet, likaiping, Marygenns, MENGHUAMAN, PARTEN, xianduoyudianzikejiyouxianzerengongsi, ZCX BATTERY, zhouxiaolong01qwq, AAA Car Parts Shop, abboss-is, Affordable PLC module store, ApexCrafts, ApexCraftss, Auto Parts Club123, Automation-electrical, AutoVenture-Mart, autwaus, Boutique Home Gardening, buwei318, car-light-store, chexiqiang, Cloudwave, fabrication-plc, FIFTTINGS-GARDEN-MALL, FOGUANG, gexin-61, GG AUTO PARTS LLC, hcautopartsllc, hiji-9952, HLH auto parts, ieast825, Indicators-system, Industrial automation distributor, industryplc-2008, Invincible auto parts shop, jianqing lu, jingyun-5, jinlink, jinning03-w, King Kong auto parts Shop, Lucky Cat Curiosities, Lumen, luokeshangmaoyouxiangongsi, Lxiu-Auto parts decoration store, marshmary2008, maseratipartlsllc, mcparkersu, ming yang123, Modular Fitting, Performance Auto Parts llc, piti8_14, PLCmodulecontroller mall, PLP_Control Equipment Mall, Prime-Autocomponents, qiyangshiziwansha0, quattroporoteautoparts, ronghao dong, shopmallht, star-lucky_autoparts, Swift-Deals-UP, topnice666, TOYOTA AUTO LLC, Wilie-parts, WJK auto parts, xiuping-12, yuhan zeng, BINGJIAMAOYISHANGHANG, CaiLinCen, huangdongying, InnoWorks Manufacturing, Jinrongyi, Pioneer Productions Factory, qiuchensho, shadeful cap, SHAUYJCQ, SHUAHSJCH, Top Hat Design, XQCIBUBY, BeautySmailStore, ElectroHub, Perzoly, Sportify Your Life and TINYPONY added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 to the Declaration of Teena Bohi Parts 1 - 2 by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 2 - Parts 1-2 regarding declaration 16 Modified on 5/12/2025.

Exhibit 2-1

(Exhibit 2-2)

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 13, motion for miscellaneous relief 18, motion for leave to file 3 before Honorable Jorge L. Alonso on 4/22/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 3 13 18 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discoveryis warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $83,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 4/22/25 is stricken. Notice mailed by Judge's staff

TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 4/21/2025. Notice mailed by Judge's staff Modified on 5/12/2025.

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

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

SURETY BOND in the amount of $ 83,000.00 posted by Toyota Motor Sales, U.S.A., Inc. (Document not imaged)

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 28

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 29

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time 28 before Honorable Jorge L. Alonso on 5/1/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order 28 is granted. The temporary restraining order is extended for 14 days to 5/19/25. Motion hearing date of 5/1/25 is stricken. Notice mailed by Judge's staff

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 33

(Declaration of Trevor C. Talhami)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 33 before Honorable Jorge L. Alonso on 5/8/2025 at 09:30 AM.

(Exhibit A)

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

Declaration of Thomas J. Juettner

(Exhibit A)

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

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction 33 is granted. Enter Preliminary injunction order. 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 at www.ilnd.uscourts.gov. Telephonic status hearing set for 6/10/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 5/8/2025. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. (Corrected) Signed by the Honorable Jorge L. Alonso on 5/9/2025. Notice mailed by Judge's staff

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

(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

Exhibit 2-1

(Exhibit 2-2)

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

(Exhibit 1)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, 43 before Honorable Jorge L. Alonso on 6/3/2025 at 09:30 AM.

(Exhibit A)

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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants [43] is granted. Enter Final Default Judgment Order. Status hearing previously set for 6/10/25 is stricken. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/3/2025. Notice mailed by Judge's staff

MAILED trademark report with certified copy of minute order dated to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendants

NOTICE of withdrawal of bond 27 by John Summerfield.