2025-cv-04314

COMPLAINT filed by FCA US LLC ; Filing fee $ 405, receipt number AILNDC-23374481.

Exhibit 1

SEALED EXHIBIT by Plaintiff FCA US LLC Schedule A regarding complaint[1]

MOTION by Plaintiff FCA US LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FCA US LLC

Notice of Claims Involving Trademarks by FCA US LLC

ATTORNEY Appearance for Plaintiff FCA US LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff FCA US LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff FCA US LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Plaintiff FCA US LLC by Hannah Alexa Abes

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

BOND in the amount of $ 10000.0 Receipt no 100020405 check posted by FCA US LLC

NEW PARTIES: Guangzhou Chuangling Automotive Products Co., Ltd., Xianghe Mide Auto Parts Sales Office, aitewen, JiaHuanZhiCheng, Jiningfushengdianzi, Mulai2025, NingXiaWangZhongWangCanYinGuanLiYouXianGongSi, TeeFrontier, VA Store$$, ACapArt, aiefzgq25, ameiz5w, astheparts, aurum.jin, AutoSpark Shop, BessLove, car-light-us99, chuhe_67, CIFbuy.b2c, daimautoos, diguw36, dsport-grill, east-auto, factoryshop.outlets, gkhhp_888, goldengu-13, goldengu-5, HealthHa, Hopenj, jian_1181, jianhui li-0, jingwang8889, jwvj7086, klkecom, lili zhu25, lixiangdong-8, llllenmon, magic-space, niujjjng, paradizen, qingjie wang, RemadeUS, RW-Auto, shanliang10, StarCBY_Auto, taillight-genuine, The king of auto parts, tianxiawuzeial, tomatooauto, vicostudio, wei xu, xiao sui12, xuemeliiu, yanxi zhang, yewei lin, yifang jiang, Art plaques ART, CapsDealArt, Clear dayss, CooTeen, copter, DeRYcDOp, DIY Sub Gift, diycondb, Eccentric Era E, FISHh SHOP, GentsGraffitiGarb, HILLSSEE I, HKNORMALSIZE, iF Mens studio, Ilsird, Kawaii Cup Land, little tropical rainforest local, Lycestyle, MSJIHAUED, Nice paiting, Nouveau Nook N, Orca Cup, Pinnacle Menswear a, Seven Hour Studio, Street Vibe Wear, StreetStyleStorm, TI Color Bloom Studio, Tin XJ, TrendTrove cup, TrueStyle Men, xinyaohuaguangC, YIBAOT, yilushunfashop and YUDANSD added to case caption.

MOTION by Plaintiff FCA US LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by FCA US LLC in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-2 regarding declaration 16

Exhibit 2-1

(Exhibit 2-2)

MOTION by Plaintiff FCA US LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by FCA US LLC in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

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 5/21/2025 at 9:00 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 5/21/2025. 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 2 - Parts 1-2 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 A.M. on 5/21/2025 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 6/4/2025 at 9:15 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 5/21/2025. Mailed notice

Registry Deposit Information Form by FCA US LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff FCA US LLC

SUMMONS Issued (Court Participant) as to Defendant Guangzhou Chuangling Automotive Products Co., Ltd. and all other Defendants identified in the Complaint

MOTION by Plaintiff FCA US LLC for extension of time of Temporary Restraining Order

MEMORANDUM by FCA US LLC in support of extension of time[27]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[28]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend temporary restraining order [27] is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 6/18/2025. Telephonic status hearing set for 6/4/2025 is stricken and reset for 6/18/2025 at 9:00 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 (888) 557-8511 and the access code is 3547847. 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 FCA US LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction 31

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion 32

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/6/2025, answer due 6/27/2025.

Declaration of Hannah A. Abes

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/18/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [31] is granted. Enter Preliminary Injunction Order. Plaintiff's anticipated motion for default and default judgment shall include a spreadsheet that identifies up-to-date information on the amounts that are being restrained for each of the remaining defendants. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint [2], (2) Exhibit 2 - Parts 1-2 [17], and (3) the sealed temporary restraining order [23]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 7/17/2025 at 9:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 6/18/2025. Mailed notice

ATTORNEY Appearance for Defendants iF Mens studio, little tropical rainforest local by Yan Zong

ATTORNEY Appearance for Defendants iF Mens studio, little tropical rainforest local by Mary Catherine Merz

MOTION by Defendants iF Mens studio, little tropical rainforest local for extension of time to file answer

Appendix L3.2 Disclosure Statement

(Appendix L3.2 Disclosure Statement)

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

MOTION by Plaintiff FCA US LLC for entry of default, MOTION by Plaintiff FCA US LLC for default judgment as to all Defendants with the exception of certain Defendants

(Exhibit A)

MEMORANDUM by FCA US LLC in support of motion for entry of default, motion for default judgment, 41

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 42

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Andrea R. Wood: Defendants iF Mens studio and little tropical rainforest local's motion for an extension of time to file answer or otherwise respond to Plaintiff's complaint 39 is granted. Those Defendants shall answer or otherwise respond to the complaint by 7/28/2025. Plaintiff's motion for entry of default and default judgment as to certain Defendants 41 will be heard at the telephonic hearing set for 7/17/2025 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. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 FCA US LLC as to certain defendants

ATTORNEY Appearance for Defendants DIY Sub Gift, Orca Cup by Adam Edward Urbanczyk

MOTION by Defendants DIY Sub Gift, Orca Cup for extension of time

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/17/2025. For the reasons stated on the record, the Court enters Rule 55(a) default against the remaining defendants who have not appeared. Plaintiff's motion for default judgment as to certain Defendants [41] is taken under advisement. Defendants DIY Sub Gift and Orca Cup's motion for extension of time [47] is granted. Defendants DIY Sub Gift and Orca Cup shall answer or otherwise respond to the complaint by 8/6/2025. Telephonic status hearing set for 8/7/2025 at 10:30 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 FCA US LLC as to certain defendant

ANSWER to Complaint by iF Mens studio

ANSWER to Complaint by little tropical rainforest local

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

MOTION by Defendants DIY Sub Gift, Orca Cup for extension of time UNOPPOSED

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/7/2025. As stated on the record, Defendants DIY Sub Gift and Orca Cup's unopposed motion for extension of time [53] is granted. Those Defendant shall answer or otherwise respond to the complaint by 8/27/2025. By 8/14/2025, Plaintiff and Defendants iF Mens studio and little tropical rainforest local shall file a joint status report setting forth: (1) a proposed discovery schedule; (2) the parties' views regarding prospects for settlement and whether they request a referral to the magistrate judge for a settlement conference; and (3) any other matters the parties feel it would be helpful to discuss with the Court at the next telephonic status hearing. Telephonic status hearing set for 9/3/2025 at 10:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 Defendant Ilsird by Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ilsird

MOTION by Defendant Ilsird for extension of time to file answer regarding complaint[1]

MOTION by Plaintiff FCA US LLC to stay Deadlines and Notice of Settlement (Joint)

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

MINUTE entry before the Honorable Andrea R. Wood: Defendant Ilsird's motion for extension of time to answer 57 is granted. Defendant Ilsird shall answer or otherwise respond to Plaintiff's complaint by 8/28/2025. Additionally, Plaintiff and Defendants iF Mens studio and little tropical rainforest local's joint motion to stay deadlines and notice of settlement 58 is granted. Telephonic status hearing set for 9/3/2025 at 10:15 AM remains firm. Mailed notice

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendant

STIPULATION of Dismissal (Joint)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 9/3/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment as to certain Defendants [41] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 9/4/2025. Mailed notice