2025-cv-04720

COMPLAINT filed by General Motors LLC; Filing fee $ 405, receipt number AILNDC-23418356.

Exhibit 1

SEALED EXHIBIT by Plaintiff General Motors LLC Schedule A regarding complaint[1]

MOTION by Plaintiff General Motors LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by General Motors LLC

Notice of Claims Involving Trademarks by General Motors LLC

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff General Motors LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff General Motors LLC by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff General Motors LLC by Lucas Allen Peterson

CASE ASSIGNED to the Honorable Sunil R. Harjani. 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.

AMENDED complaint by General Motors LLC against zhidi-9028, the Individuals and Entities Operating zhidi-9028 and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

(Exhibit 3)

EXHIBIT by Plaintiff General Motors LLC Amended Schedule A regarding amended complaint, 11

MINUTE entry before the Honorable Sunil R. Harjani: By 5/23/2025, Plaintiff shall file a status report with an update on the case. Mailed notice

MOTION by Plaintiff General Motors LLC for discovery Expedited

Exhibit 1

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

MEMORANDUM by General Motors LLC in support of motion for miscellaneous relief[15]

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

STATUS Report Pursuant to 13 by General Motors LLC

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's ex parte motion for leave to conduct expedited discovery 14 and electronic service of process 15 are granted as to Defendant No. 1 in Amended Schedule A. Plaintiff's motion for leave to file under seal 3 is granted. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendant. Expedited discovery is warranted to identify the individuals or business entities who own and/or operate the e-commerce store under the seller alias, the nature of their operations, all associated sales, and the financial accounts used for their operations. By 7/15/2025, Plaintiff shall file a status report with an update on the case. Telephone status hearing is set for 7/22/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

ORDER Signed by the Honorable Sunil R. Harjani on 6/3/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) zhidi-9028 and the Individuals and Entities Operating zhidi-9028 by Plaintiff General Motors LLC

SUMMONS Issued (Court Participant) as to Defendants zhidi-9028 and the Individuals and Entities Operating zhidi-9028

SUMMONS Returned Executed by General Motors LLC as to the Individuals and Entities Operating zhidi-9028 on 6/11/2025, answer due 7/2/2025; zhidi-9028 on 6/11/2025, answer due 7/2/2025.

Declaration of Lucas A. Peterson

(Exhibit A)

MINUTE entry before the Honorable Sunil R. Harjani: Summons was issued on 6/3/2025, and Defendants' responses to the complaint are due by 7/2/2025. Plaintiff should file any motion for entry of default and default judgment by 7/16/2025. If there are any remaining defendants whom default and default judgment are not being sought, Plaintiff is ordered to file a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. A telephone status hearing is set for 7/23/2025 at 9:15 a.m. Status report due by 7/15/2025 and status hearing set for 7/22/2025 are stricken. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to Defendants zhidi-9028 and the Individuals and Entities Operating zhidi-9028

Exhibit A

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment, [25]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[26]

Exhibit 1

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is plaintiff's motion 25 for entry of default and default judgment against all remaining defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 7/16/2025. If no objections are filed by that date, the Court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by 7/16/2025. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. The telephone status hearing set for 7/23/2025 is converted to a tentative default judgment hearing. Mailed notice.

CERTIFICATE of Service by Plaintiff General Motors LLC regarding set deadlines, 28

(Exhibit A)

MINUTE entry before the Honorable Sunil R. Harjani: No remaining defendant has responded to plaintiff's motion for entry of default judgment. Accordingly, the motion [25] is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's marks irreparably harms plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $50,000 is an appropriate award of statutory damages. Plaintiff has also certified and established [29] that it provided electronic notice to defendants of the objection deadline, but no objection to the motion for entry of default judgment has been filed on behalf of any defendant. Because no default judgment hearing has been requested, the default judgment hearing tentatively set for 7/23/2025 is stricken. Enter separate Final Default Judgment Order. Civil case terminated. Mailed notice

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Sunil R. Harjani on 7/22/2025. Mailed notice