2025-cv-04891

COMPLAINT filed by General Motors LLC; Filing fee $ 405, receipt number AILNDC-23437653.

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 Charles P. Kocoras. Designated as Magistrate Judge the Honorable Laura K. McNally. 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: Aotasi, GoVroom, HANNUO SHOP, Lemi Fruit, MAguangzhou, Phng maruti shop, TLCcollections, TownMotorDirect, tzw0920, Udjkasgn, VA StoreDaN, xiaolongwujindian, automaticity6644, cyio5774, himinze, tigerrrauto, yzai57, zhaocai, AA BLFeng, AllTMIN, ALMIN, Andreas home, AQWERFAA, baokuanfa, big edgy cloest, biyiban, BJKGUYFGJG, Black whale A, blankethome, BTQIJJHKK, CACshop, CBACBA, ChenChenArt, ChicThreadsss, ChicWave Cup, Cool Wall Decor, CUSTOMIZE YOUR OWN TEE, Delta Saint, Different clothing, DIY personalize custom made local, donggaowang, DUIOJQMA, Eiiwaa, ERIES, Factoryss, Fashion Forge C, FreshFit, FZAishirt, garment home, Good luck station, HARBOR CHIC TWO, Hat Hive, Hello friend E, Hero AA, HYXMPQHLL, HYXPOIUYY, HZCar, JUNGUIKONG and yulinl 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 General Motors LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by General Motors LLC in support of motion for temporary restraining order[13]

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

DECLARATION of Andrea Ankawi regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiff General Motors LLC Exhibit 2 Parts 1-2 regarding declaration[16]

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[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 leave to file[3], motion for temporary restraining order[13], motion for miscellaneous relief[18] before Honorable Charles P. Kocoras on 5/13/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal 3, motion for a temporary restraining order 13 and motion for electronic service of process 18 are granted. Enter Temporary Restraining Order. Presentment hearing scheduled for 5/13/2025 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 5/7/2025.Mailed notice.

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

Registry Deposit Information Form by General Motors LLC

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

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Robert W. Gettleman for all further proceedings pursuant to IOP13(f)(1). Honorable Charles P. Kocoras no longer assigned to the case. Signed by Honorable Charles P. Kocoras on 5/12/25.

ATTORNEY Appearance for Defendant cotether by Steven G Kalberg

SURETY BOND in the amount of $ 10,000.00 posted by General Motors LLC

EXECUTIVE COMMITTEE ORDER: IT APPEARING THAT, due to a clerical error case 25-cv-4891, General Motors LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A, was assigned in error to the Honorable Robert W. Gettleman pursuant to 28 USC 294 (b), therefore IT IS HEREBY ORDERED that the assignment of 25-cv-4891, General Motors LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A, to the Honorable Robert W. Gettleman be vacated as the assigned judge and the case shall be reassigned by lot to a regular active district judge. Case reassigned to the Honorable John F. Kness for all further proceedings. Honorable Robert W. Gettleman no longer assigned to the case. Signed by Executive Committee on 5/15/2025.

MOTION by Plaintiff General Motors LLC for extension of time of Temporary Restraining Order

MEMORANDUM by General Motors LLC in support of extension of time 30

DECLARATION of Marcella D. Slay regarding memorandum in support of motion 31

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for an extension of the TRO entered by the previously-assigned judge is granted for the reasons provided earlier [22] [23]. The case is otherwise stayed to permit this court the opportunity to to reassess its previous approach in so-called "Schedule A" litigation involving Lanham Act, Copyright Act, and Patent Act claims. Mailed notice.

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MOTION by Plaintiff General Motors LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by General Motors LLC in support of motion for preliminary injunction 36

(Declaration of Marcella D. Slay)

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/30/2025, answer due 6/20/2025.

Declaration of Lucas A. Peterson

(Exhibit A)

MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion [36] for entry of a preliminary injunction. In connection with that motion, which is entered and continued, Plaintiff must forthwith serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects on or before 6/11/2025." Plaintiff must file proof of service of the Court's statement within two business days of service. For the reasons stated in the Court's order's entering and extending the temporary restraining order ("TRO"), as well as in Plaintiff's motion [30] [31] to extend the TRO, the TRO is further extended to and including the date on which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff General Motors LLC regarding order on motion for preliminary injunction, text entry, [39]

Exhibit A

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MOTION by Defendant cotether to Modify the Briefing Schedule of Plaintiff's Motion for Entry of a Preliminary Injunction (Unopposed)

MINUTE entry before the Honorable John F. Kness: Defendant's Unopposed Motion to Modify the Briefing Schedule of Plaintiff's Motion for Entry of a Preliminary Injunction [42] is granted. Mailed notice.

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MOTION by Defendant cotether for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MEMORANDUM by cotether in Opposition to motion for preliminary injunction[36]

Exhibit List

Declaration of Wuqiang Zhang

Exhibit 1 cotether Accused Sales

Exhibit 2 cotether Restrained Balance

Exhibit A cotether Accused Product

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MINUTE entry before the Honorable John F. Kness: Defendant No. 3 cotether's unopposed motion for extension of time [45] is granted. Mailed notice.

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for a preliminary injunction [45] is granted. Enter separate preliminary injunction order. Plaintiff's filings establish that Plaintiff has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit or infringing goods. Plaintiff has also certified and established [38] [40] that it provided electronic notice to Defendants of the pendency of this case and provided a link to a website containing relevant case documents, but, despite the Court having provided [39] the opportunity to do so, no Defendant has objected to the motion for a preliminary injunction. Plaintiff's counsel is directed to ensure that all Defendants listed on Schedule A are added to the docket within five business days. The Clerk is directed to unseal any and all previously-sealed documents. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable John F. Kness on 6/30/2025. Mailed notice.

NOTICE of Voluntary Dismissal by General Motors LLC as to a certain Defendant

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all remaining Defendants

Exhibit A

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment[54]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[55]

Exhibit 1

ORDER: Plaintiff's motion for entry of default [54] is granted. Civil case terminated. Signed by the Honorable John F. Kness on 7/16/2025. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable John F. Kness on 7/16/2025. The ten-thousand-dollar ($10,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Mailed notice.

FULL SATISFACTION of Judgment regarding order, [58] in the amount of $100,000 as to certain defendant