2025-cv-05862

COMPLAINT filed by FCA US LLC; Filing fee $ 405, receipt number AILNDC-23535555.

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

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Heather K. McShain. 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: Guangdong Pake Auto Parts Co., Ltd., Hubei Shiyan Pulijin Import And Export Trading Co., Ltd., Shandong Kayoudi International Trade Co., Ltd., Weifang Kairuisi Trading Co., Ltd., anqingruijundianzishangwuyouxiangongsi, FANGXH-USA, FirFiltr, GBYUEQIHANG, guangshuishikalumishangmaoyouxiangongs, haerbinbiwuxinxizixunyouxiangongsi, HongJiHao, Huilinkeji, HYLShop, Jason Wambolt, Jennifer p Leslie, JiangYanHui-us, JiZhongJia-us, kaihaixsing, lianyunganghaojunshumakejiyouxiangongsi, LiuHong-us, LiuYan-US, MaQing-us, rui da long, SeaVista, suizhoushipengchangshangmaoyouxiangongsi, Tucool Racing Store, Tvoip -us, VA StoreDNa, xiafafaf, ZhaoWeiLi-us, zhenxionglonglishangmaoyouxiangongsi, ZSS Direct, andromeda_parts, canauto_1, carstyle18, cwpengshop3, deepkeed, h67744li, Health Storer, horsemanauto, KAPAMZ, kummpart, LONGFLGHT, mingxuemotors, motoree, mushengyuandianzishangwu, oe-quality-autoparts-shop, patesparts, pinliang001, ProPartsMasters, Quebo-parts, romayu1, scorpius_parts, SpeadsStar-zone, starspeeed, topwave-v, union-all-day, winbruke, wondex-v, xj19950, Yu Neon, yy-motors, zenghaiping9, zhichunzunzhe11, A Money comes from the old shopkeeper, AmorousAttireHouse, DJINYYK, Grey humor, GUYBJJN skkaw cup, homgqinglong, Labworkparts, LOVE DIY ZHU, love mistakenly, petyeah, PyTX diy happy, StylishStitchers, TIM CAP, TrendAuraAA, UrbaneApparel, WaysleL, ComfyChillax, mskjstore, Rebel Gear, Unisex Mode and YiY-Enterprise added to case caption.

***Civil Case Terminated.

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

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]

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]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[18], motion for leave to file[3], motion for temporary restraining order[13] before Honorable Manish S. Shah on 6/3/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3][13][18] are granted and no appearance on 6/3/25 is necessary. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 6/2/2025. Notices Mailed.

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 Guangdong Pake Auto Parts Co., Ltd. and all other Defendants identified in the Complaint

SURETY BOND in the amount of $50,000 posted by FCA US LLC (Document not scanned).

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[28]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[29]

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of extension of time[28] before Honorable Manish S. Shah on 6/12/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 28 is granted, and no appearance is necessary. The TRO is extended to 6/30/25. Notices Mailed.

MOTION by Plaintiff FCA US LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction 33

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion 34

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for preliminary injunction 33 before Honorable Manish S. Shah on 6/18/2025 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/11/2025, answer due 7/2/2025.

Declaration of Hannah A. Abes

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [33] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 6/18/2025. Notices Mailed.

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

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

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for entry of default, motion for default judgment[41] before Honorable Manish S. Shah on 7/10/2025 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Defendant FANGXH-USA by Zhiwei Hua

MOTION by Defendant FANGXH-USA for extension of time to file answer regarding summons returned executed[37]

ATTORNEY Appearance for Plaintiff FCA US LLC by Rachel S Miller

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. Defendant FANGXH-USA does not appear, nor did defendant notice the motion for extension of time [46] for presentment. The motion [46] is denied. For the reasons stated in open court, the motion for entry of default judgment [41] is granted. Enter Default Judgment Order. Terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 7/10/2025. Notices mailed.

TRANSCRIPT OF PROCEEDINGS held on 07/10/2025 before the Honorable Manish S. Shah. Motion Hearing. Order Number: 52421. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 8/4/2025. Redacted Transcript Deadline set for 8/14/2025. Release of Transcript Restriction set for 10/13/2025.

Full SATISFACTION of Judgment regarding order[49] in the amount of $10,000 as to certain defendants