2025-cv-06219

COMPLAINT filed by General Motors LLC; Filing fee $ 405, receipt number AILNDC-23578436.

(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 Thomas M. Durkin. 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: 4.36797E+15, adiazimaoyiyouxiangongsi, baigaomaoyi, CDKJ-US, DUC VU CONG, HGKJ--US, huifengshanghang, HUILUO, HuJiang-Tech, LuBaBa MaoYi, LuoJiaMing-US, meidongma999, QiHangDianZi Store, Shun Lei Shang, Sinuqi, sixiankaifengjiajuyouxiangongsi, suizhoushichanyuanshangmaoyouxiangongsi, xiaxianchuangxiangnongyekejifuwuyouxiangongsi, yitingqipeidian, yudeshui store, Yu-home, YYKeJi-US, ZiYangDianZiShangWu Store, Aoto all-around tool, Auto Parts Specialty Store, Auto Parts Storeot, Auto Parts Storet, Auto-Mateee, BossRide5, Car01store, Car-Auto-along, chang350673, chunming03-a, cutep_29, Ella-us1, fdgdgtyrt-35, gearbolt, happy-hour0, HarmoyWorkshop, hjwfv257, huiewgv67, ikgv632, item03, jfehuhhb20222, jiaoc_16, kejie985, king-autopart-top, kjhgly, ksdkji132, li013_43, Mary_superhero-1, m-dollhouse, NovaStar_AutoParts, oujiuzhanshangmao, Pilot Autos Steering Wheel Cover, Pkacaps, purchasing-easy, qingxiong fang, Smart car accessories, SP auto sell, StellarBOX, sudgmd, vehicle-9981, zqwmnbez-2548, shanyoumuzhi Co.ltd, zhe yu and cadillacaccessory.com added to case caption.

NEW PARTIES: 4367970147633575 added to case caption. Terminating 4.36797E+15

NEW PARTIES: 4.36797E+15, adiazimaoyiyouxiangongsi, baigaomaoyi, CDKJ-US, DUC VU CONG, HGKJ--US, huifengshanghang, HUILUO, HuJiang-Tech, LuBaBa MaoYi, LuoJiaMing-US, meidongma999, QiHangDianZi Store, Shun Lei Shang, Sinuqi, sixiankaifengjiajuyouxiangongsi, suizhoushichanyuanshangmaoyouxiangongsi, xiaxianchuangxiangnongyekejifuwuyouxiangongsi, yitingqipeidian, yudeshui store, Yu-home, YYKeJi-US, ZiYangDianZiShangWu Store, Aoto all-around tool, Auto Parts Specialty Store, Auto Parts Storeot, Auto Parts Storet, Auto-Mateee, BossRide5, Car01store, Car-Auto-along, chang350673, chunming03-a, cutep_29, Ella-us1, fdgdgtyrt-35, gearbolt, happy-hour0, HarmoyWorkshop, hjwfv257, huiewgv67, ikgv632, item03, jfehuhhb20222, jiaoc_16, kejie985, king-autopart-top, kjhgly, ksdkji132, li013_43, Mary_superhero-1, m-dollhouse, NovaStar_AutoParts, oujiuzhanshangmao, Pilot Autos Steering Wheel Cover, Pkacaps, purchasing-easy, qingxiong fang, Smart car accessories, SP auto sell, StellarBOX, sudgmd, vehicle-9981, zqwmnbez-2548, shanyoumuzhi Co.ltd, zhe yu and cadillacaccessory.com added to case caption.

MAILED original $55,000 surety bond posted by General Motors LLC to Amy Crout Ziegler of Greer, Burns, Crain LTD. via certified mail # 7001 2510 0002 3701 4058.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal 3 is granted. Mailed notice.

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 14

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 15

DECLARATION of Andrea Ankawi regarding memorandum in support of motion 15

(Exhibit 1)

SEALED EXHIBIT by Plaintiff General Motors LLC Exhibit 2 Parts 1-2 regarding declaration 17

Exhibit 2-1

(Exhibit 2-2)

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 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 19 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 6/6/2025. Mailed notice.

Registry Deposit Information Form by General Motors LLC

SUMMONS Issued (Court Participant) as to The Partnerships and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 55,000.00 posted by General Motors LLC

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[28]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[29]

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [28] is granted. The Temporary Restraining Order entered on 6/6/2025 is extended by a period of fourteen (14) days until 7/7/2025. 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[34]

Declaration of Marcella D. Slay

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/1/2025, answer due 7/22/2025.

Declaration of Lucas A. Peterson

Exhibit A

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [34] is set for 7/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 General Motors LLC as to certain defendants

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 7/7/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibits to the Declaration of Andrea Ankawi 18, and the TRO 24. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 8/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 7/7/2025. Mailed notice.

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

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

MOTION by Plaintiff General Motors LLC to Reinstate Case Against a Certain Defendant

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: Motion to reinstate case against a certain defendant 43 is granted. The case as to Defendant cadillacaccessory.com (Defendant No. 75) is reinstated. Mailed notice.

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 46

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 47

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 8/7/2025 at 9:00 a.m. is converted to a telephone hearing as to the motion for entry of default and default judgment 46. Mailed notice.

ATTORNEY Appearance for Plaintiff General Motors LLC by Trevor Christian Talhami

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 8/7/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and default judgment [46] is granted. Enter order. The fifty-five thousand dollar ($55,000) 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. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 8/7/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order 52 in the amount of $200,000 as to certain defendant

RETURN of U.S. Post Office Receipt, article no. 9590 9402 8057 2349 7273 50.