2025-cv-06407

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 405, receipt number AILNDC-23597161.

Exhibit 1

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Volkswagen Group of America, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Volkswagen Group of America, Inc.

Notice of Claims Involving Trademarks by Volkswagen Group of America, Inc.

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Jennifer Van Nacht

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Thomas Joseph Juettner

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.

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2).

NEW PARTIES: Changzhou Kaimao Automotive Parts Co., Ltd., Guangdong New Vision Film Co., Ltd., Xiamen Xinsanxin Precision Machinery Co., Ltd., Yiwu Years Crafts Co., Ltd., Auspi cious AnkangTrade, Benbao-Auto, Chanfron, ChenZheng19, Glamour Avenue, HFYANGZH, JiaYiChuan, RSphere, SANSAN Digital Accessories, shanxishengbeijianzhugongchengyouxiangongsi, USACong, xiaotingSHOP, YI JU DIANSHANG, ZHONGlihong8887, 5d89ew6ew, 786uirjkg2, 87695490o, 8965uiotr, 896uoitr, angzhouliu, Auto Parts Store111, auto_defenders, auto_jdm06, auto_SSS, automaticity0, automation-3883, b_bodyshop, ban347166, bi_peng9, bmgko09, Caps_MAO99, car-auto-us241, chenchun889, chenjiayao-596, chenwenshi, China Beauty Fair, coldlyco, cxjche, dainianminkejiyo, daizongqiang, debooo2022, delin huang, dengruo_lan16, dengxiaoqingqing, dengyu_zhen1, dongguanshiburaom_0, easylifeshop, fangyu988, fanlin12, fds1562gfj, Fgf1256, fgh1562hgj, fuduo wu, gaoyu01, gengmahelianshan, gfds156564s2, gfds6521jf, gfsd1563456f, gh1562ghj, ghf1562hgj, gkfiotr89043, goyy3917, guanyu_yu00, guohua1600car and gzant-71 added to case caption.

MAILED original ten-thousand-dollar ($10,000) surety bond 37 posted by Justin R. Gaudio at Greer, Burns & Crain Ltd. 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7806 45.

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court grants the motion to seal [3], but upon review of the complaint, the Court sua sponte raises the propriety of joining 70 defendants in a single action. By June 20, 2025, plaintiff must file a supplemental memorandum addressing the propriety of joinder. In the alternative, plaintiff has leave to file an amended complaint by June 20, 2025 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting the opinion issued in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025) (Alexakis, J.). Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

Supplemental Memorandum in Response to Minute Order [11] by Volkswagen Group of America, Inc.

DECLARATION of Justin R. Gaudio regarding other[14]

Exhibit 1

MOTION by Plaintiff Volkswagen Group of America, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for temporary restraining order[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

DECLARATION of Dana A. Cizmadia regarding memorandum in support of motion[17]

Exhibit 1

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Exhibit 2 - Parts 1-2 regarding declaration[19]

MOTION by Plaintiff Volkswagen Group of America, Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for miscellaneous relief[21]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

SEALED DOCUMENT by Plaintiff Volkswagen Group of America, Inc. Schedule A Template

Registry Deposit Information Form by Volkswagen Group of America, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Volkswagen Group of America, Inc.

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

SURETY BOND in the amount of $ 10,000.00 posted by Volkswagen Group of America, Inc.

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to a Certain Defendant

MOTION by Plaintiff Volkswagen Group of America, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for preliminary injunction[31]

DECLARATION of Jennifer V. Nacht regarding memorandum in support of motion[32]

SUMMONS Returned Executed by Volkswagen Group of America, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/24/2025, answer due 7/15/2025.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all 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 by June 30, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. 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. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until 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 Volkswagen Group of America, Inc. regarding order on motion for preliminary injunction, text entry, [35]

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction [31] is granted, which the Court now considers unopposed because no defendant filed a notice of objection by the established deadline. For the reasons set forth in plaintiff's motion for a preliminary injunction, as well as the reasons provided by plaintiff in connection with the Court's earlier entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction, including 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 goods. Plaintiff has also certified and established [36] that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Assuming no defendant appears beforehand, plaintiff is directed to file a motion for entry of default and default judgment by July 21, 2025. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Lindsay C. Jenkins on 7/1/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to Certain Defendants

MOTION by Plaintiff Volkswagen Group of America, Inc. for entry of default, MOTION by Plaintiff Volkswagen Group of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for entry of default, motion for default judgment, [43]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, 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 July 28, 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 July 24, 2025. A hearing 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. Mailed notice.

CERTIFICATE of Service by Plaintiff Volkswagen Group of America, Inc. regarding order on motion for entry of default, order on motion for default judgment, text entry, [46]

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [43] 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 Clerk is directed to return the surety bond posted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 7/29/2025. Mailed notice.

MAILED Closing Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Minute Entry dated 7/29/2025)

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7806 45. (Received by mail in the Clerk's Office on 08/18/2025)

FULL SATISFACTION of Judgment regarding entered judgment 49 in the amount of $10,000 as to certain defendant