2025-cv-09562

COMPLAINT filed by FCA US LLC ; Filing fee $ 405, receipt number AILNDC-23872132.

Exhibit 1

Exhibit 1

Trademarks

Exhibit 2-1

Exhibit A

Exhibit A

Declaration of Hannah A. Abes

SEALED EXHIBIT by Plaintiff FCA US LLC Schedule A regarding complaint[1]

(Exhibit 2-2)

Exhibit A

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 Jorge L. Alonso. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

NEW PARTIES: aoligei auto, B.ZSSY AUTO, Bottlenose Dolphin, ChenWangSheng-us, Custom Size Wall Murals, Damao autostore, DongGuanShiXiaoYiMaoYiYouXianGongSi, DW-010, DWKJMYCP, Haiphong Shop, hengyangmicushangmaoyouxiangongsi, INTCHE, Juoar Puddle Light, Lancham, 1007MGT, 123sex toys, ADXH-autoparts, ALOnline-Autoparts, astsupermotor, Automobile_2022, autopartspavilion, autopartsplanet1, AutoPro001, autoprohub001, autoshopler, AutoVirtuoso, Aux_partoutlets, aux_purecarpart, aux_usmotors, AuxFastway, AUXITO, AUXITO Authorized Store on eBay, AUXITO auto led bulb, AUXITO Auto Parts Store, AUXITO BULB, AUXITO LED LIGHT, AUXITO Lighting Depot, AUXITO Offical, AUXITO official store, AUXITO Performance Parts, auxito_light2, AUXITO_online, auxito_store, auxito_world, AWXHparts, Axi_Auto, aygroqwlahgws, bestautoseller_99, bestpartsok, BestPartsStore, Bussipt, caiyanyantiger, carbadges2022, carest-parts, cenyaoo, CHAOGANG3030, Choose Starry Sky, clronhorse, cyadence, dabaobei-08, dbdb-auto, eco-auxito, Feiteplus2098, gajan-auto, GD-gdAuto, BACKYARD TOOL HOUSE, carlights, FUNKL, 102824735, Aether Apparel, DANTA COMPANY LIMITED, dongguanshilingxiao, Earth Tones, Flexora Fresh, FUSCH, huhuhaha and ICHTHYOSAUR added to case caption. (Text entry; no document attached.)

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[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion[12]

MAILED trademark report to Patent Trademark Office, Alexandria VA.

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-2 regarding declaration[14]

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[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for miscellaneous relief[17], motion for temporary restraining order[11] before Honorable Jorge L. Alonso on 8/19/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [11] [17] are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $77,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 8/19/25 is stricken.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 8/18/2025. Notice mailed by Judge's staff

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 The Partnerships and Unincorporated Associations Identified on Schedule A

MOTION by Plaintiff FCA US LLC for preliminary injunction

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction[27]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[28]

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for preliminary injunction[27] before Honorable Jorge L. Alonso on 8/28/2025 at 09:30 AM.

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/25/2025, answer due 9/15/2025.

SURETY BOND in the amount of $ 77,000 posted by FCA US LLC (Document not scanned)

ATTORNEY Appearance for Plaintiff FCA US LLC by Thomas Joseph Juettner

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [27] is granted. Enter Preliminary injunction order. The Clerk's office is directed to unseal all previously sealed documents. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Telephonic status set for 9/30/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 8/28/2025. Notice mailed by Judge's staff

NOTICE by Damao autostore regarding removed listing and minimal sales (Exhibits) (Received via pro se online portal on 8/28/25.)

Entered in error.

Entered in error.

NOTICE of Correction regarding Patent/Trademark report 37, lanham notification 38