2025-cv-11116

COMPLAINT filed by Volkswagen Group of America, Inc. ; Filing fee $ 405, receipt number AILNDC-24062439.

Exhibit 1

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

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Exhibit 2 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

CASE ASSIGNED to the Honorable April M. Perry. Designated as Magistrate Judge the Honorable Maria Valdez. 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.)

AMENDED complaint by Volkswagen Group of America, Inc. against Nanjing Carim Wheels Technology Co., Ltd. and the Individuals and Entities Operating Nanjing Carim Wheels Technology Co., Ltd. and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Amended Schedule A regarding amended complaint, [12]

MINUTE entry before the Honorable April M. Perry: Plaintiff's Motion to Seal [4] is granted. It appearing that the case filed is a "Schedule A" case, Plaintiff is directed to the Court's standing order on its website directing the filing of the Court's Schedule A Template within 14 days. Upon review of the complaint, the Court sua sponte raises the propriety under Federal Rule of Civil Procedure 20(a)(2) of joining 63 defendants to this action. See, e.g, Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). Plaintiff should reference this Court's opinion in Zaful v. Schedule A Defs., 24-cv-11111, Doc. 12 (N.D. Ill. Jan. 10, 2025), where the Court expressed its views on joinder in such cases. By 10/1/2025, Plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of the above cases and explaining why each defendant is properly joined to all of the others. In the alternative, Plaintiff has leave to file an amended complaint by 10/1/2025 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Mailed notice. (jcc,)

MOTION by Plaintiff Volkswagen Group of America, Inc. for discovery Expedited

Exhibit 1

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[16]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for discovery[15], motion for miscellaneous relief[16] before Honorable April M. Perry on 9/30/2025 at 10:00 AM.

MINUTE entry before the Honorable April M. Perry: The Court has received Plaintiff's notice that it no longer seeks to seal its initial filings in this case. [15] Accordingly, the Clerk of Court is directed to unseal docket entries [2] [3] and [4]. Plaintiff's motions for Expedited Discovery [15] and Electronic Service of Process [16] are granted. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with an online marketplace defendant. Expedited discovery is warranted to identify defendant. The Court strikes the motion hearing set for 9/30/2025. Enter order. Mailed notice. (jcc,)

ORDER for Leave to Conduct Expedited Discovery and Service of Process by E-Mail and/or Electronic Publication. Signed by the Honorable April M. Perry on 9/23/2025. Mailed notice. (jcc,)

SUMMONS Submitted (Court Participant) for defendant(s) Nanjing Carim Wheels Technology Co., Ltd. and the Individuals and Entities Operating Nanjing Carim Wheels Technology Co., Ltd. by Plaintiff Volkswagen Group of America, Inc.

SUMMONS Issued (Court Participant) as to Defendant Nanjing Carim Wheels Technology Co., Ltd. and the Individuals and Entities Operating Nanjing Carim Wheels Technology Co., Ltd. (Main Document 23 replaced on 9/25/2025).

NOTICE of Correction regarding [23] (bi,)

SUMMONS Returned Executed by Volkswagen Group of America, Inc. as to Nanjing Carim Wheels Technology Co., Ltd. and the Individuals and Entities Operating Nanjing Carim Wheels Technology Co., Ltd. on 9/30/2025, answer due 10/21/2025.

Declaration of Thomas J. Juettner

Exhibit A