2025-cv-12032

COMPLAINT filed by FCA US LLC; Filing fee $ 405, receipt number AILNDC-24145067.

Exhibit 1

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

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-2 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

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Albert Berry, III. 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 FCA US LLC against kangru-motorUser ID, the Individuals and Entities Operating kangru-motorUser ID and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

EXHIBIT by Plaintiff FCA US LLC Amended Schedule A regarding amended complaint, [13]

MOTION by Plaintiff FCA US LLC for discovery Expedited

Exhibit 1

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[16]

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

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for expedited discovery [15] and motion for electronic service of process [16] are granted. Expedited discovery is warranted to identify Defendants and to implement the asset freeze. Under Rule 26(d) of the Federal Rules of Civil Procedure, a party may not seek discovery from any source before the parties have conferred as required by Rule 26(f). Fed. R. Civ. P. 26(d); Dallas Buyers Club LLC v. Does 1-26, 14-cv-360, 2014 WL 1612251 at *1 (E.D. Wis. Apr. 22, 2014). But courts can allow expedited discovery before a Rule 26(f) conference if, after consideration of all the surrounding circumstances, the movant shows good cause for the request and the request is reasonable. Id.; Malibu Media, LLC v. Doe, 13-cv-8484, 2014 WL 1228383 at *3 (N.D. Ill. Mar. 24, 2014). In this instance, expedited discovery is warranted to enable Plaintiff to identify Defendants' contact information (including their associated e-mail addresses) so that Plaintiff can effectuate service of process by e-mail. Electronic service of process does not violate any treaty, complies with Rule 4(f)(3) of the Federal Rules of Civil Procedure, and, because it effectively communicates the pendency of this action to Defendants, is consistent with due process requirements for the service of legal process. Enter separate order authorizing expedited discovery and electronic service of process. Plaintiff states that it has withdrawn its motion [4] for leave to file under seal; accordingly, that motion is dismissed as moot, and the Clerk shall unseal all documents in this case. Mailed notice.

ORDER signed by the Honorable John F. Kness on 10/27/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) kangru-motorUser ID and the Individuals and Entities Operating kangru-motorUser ID by Plaintiff FCA US LLC

SUMMONS Issued (Court Participant) as to Defendants kangru-motorUser ID, the Individuals and Entities Operating kangru-motorUser ID