2025-cv-12609

COMPLAINT filed by FCA US LLC; Filing fee $ 405, receipt number AILNDC-24203853.

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]

Exhibit 2-1

(Exhibit 2-2)

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 Manish S. Shah. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

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[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-2 regarding declaration[16]

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[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[4], motion for temporary restraining order[13], motion for miscellaneous relief[18] before Honorable Manish S. Shah on 10/23/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [4][13][18] are granted. Security is set at $90,000. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/22/2025. Notices Mailed.

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

SURETY BOND in the amount of $ 90,000 posted by FCA US LLC (Received via the Clerk's Office drop box on 10/24/2025) (Document Not Imaged)

MOTION by Plaintiff FCA US LLC for extension of time of Temporary Restraining Order

MEMORANDUM by FCA US LLC in support of extension of time[28]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[29]

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of extension of time[28] before Honorable Manish S. Shah on 11/5/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time [28] is granted, and no appearance is necessary. The TRO is extended to 11/19/25. Notices Mailed.

MOTION by Plaintiff FCA US LLC for preliminary injunction

Exhibit A

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction[33]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[34]

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for preliminary injunction[33] before Honorable Manish S. Shah on 11/13/2025 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/7/2025, answer due 11/28/2025.

Declaration of Hannah A. Abes

Exhibit A

ATTORNEY Appearance for Defendants MousseRepairs, Muse-Carparts, qarmaxparts by Christopher Paul Keleher

MOTION by Defendants MousseRepairs, Muse-Carparts, qarmaxparts for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[39] before Honorable Manish S. Shah on 11/13/2025 at 09:45 AM.

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

ATTORNEY Appearance for Plaintiff FCA US LLC by Luana Faria De Souza (Faria De Souza, Luana)

ATTORNEY Appearance for Defendants MousseRepairs, Muse-Carparts, qarmaxparts by Lan Li

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. Without objection, the motion for extension of time [39] is granted. Defendants MousseRepairs, Muse-Carparts, and qarmaxparts must respond to the complaint by 12/1/25. For the reasons stated in open court, plaintiff's motion for preliminary injunction [23] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 11/13/2025. Notices Mailed.

NEW PARTIES: Liurucong920, MaJiaoDengJuSTR, MeiJingMax, Mississippi 01, MUXIsu336 mall, Newstart_auto, ningchengSHOP, panshengqiang, PAN-ZHIHAO, PPouLiu, qiyaSHOP, rongjietigen, Ruipu Direct, shangshuijunyangshangmaoyouxiangongsi, shanweishisuzhoumaoyidian, Splendor Industry, suliang1206, susongfuyingyouxiangongsi, TOKMOCO Mural, VAVICARS, wenxiaoyong, Xuzhou Leyixiang Trading Co., LTD, yexinmingsds, yuanpingchangtaishangmaoyouxiangongsi, yuanpingshixiangyouqianshangmaoyouxiangongsi, yuanyuanyuana shop, zhoukouguixinshangmaoyouxiangongsi, zhoukoujingyishangmaoyouxiangongsi, zhoulingyan6852, zhshiun, zhuzhoushihetangqudingningshangmaohang, Zongqishangmao, Zubanjiejie mall, Love-Trim, luckyday2008, max_autohub, moreautopart, mostcar-accessories1, Motorcraft-Mopar-auto, motosportstore2020, MousseRepairs-shop, MSSJ, mylove-auto, no1_autopart_2024, omuoffroadbase, panelled, partskingdom us, preferred_store, primestores99, ProGear Tools, QYYAUTO, saikendeuk, sengho, skd-autoparts, smarthome-1980, sominiaeros, sport-autopart, sshauto, syfwe6343, thisparts, tomatochicken, top_lamp_8, traffic-most, TX6688, uscarparter, vehicleshops, victoryauto88, vintagetreasurehunt_397, vision2010, warmlight-centre, wennu83, X-radio, yeego4-95, yeegobusiness, yeego-led, yeego-shop, yksei-autoparts, yucgo_47, yunyiautoparts, yupoiopq, Jushang Color Decoration, YYDSLUCKY, Luukc llc, moonStar, Vincent hou and WheelX Shop added to case caption.

ATTORNEY Appearance for Defendant Newstart_auto by Christopher Paul Keleher

MOTION by Defendant Newstart_auto for extension of time to file answer regarding complaint 1 (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 47 before Honorable Manish S. Shah on 12/3/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Defendant Newstart_auto's motion for extension of time 47 is granted, and no appearance on the motion is necessary. Defendant Newstart_auto's response to the complaint is due 12/22/25. Notices mailed.

NOTICE of Voluntary Dismissal by FCA US LLC as to Certain Defendants

MOTION by Plaintiff FCA US LLC for entry of default, MOTION by Plaintiff FCA US LLC for default judgment as to all Defendants with the exception of Certain Defendants

(Exhibit A)

MEMORANDUM by FCA US LLC in support of motion for entry of default, motion for default judgment 51

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 52

(Exhibit 1)

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for entry of default, motion for default judgment 51 before Honorable Manish S. Shah on 12/9/2025 at 09:45 AM.

(Exhibit A)