2025-cv-07655

COMPLAINT filed by FCA US LLC ; Filing fee $ 405, receipt number AILNDC-23719077.

Exhibit 1

SEALED EXHIBIT by Plaintiff FCA US LLC Schedule A 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

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 - Part 1 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]

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13] is granted. Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [18] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 7/10/2025.

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

SURETY BOND in the amount of $58,000.00 posted by 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

Exhibit A

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

Declaration of Berel Y. Lakovitsky

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/21/2025, answer due 8/11/2025.

Declaration of Hannah A. Abes

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Responses to the motion for preliminary injunction are due 8/13/25. Status report due 8/20/25. Mailed notice.

CERTIFICATE of Service by Plaintiff FCA US LLC regarding set motion and R&R deadlines/hearings, set deadlines/hearings[30]

Exhibit A

ATTORNEY Appearance for Defendant LABLT by Steven G Kalberg

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

ATTORNEY Appearance for Defendant The Partnerships and Unincorporated Associations Identified on Schedule A by Xiaojun Wang

Appendix List of Parties on whose behalf the appearance is filed.

MOTION by Defendants Jing Dian Chang Xing, JKSXIX Autopart, JYYQ store1, KAIHUIXING, kexin-jp, KuaSheng, Lcskuajing, LIJWLFEE, LIMMEI, Ling-us, LiXinshangmao, LongShengfei, loxilories for extension of time to file answer

MINUTE entry before the Honorable Mary M. Rowland: Defenadnts Jing Dian Chang Xing, JKSXIX Autopart, JYYQ store1, KAIHUIXING, kexin-jp, KuaSheng, Lcskuajing, LIJWLFEE, LIMMEI, Ling-us, LiXinshangmao, LongShengfei, and loxilories' unopposed motion for extension of time to file answer [35] is granted. Jing Dian Chang Xing, JKSXIX Autopart, JYYQ store1, KAIHUIXING, kexin-jp, KuaSheng, Lcskuajing, LIJWLFEE, LIMMEI, Ling-us, LiXinshangmao, LongShengfei, and loxilories to answer or otherwise plead in response to complaint by August 11, 2025. Mailed notice.

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

MOTION by Defendant LABLT for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

MINUTE entry before the Honorable Mary M. Rowland: Defendant No. 14 LABLT's unopposed motion for extension of time to file answer [38] is granted. Defendant No. 14 LABLT is to answer or otherwise plead in response to the complaint by 9/10/25. Mailed notice.

MEMORANDUM by LABLT in Opposition to motion for preliminary injunction[27]

Exhibit List

Declaration Guowei Han

Exhibit 1 LABLT Accused Sales

Exhibit 2 LABLT Restrained Balance

Exhibit 3 LABLT Active Listings of Other Products

Exhibit A LABLT Accused Product

Joint STATEMENT by FCA US LLC Regarding Defendant No. 14 LABLT's Opposition to Plaintiff's Motion for Entry of a Preliminary Injunction 40

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's response in support of preliminary injunction due 9/4/25. Parties are to notify the court if they resolve this matter. Mailed notice.

STATUS Report Pursuant to 30 by FCA US LLC

(Exhibit A)

ATTORNEY Appearance for Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories by Christopher Paul Keleher

NEW PARTIES: JiangLiLi0510, Jilin Province Lingdu Cultural Media Co., Ltd, jilinshengzhiweichuanmeiyouxiangongsi, Jingu Autostore, JITUIHOM, kaisudi, KJ-ZJ, Lemon Automation, LLiYYU, LLUChen, Lokmobiek, MaoNianHua-us, MINHQUANPHAN767, WangJun---us, mcbrockman, mccreparts, minnoun, nvcccauto, oisdeparts, RelikeParts, sawyerdealss, scshscarpart, shangpeng chen, SMG_Show, swiftflyerr, through-power, vvworlf, westernrocky1999, y1301873, zerenzhixin13, zhiweilai-22, zutina, Meishan SHOP, Mijia mall, one for rose local, One stay, Yino Clothing, Greenweave, Klxi and Verenity Dream added to case caption. (Text entry; no document attached.)

MOTION by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories Modify Asset Restraint

Exhibit Store representative declarations and platform screenshots

(Exhibit Summary of figures)

MOTION by Plaintiff FCA US LLC for Entry of an Agreed Asset Restraint Order as to Defendant LABLT (Joint)

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, [47]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [43], the motion for preliminary injunction and motion by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories Modify Asset Restraint [45]. Defendant LABLT (Def. No. 14) ("LABLT") opposed the motion for preliminary injunction. [40]. Plaintiff's motion for preliminary injunction is granted ONLY in part. First it is denied at to LABLT. Next as to the defendants who did not object. As to the objecting defendants identified at docket entry [45], there is no asset restraint on those defendants at this time. The court grants Plaintiff's motion for preliminary injunction limited to the amount of the sales of the accused items. Plaintiff is to send a revised preliminary injunction to the court's proposed order box. Mailed notice.

RESPONSE by LABLTin Opposition to MOTION by Plaintiff FCA US LLC for Entry of an Agreed Asset Restraint Order as to Defendant LABLT (Joint) [46]

MINUTE entry before the Honorable Mary M. Rowland: Agreed motion for asset restraint 46 is denied as LABLT now opposes it. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Response to the motion for default is due 9/9/25. Status report due 9/16/25. Mailed notice.

MOTION by Plaintiff FCA US LLC to Reconsider Minute Order 52

MEMORANDUM by LABLT in Opposition to motion for miscellaneous relief 54 Plaintiff's Motion to Reconsider

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories

Exhibit Amazon listing

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Exhibit Amazon listing

(Exhibit ND Illinois Judge Alonso Order)

MINUTE entry before the Honorable Mary M. Rowland: Motion to reconsider set for in-person hearing on 9/3/25 at 1:30 PM. Mailed notice.

ATTORNEY Appearance for Defendant LABLT by David Randolph Bennett

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 8/28/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Motion hearing held. By 9/5/25, Plaintiff and defendant LABLT are to file the agreed motion for asset restraint. By 9/22/25, these same two parties are to file a status report informing the court: (1) if parties are interested in moving forward with discovery or (2) if they need more time to work it out. Plaintiff's response to [56] due by 10/8/25. Mailed notice.

MOTION by Defendant LABLT for an Agreed Asset Restraint Order as to Defendant LABLT (Agreed)

MINUTE entry before the Honorable Mary M. Rowland: Agreed motion by Defendant LABLT 61 for asset restraint in an amount certain is granted. Parties are to send a proposed order to the court. Mailed notice.

AGREED ASSET RESTRAINT ORDER as to LABLT Signed by the Honorable Mary M. Rowland on 9/8/2025. Mailed notice.

ANSWER to Complaint by LABLT

TRANSCRIPT OF PROCEEDINGS held on 9/3/25 before the Honorable Mary M. Rowland. Motion hearing. Order Number: 52906. Court Reporter Contact Information: Laura Renke, OfficialTranscript@gmail.com, 312.435.6053. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 10/7/2025. Redacted Transcript Deadline set for 10/17/2025. Release of Transcript Restriction set for 12/15/2025.

STATUS Report Pursuant to [53] by FCA US LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the status report 68. No defendant filed a response to the motion for default judgment. The Court grants Plaintiff's motion for default judgment 47. Enter Order. Status report remains due on 9/22/25. Motion to reconsider 54 is denied as moot. 63. Motion by certain defendant to modify the asset restraint 45 is denied as moot. 50. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 9/17/2025. Mailed notice.

STATUS Report Pursuant to [60] (Joint) by FCA US LLC

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report. A Joint initial status report by Plaintiff and LABLT is due to the Court by 10/1/25. A template for the Initial Status Report, setting forth the information required, may be found at http://www.ilnd.uscourts.gov/Judges.aspx by clicking on Judge Rowland's name and then again on the link entitled 'Initial Status Conference.' The litigants are further ordered to review all of Judge Rowland's standing orders and the information available on her webpage. The court will enter a scheduling order in response. Mailed notice.

STATUS Report Pursuant to 70 (Joint) by FCA US LLC

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report. Amended complaint due 10/8/25. Rule 26(a)(1) disclosures due 10/15/25. Written discovery will issue 10/28/25. Written discovery will close 3/2/26. Status report due 12/1/25 updating the court on discovery and settlement discussions. Mailed notice.

AMENDED complaint by FCA US LLC against JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LABLT, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories

Exhibit 1

(Exhibit 2)

STIPULATION of Dismissal as to a Certain Defendant

ATTORNEY Appearance for Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories by Steven P. Mandell

MOTION by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories for extension of time

MINUTE entry before the Honorable Mary M. Rowland: The Court grants Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, and loxilories' unopposed motion for extension of time 76. Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, and loxilories to answer or otherwise plead by 12/24/25. Mailed notice.

MOTION by Plaintiff FCA US LLC to compel Compliance with Local Rule 3.2

DECLARATION of Hannah A. Abes regarding motion to compel 78

(Exhibit 1)

MINUTE entry before the Honorable Mary M. Rowland: Motion to compel compliance with LR 3.2 is set for in person hearing on 11/12/25 at 9:30 AM. Parties are to notify the Court by 11/10/25 is the hearing is not necessary because compliance with LR 3.2 is complete. Mailed notice.

MOTION by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories to amend/correct order on motion for extension of time, text entry, 77 (Unopposed)

MINUTE entry before the Honorable Mary M. Rowland: Motion by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories to amend/correct order 81 is granted. The Court's order dated 10/27/25 77 is amended to provide: Motion to dismiss due 11/10/25; Response due 12/3/25 and Reply due 12/24/25. Mailed notice.

ATTORNEY Appearance for Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories by Brian D. Saucier

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories

MINUTE entry before the Honorable Mary M. Rowland: Defendants have filed their notice of affiliates (Dkt 84). Plaintiff's Motion to compel Compliance with Local Rule 3.2 78 is denied without prejudice, as moot. The Court strikes the hearing set for 11/12/25 at 9:30 AM. Mailed notice.

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories

MEMORANDUM by JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories in support of Motion to Dismiss for Failure to State a Claim, 86 DEFENDANTS MEMORANDUM IN SUPPORT OF THEIR MOTION TO DISMISS AMENDED COMPLAINT

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: Defendants have filed a motion to dismiss in response to the amended complaint. 86. Briefing is set. 82. The original motion to dismiss 56 by these defendants is denied as moot based on the filing of the amended complaint 73. Mailed notice.

STATUS Report Pursuant to 72 (Joint) by FCA US LLC

MOTION by Plaintiff FCA US LLC to stay all Deadlines and Notice of Settlement (Joint)

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 89. Plaintiff has reached a settlement with the last remaining defendant. Plaintiff's motion to stay 90 is granted. Defendant's motion to dismiss 86 is denied without prejudice. All dates are stayed. Plaintiff is to file a stipulation to dismiss or a status report by 1/6/26. Mailed notice.

STIPULATION of Dismissal as to Certain Defendants (Joint)

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/31/2025: Mailed notice.

NOTICE of withdrawal of bond 25 by John Summerfield