2025-cv-14848

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 405, receipt number AILNDC-24444324.

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 -- Parts 1-2 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 Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Justin R. Gaudio

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 Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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 Volkswagen Group of America, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for temporary restraining order[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

DECLARATION of Dana A. Cizmadia regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Exhibit 2 -- Parts 1-2 regarding declaration[15]

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[17]

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

MAILED Trademark report to Patent Trademark Office, Alexandria VA (qrtr,)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials (qrtr,)

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for leave to file under seal [4] is granted. Plaintiff's Ex Parte motion for Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, and expedited discovery [12] is granted. Plaintiff's motion for electronic service of process [17] is granted. Order to enter. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 12/10/2025. Mailed notice.

Registry Deposit Information Form by Volkswagen Group of America, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Volkswagen Group of America, Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 50,000 posted by Volkswagen Group of America, Inc. (Document not Imaged)

MOTION by Plaintiff Volkswagen Group of America, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Volkswagen Group of America, Inc. in support of extension of time[30]

DECLARATION of Jennifer V. Nacht regarding memorandum in support of motion[31]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion for extension of time [30] is granted. Order to enter. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 12/23/2025. Mailed notice.

MOTION by Plaintiff Volkswagen Group of America, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for preliminary injunction[35]

Declaration of Jennifer V. Nacht

SUMMONS Returned Executed by Volkswagen Group of America, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/23/2025, answer due 1/13/2026.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of a preliminary injunction [35] is granted. Order to enter. The Clerk of the Court is directed to unseal: Schedule A to the Complaint [2], Exhibit 2 to the Complaint [3], Seller Aliases screenshots attached to the Declaration of Dana A. Cizmadia [16] and the TRO [25]. The Law Firm of Greer, Burns & Crain Ltd. is ordered to add all defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 12/30/2025. Mailed notice.

NEW PARTIES: JWlJX, junfei83, luckauto-8, mia-us8, new-auto-parts, iu iu iu, Jacqueline Clothing, ji sai fang yi, JIA BAO ART, jiadianyan, JoyLuX Z, JPHWCASE, JUNLIN PAINTING, KAJI CLOTHING, KALAOKDONUTS, Kamuran, KIOSH, KL LY, Lb Baseball Cap, LCY XFTextiles A, LDWC Decoration, LDXLL, Leisure Best hat, LER Small shop, LGQA Baseball Cap, LGQB Baseball Cap, LidSpark, Life will be good, Lin Ping An, lin qingbing bin, lin qingbingqingbing, Lina Hat Selection, lingzhixiong cap, linjinqang Cap, Linlililililililliili, linxuelinnnnn, Little baseball hat shop, Little Red Riding Hood Running, Liu fengfengfeng, liu fengfneg wang, liuqinhua, Liwo Hat F, LJJONE HAT, lliiGD, Lookory, LOVE HAT OV, LOVE HATSS, Love Life Merchant, Love Living Hat, LOVEGIFTCC, LOVEGIFTK, LOVEGIFTS, LOVEGIFTT, Lovely Baseball Cap, LOVEZZ, ltelc Cool car, LuckydayGOOD, Lucy baseball cap, LYF Hat Baseball cap, LZCONE CAP, Ma Da Shuai, Ma Hai Huang, Machine POP, Main main, Many Materials, Meadow Cloth, Meadow Mason, mengmengaa, mihongDZ, Mina baseball cap, Molasses Moss, Mono Good Cap, Mono Hat, Moon Bend Trendy Wind, Moon Ship Big Player, Moon Ship Counts Stars, Mr HATs, Mr Outfit, New style blanket, Next Wednesday, Nova blanket, Number Eleven, Olden Mart, Ostracon OLED, Outdoor hat customization, PandaStitch, SHEKIKO Mall, Star River Shopping Plaza, TE CHEN and Wisdom Merchants added to case caption.

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.

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.

MOTION by Plaintiff Volkswagen Group of America, Inc. for entry of default, MOTION by Plaintiff Volkswagen Group of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for entry of default, motion for default judgment, [42]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1