2026-cv-00450

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-24599381.

Exhibit 1

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A regarding complaint[1]

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 2 Parts 1-2 regarding complaint[1]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Toyota Motor Sales, U.S.A., Inc.

Notice of Claims Involving Trademarks by Toyota Motor Sales, U.S.A., Inc.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

DECLARATION of Teena Bohi regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 2 Parts 1-2 regarding declaration[17]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file under seal [4] and motion for electronic service [19] are granted. Plaintiff's ex parte motion for entry of a temporary restraining order [14] is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 2/6/2026 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 2/3/2026. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 1/23/2026. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Toyota Motor Sales, U.S.A., Inc.

Registry Deposit Information Form by Toyota Motor Sales, U.S.A., Inc.

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

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of extension of time[27]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[28]

SURETY BOND in the amount of $ 10,000.00 posted by Toyota Motor Sales, U.S.A., Inc. (Document not scanned).

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to extend the temporary restraining order [27] is granted; the telephonic preliminary injunction hearing set for 2/6/2026 is vacated and reset to 2/20/2026 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction is to be filed by 2/17/2026. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Madeline Halgren

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction[32]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[33]

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/4/2026, answer due 2/25/2026.

Declaration of Thomas J. Juettner

Exhibit A

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain Defendants

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or a response to the complaint or the motion for preliminary injunction. The telephonic preliminary injunction hearing set for 2/20/2026 is vacated. Plaintiff's motion for entry of a preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the 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. The case is set for a telephonic status hearing on 4/20/2026 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 4/13/2026. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 2/18/2026. Mailed notice.

NEW PARTIES: A19SC5XTCTYITK, A26XNX6BF66SBG, A3QWTAI6OYUV7W, AIBEISI braiding hair, AiMiNi, AZLSM, baituoshangmao123, beixu chai, chaixiyang, CharmOnly, ChenYuXi421, DASONLT, Dexinstar, FUGUIXIAOHUI, Guang Zhou Ting He Mao Yi You Xian Gong Si, guangzhoupanghuqicheyongpinyouxiangongsi, hegongxushangmao, jixinzhang, Kura-Mart, LiuYongjinVVB, Michael's premium store, NICEWQY, Pancozy US, PeachFairy, RUYUAUTO, ShanXiXinLanHaiBinWangLuoKeJiYouXianGongSi, Shubo Trading, SSBOX, Sunwellauto, the red hat, yiyuedianzishangwu88, yunchengyanjunqichexiaoshouyouxiangongsi, YushengTrading, 6399mall, ageon21, aochua_19, aochua52, aochua9, aucycle, autohubglo, automobileshop, Boutique Auto Parts-06, Carshow Autoparts, eonore14, estax--168, EverSpringAuto, filiojaz27, HAN AUTOMOBILE PARTS-08, interioryt, jdm-cars2018, lulu01-2, orl-auto-care, orl-auto-quick, orl-auto-service, Precision Point, remart134, sxia65, toukeauto, US-Manufacturer, wbqy001, wdd19-65, williamwushop, xhy374, ye156238, YG02-HIGH QUALITY AUTO PARTS, yiranchuangyi3, youchua_4, youchua-68, youchua7, An encounter with beauty, AuraNova bag, Automobile car, Awesome car sticker, Blzr Allin Shop, Botanical Dye Atlas, Bwyx Harmony Goods, CCCYJY, CCCYJYbb, CFLpoiy, chenyaohuaOne, Distressed Tin Sign Art, eTJVs, Everyone sing together, Fashionable beautiful and generous, Fourleaf clover stickers, JBXDEY, JHgoodluckE and LFXFIVE added to case caption.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain Defendants

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for entry of default, MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for default judgment as to all remaining Defendants

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., 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