Robert Bosch GmbH et al v. Jinhua City Jindong District Zhuoyun E-Commerce Co., Ltd.

COMPLAINT filed by Robert Bosch GmbH, Robert Bosch LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-25006444.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by John Wilson

ATTORNEY Appearance for Plaintiffs Robert Bosch GmbH, Robert Bosch LLC by Elizabeth Aubree Miller

MOTION by Plaintiffs Robert Bosch GmbH, Robert Bosch LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiffs Robert Bosch GmbH, Robert Bosch LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Robert Bosch GmbH, Robert Bosch LLC

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Laura K. McNally. 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

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to Judge LaShonda A. Hunt. Upon review of the complaint, the Court questions whether Plaintiff has shown that the Court can exercise personal jurisdiction over the defendant. To adequately plead personal jurisdiction, Plaintiff must sufficiently allege that the defendant actually sold the allegedly infringing product to a customer in Illinois. See Liu v. Monthly, No. 25-2074, 2026 WL 880018, at *1 (7th Cir. Mar. 31, 2026) (citing Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 400 (7th Cir. 2020)). The complaint alleges sales in this district, but those allegations are conclusory, and Plaintiff did not provide proof of actual sales in this district. See id. (remanding with instructions to dismiss for lack of personal jurisdiction because plaintiff had not provided screenshot evidence of actual sales in Illinois). Additionally, Plaintiff has not established good cause under Local Rule 26.2 or Seventh Circuit precedent to justify sealing the name of defendant or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightsholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", 794 F. Supp. 3d 543, 552 (N.D. Ill. 2025). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject of the case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-568 (7th Cir. 2000). For these reasons, the motion for leave to file under seal 8 is denied. The Clerk of Court is directed, forthwith, to (1) unseal the document filed at 9 and (2) update the caption / case title and parties on the docket to reflect that Defendant is "Jinhua City Jindong District Zhuoyun E-Commerce Co., Ltd." By 5/5/26, Plaintiff must file either an amended complaint or supplemental statement establishing a basis for personal jurisdiction. Failure to do so will result in the current complaint being dismissed without prejudice and this case being closed. Mailed notice (gel,)

DECLARATION of Robert P. McMurray

(Exhibit 1)

MINUTE entry before the Honorable LaShonda A. Hunt: Upon review of the declaration of Plaintiff's counsel 14, the Court is now satisfied that personal jurisdiction has been established with respect to Defendant. If no other appropriate relief has been sought, Plaintiff is ordered to file a status report by 6/3/26 with proposed next steps in the case. Mailed notice (gel,)

DECLARATION of Jay Paragoso

Exhibit 1

(Exhibit 2)

MOTION by Plaintiffs Robert Bosch GmbH, Robert Bosch LLC to expedite Plaintiff's Motion for Expedited Discovery

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiffs' motion for leave to conduct expedited discovery 17 is granted. The Court grants Plaintiffs' request for expedited discovery as the Court finds that expedited discovery is warranted to obtain Defendant's contact information. Enter Order Authorizing Expedited Discovery. If no other relief has been sought, Plaintiffs are ordered to file a status report by 6/4/26 updating the Court on the progress of expedited discovery and proposed next steps in the case. Separately, the Court notes that Plaintiffs have filed a declaration 16 wherein the declarant asserts that Plaintiffs "will suffer immediate and irreparable injury, loss, or damage if an ex parte Temporary Restraining Order is not issued in accordance with Federal Rule of Civil Procedure 65(b)(1)." Any request for injunctive relief must be made in the form of a motion, which Plaintiffs have not filed. Counsel is reminded to review and comply with all court rules, orders, and procedures. Non-compliant filings will be summarily stricken going forward. Mailed notice (gel,)

ORDER AUTHORIZING EXPEDITED DISCOVERY Signed by the Honorable LaShonda A. Hunt on 5/14/2026. Mailed notice (gel,)