2026-cv-04831

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-25041361.

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 Madeline Halgren

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Young B. Kim. 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.

(List of Trademarks, Ex. 1)

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

AMENDED complaint by Toyota Motor Sales, U.S.A., Inc. against Techmall MX and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Notice of Withdrawal of Plaintiff's Motion for Leave to File Under Seal by Toyota Motor Sales, U.S.A., Inc.

MINUTE entry before the Honorable Martha M. Pacold: The parties are directed to file an initial joint status report by 6/3/2026. Plaintiff's motion [4] to proceed under seal is denied. Proceeding under seal is extraordinary. Plaintiff has not identified circumstances warranting such extraordinary relief. See generally Eicher Motors Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", No. 25-CV-02937, 2025 WL 2299593 (N.D. Ill. Aug. 8, 2025). Plaintiff shall refile all sealed documents on the docket no later than 5/13/2026. Additionally, by 6/2/2026, plaintiff is ordered to show cause why this case should not be dismissed or severed for improper joinder. Plaintiff is advised of the following: First, "[o]n motion or on its own, the court may at any time, on just terms, add or drop a party." Fed. R. Civ. P. 21(a). Second, sua sponte review of the propriety of joinder in Schedule A cases is a regular practice of courts in this district because plaintiffs "routinely file these multi-defendant cases. using cookie-cutter complaints that allege in a conclusory manner that 'on information and belief' each infringing defendant is inter-connected with the others." Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", No. 24-cv-1566, 2024 WL 2953105, at *1 (N.D. Ill. June 6, 2024). Third, "[c]ourts generally find that claims against different defendants arose out of the same transaction or occurrence only if there is a logical relationship between the separate causes of action." Estee Lauder Cosms. Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", 334 F.R.D. 182, 185 (N.D. Ill. 2020) (citations and internal quotation marks omitted). Fourth, courts have held that "to be part of the same transaction requires shared, overlapping facts that give rise to each cause of action, and not just distinct, albeit coincidentally identical, facts." Id. (quoting In re EMC Corp., 677 F.3d 1351, 1359 (Fed. Cir. 2012)). Fifth, courts have held that the allegation that multiple defendants have infringed on the same copyright or trademark in the same way "does not create the substantial evidentiary overlap required to find a similar transaction or occurrence." Roadget Bus. Pte. Ltd. v. Schedule A Defs., No. 23-cv-17036, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) (collecting cases). Finally, courts have held that the allegation that defendants "share unique identifiers, such as design elements and similarities of the unauthorized products offered for sale," is not sufficient to establish joinder. Ilustrata Servicos Design, Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", No. 21-cv-05993, 2021 WL 5396690, at *2 (N.D. Ill. Nov. 18, 2021); Art Ask Agency v. Individuals, Corps., Ltd. Liab. Cos., P'ships, & Unincorporated Ass'ns Identified on Schedule "A", No. 21-cv-06197, 2021 WL 5493226, at *2 (N.D. Ill. Nov. 23, 2021). Mailed notice.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc.

MINUTE entry before the Honorable Martha M. Pacold: The court has received plaintiff's Notice of Voluntary Dismissal, [17]. This dismissal took effect without court intervention. See Fed. R. Civ. P. 41(a)(1)(A)(i); Waetzig v. Haliburton Energy Servs., 145 S. Ct. 690, 694 (2025). Civil case terminated. Mailed notice.