2026-cv-05024

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-25056486.

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 Sharon Johnson Coleman. 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.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff has filed a complaint alleging infringement by 76 defendants. This case follows a pattern common to "Schedule A" cases where plaintiffs allege that defendants employ similar methods and "work in active concert" to infringe plaintiffs' intellectual property. But experience has shown that not all defendants named in a Schedule A case work together. More importantly, experience has shown that joinder under Fed. R. Civ. P. 19 and 20 is rarely appropriate in Schedule A cases. Accordingly, the Court raises the propriety of joinder and requires the plaintiff to file a supplemental memorandum addressing the propriety of joinder at least 7 days before the filing of the motion for temporary restraining order. Alternatively, by the same date, Plaintiff may file an amended complaint and amended Schedule A reducing the number of defendants. However, if Plaintiff names multiple defendants, Plaintiff must show that joinder of those defendants is proper. The Court directs Plaintiff to this Court's standing order in Schedule A cases regarding joinder on the Court's website. Additionally, the Seventh Circuit has recently clarified that establishing personal jurisdiction in Schedule A cases requires that plaintiffs show evidence, for each defendant, of actual sales to Illinois customers and of actual products shipped to Illinois. Liu v. Monthly, No. 25-2074, 2026 WL 880018, at *23 (7th Cir. Mar. 31, 2026). Mere evidence of being willing to ship to Illinois customers is insufficient. Plaintiff may file an amended complaint if additional evidence is needed to establish personal jurisdiction over each Defendant under this standard. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Toyota Motor Sales, U.S.A., Inc. against FACAIJI 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 Sharon Johnson Coleman: Pursuant to the notice of withdrawal [16], plaintiff's motion for leave to file under seal [4] is withdrawn. Mailed notice.