Volkswagen Group of America, Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 405, receipt number AILNDC-25161487.

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 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 Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Jennifer Van Nacht

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 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.

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Additionally, to the extent Plaintiff also makes a motion for expedited discovery or for an order permitting electronic service of process, Plaintiff should submit a proposed order for that relief that is separate from the proposed order for the TRO and asset restraint. The proposed order for the TRO and asset restraint should name the relevant defendants directly in the order, without reference to Schedule A. Mailed notice.

Notice of Withdrawal of Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) by Volkswagen Group of America, Inc.

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff's motion for a temporary restraining order, temporary asset restraint, and expedited discovery 12 and motion for electronic service of process 17 are denied without prejudice in light of Kangol LLC v. Hangzhou Chuanyue Silk Import & Export Co., Ltd., Case No. 25-2205 (7th Cir. May 29, 2026). Mailed notice.

MOTION by Plaintiff Volkswagen Group of America, Inc. for reconsideration regarding order on motion for temporary restraining order, order on motion for miscellaneous relief, text entry, 23

MINUTE entry before the Honorable Thomas M. Durkin: The motion for reconsideration [24] is granted. The request for a temporary restraining order, a temporary asset freeze, and expedited discovery is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 6/2/2026. Mailed notice.

SEALED Order Authorizing Expedited Discovery. Signed by the Honorable Thomas M. Durkin on 6/2/2026. Mailed notice.

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

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 29

DECLARATION of Jennifer V. Nacht regarding memorandum in support of motion 30

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order 29 is granted. The Temporary Restraining Order entered on 6/2/2026 is extended by a period of fourteen (14) days until 6/30/2026. Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by Volkswagen Group of America, Inc.

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to certain Defendants

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)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 35 is set for 6/30/2026 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

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