Volkswagen Group of America, Inc. v. liangma74

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 405, receipt number AILNDC-25407926.

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 - Parts 1-2 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 LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Heather K. McShain. 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 trademark infringement complaint and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all 56 defendants under Fed. R. Civ. P. 20. See Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule A,No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). Indeed, Plaintiff filed a form complaint with generic allegations about coordinated counterfeiting activity between 56 defendants without any details whatsoever, which arguably violates the requirements of Federal Rules of Civil Procedure 8 and 10. The Court also questions whether Plaintiff has sufficiently alleged personal jurisdiction over the defendants. To adequately plead personal jurisdiction, Plaintiff must sufficiently allege that the defendants actually sold the allegedly infringing product to a customer in Illinois. See Liu v. Monthly, 170 F.4th 1090, 1093-94 (7th Cir. 2026) (citing Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 400 (7th Cir. 2020)). Plaintiff's 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). Accordingly, Plaintiff has not sufficiently alleged that the Court has personal jurisdiction over any Defendant. Accordingly, by 7/29/26, Plaintiff must file either a memorandum explaining why joinder and personal jurisdiction are proper, or an amended complaint specifically naming and identifying each defendant being sued and setting forth with more than conclusory statements the alleged infringing activity and that includes proof of actual sales in Illinois. Failure to do so will result in the current complaint being dismissed without prejudice and this case being closed. Furthermore, Plaintiff has not established good cause under Local Rule 26.2 or Seventh Circuit precedent to justify sealing the names of defendants or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' 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) (Kness, J.). 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 matter of a 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 those reasons, the motion for leave to file under seal [4] is denied. The Clerk of Court is directed to unseal the document filed at [2] [3]. Mailed notice (gel,)

AMENDED complaint by Volkswagen Group of America, Inc. against liangma74 and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

MINUTE entry before the Honorable LaShonda A. Hunt: Upon review of Plaintiff's amended complaint 15, the Court's joinder and personal jurisdiction concerns are resolved. The Clerk's office is directed, forthwith, to update the caption to reflect that the Defendant in this case is "liangma74". By 8/6/26, Plaintiff is ordered to file a status report proposing next steps in this case, if no other appropriate relief has not been sought by that date. Failure to comply with this order will result in the case being dismissed for want of prosecution and non-compliance with court orders. Mailed notice (gel,)

NOTICE of Voluntary Dismissal by Volkswagen Group of America, Inc. as to Defendant liangma74

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil Procedure 41(a)(1) and Plaintiff's notice of voluntary dismissal [17], this action is being dismissed without prejudice. All pending motions and deadlines are terminated as moot. Civil case terminated. Mailed notice (gel,)