2024-cv-02071

COMPLAINT filed by Volkswagen Group of America, Inc.; Filing fee $ 405, receipt number AILNDC-21735876.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Schedule A 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 Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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.

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 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Dana A. Cizmadia regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Volkswagen Group of America, Inc. Exhibit 3 - Parts 1-3 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

(Exhibit 3-3)

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 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 18, motion for leave to file 3, motion for temporary restraining order 13 before Honorable Virginia M. Kendall on 3/25/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing set for 3/25/2024 is reset for 9:30 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 3/25/2024. Plaintiff's Motion for leave to file under seal 3 and Motion for electronic service of process 18 are granted. Plaintiff's Sealed Motion for Temporary Restraining Order 13 is granted and shall remain in effect up to and including 4/8/2024. Sealed Order to follow. Status hearing set for 4/8/2024 at 9:00 AM. Mailed notice

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 3/25/2024. Mailed notice

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

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 10,000 posted by Volkswagen Group of America, Inc. (Document not Imaged)

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[27]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time[27] before Honorable Virginia M. Kendall on 4/8/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion to extend Temporary Restraining Order 27 is granted. Temporary Restraining shall remain in effect up to and including 4/22/2024. Status hearing is reset for 4/22/2024 at 9:00 AM. Motion and Status hearing set for 4/8/2024 are stricken. Mailed notice

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 32

Declaration of Kahlia R. Halpern

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 32 before Honorable Virginia M. Kendall on 4/22/2024 at 09:00 AM.

(Exhibit A)

SUMMONS Returned Executed by Volkswagen Group of America, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/17/2024, answer due 5/8/2024.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Status and Motion hearing set for 4/22/2024 is reset for 9:15 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

ATTORNEY Appearance for Plaintiff Volkswagen Group of America, Inc. by Luana Faria De Souza (Faria De Souza, Luana)

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 4/22/2024. Plaintiff's Motion for Preliminary Injunction [32] is granted. Order to follow. Status hearing set for 6/17/2024 at 9:00 AM.

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 4/22/2024. Mailed notice

NEW PARTIES: 8mile, Gkirkkh, GKLY, LiuYunFeidian, putianshichengxiangqulongqiaojiedaolinqingfangfuzh, QXK kk, shanghaichifenwangluokejiyouxiangongsi, smdd, tianjingwangluokejiyouxiangongsi, wenzhunshangmaoyouxi, zhijiangshimanbianshangmaoyouxiangongsi0511, ai821, d1fs, eerj, k2yx, npkh, rbur, vi3q, voay, wwwcom88 Store, zk4r, zqnw, aaplus1682, ac29u.kphye-1o12, apex_1991, battery-center-a100, chui-5624, cuma903597, dishi-1342, dummysensors, game_master6, hama-791138, hela739000, hongkongshengfengpin_0, jieanhemy, kangrong, kkprint, luofei14, luofei-99, luofeifei, modification-auto.0.10, omofr_22, sgr855489, super_yoga_vv, weizabcde, weizabcdef, wushaozhong211, wzhen-g, xixisusu, yhtoweuitwh, youqingzhiren520, zew_37, RAuto and Wooden pilion t added to case caption.

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

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

MOTION by Plaintiff Volkswagen Group of America, Inc. for entry of default, MOTION by Plaintiff Volkswagen Group of America, Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Volkswagen Group of America, Inc. in support of motion for entry of default, motion for default judgment, 42

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 43

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, 42 before Honorable Virginia M. Kendall on 5/28/2024 at 09:00 AM.

(Exhibit A)

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 5/28/2024. Plaintiff's Motion for entry of Default and Default Judgment as to all remaining Defendants 42 is granted. Enter Order of Default as to Defendants as outlined in Exhibit A. Final Judgment Order to follow. Mailed notice

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 5/28/2024. Civil case terminated. Mailed notice

NOTICE of withdrawal of bond [26] by John Summerfield, Greer Burns & Crain, Ltd.