2024-cv-05182

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-22167192.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A 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 Jennifer Van Nacht

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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 Toyota Motor Sales, U.S.A., Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Teena Bohi regarding memorandum in support of motion 12

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 3 Parts 1-6 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for miscellaneous relief 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 16, motion for temporary restraining order 11 before Honorable Elaine E. Bucklo on 7/3/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 3 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 11 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 16 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 7/16/2024, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 7/11/2024. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a status hearing on 8/19/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 8/12/2024 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 7/3/2024. Mailed notice.

Registry Deposit Information Form by Toyota Motor Sales, U.S.A., Inc.

SUMMONS Issued as to The Partnerships and all other Defendants identified in the Complaint

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Lucas Allen Peterson

CIVIL BOND in the amount of $ 10,000 posted by Toyota Motor Sales, U.S.A., Inc. (Document not imaged).

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction 25

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 26

(Exhibit 1)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 25 before Honorable Elaine E. Bucklo on 7/17/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 7/11/2024, answer due 8/1/2024.

Declaration Lucas A. Peterson

(Exhibit A)

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction as to certain defendants [25] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Teena Bohi [15], and the TRO [21] are unsealed. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 7/23/2024. Mailed notice.

NEW PARTIES: Foshan Shirui Trading Company Ltd, Guangzhou Bohang Film Co., Ltd., Guangzhou Fengqin Trading Co., Ltd., Guangzhou Fuxuan Auto Accessories Co., Ltd., Guangzhou Hongcar Electronics Technology Co., Ltd., Guangzhou Jiachi Trading Co., Ltd., Guangzhou Jinyi Electronic Technology Co., Ltd., Guangzhou Tesila Automobile Products Co., Ltd., Jinan Yihui Automobile Co., Ltd., Ma'anshan Tengxin Import And Export Trading Co., Ltd., Ma'anshan Xinze Import And Export Trading Co., Ltd., Shenzhen Me Booming Innovate Technology Co., Ltd., Yiwu Jin'ai Commodity Firm, A12N2M2N8IATK6, A2PHG0AAXI3K32, Amozan.cam US, AUYXO1T86G59P, caoywlll, DongLiyuan, FengLonga, guangzhougongdunshangmaoshanghang, handwork shop, jingmenshiyuejinshangmao, jinyueyu, jubaofu, JYXSSMJYB, k.L.L, kuangtengbaihuodian, kunmingqingquanguojishangmaoyouxiangongsi, linglanhuadianzi, liqibo, LiuXiang-US, lzyus, nuomaiqihuikeji, quanhuimaoyi, RicFarb, SerhooHazo, suchunhuajiali, TIANCILEW, TIANHEYUAN, Tom's small Shop, wenzhidianzi, WWWSHop, xinchuangkefeisi, yangzhuzhebaihuodian, Youi car products, yuanwangjiaohuan, zhangzilinranhouta, zhengzhoumiaorushangmaoyouxiangongsi, aa03bms, anyautopart, AUTO-PPCF, autotester23, Big selling shops, bms7216, bodyboomm, breezehair86, business_autoparts, carparts_create, chassiss, daishuyao, decalbase, duan5624, e-bay-autoparts, faverautoparts, faverparts, fereat-motors, flarestar, fzkadou-88, heatparts23, heatsupply, hello.hcir, HFF, homedream2023, jecdg2, lihua-autopart, lihua-genuine, mlihu-89, nanly_25, nua_6138, nymengmeng, perfectallhere, perfectbeautys, pomtr_7, qingyabazaar, taking, tingdanyu6, toly357, TOP-LEDlight, toptop-autoparts, tyllq, ultravision9, wanyibei, willowly, wols_9792, xsfbigseller-us, yayiba88, yunxun2, ihesh shop and xinweiying added to case caption.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 7/25/2024, answer due 8/15/2024.

Declaration of Lucas A. Peterson

(Exhibit A)

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

STATUS Report Pursuant to [20] by Toyota Motor Sales, U.S.A., Inc.

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report, plaintiff reports active settlement negotiations with several defendants. Status hearing is reset for 9/19/2024 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 9/12/2024. The court will enter a scheduling order in response to the status report. Mailed notice.

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for entry of default, MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for default judgment as to all Defendants with the exception of certain Defendants

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment, [39]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[40]

Exhibit 1

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. to approve consent judgment as to Certain Defendants

Exhibit A

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, [39] before Honorable Elaine E. Bucklo on 8/22/2024 at 09:45 AM.

Exhibit A

NOTICE of Motion by Trevor Christian Talhami for presentment of motion to approve consent judgment[42] before Honorable Elaine E. Bucklo on 8/22/2024 at 09:45 AM.

Exhibit A

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment as to all remaining defendants with the exception of certain defendants [39] is granted. Enter Final Judgment Order. Agreed motion for entry of consent judgment as to certain defendants [42] is granted. Enter Consent Judgment. The ten thousand dollar ($10,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 8/22/2024. Mailed notice.

CONSENT JUDGMENT signed by the Honorable Elaine E. Bucklo on 8/22/2024. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

FULL SATISFACTION of Judgment regarding order 47 in the amount of $100,000 as to certain defendants

Notice of Removal of Material from the Custody of the Clerk's Office by Greer, Burns & Crain, Ltd. (Doc 24- Civil Bond). (Received by Intake Counter on 8/29/24).

FULL SATISFACTION of Judgment regarding order 47 in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 47 in the amount of $100,000 as to certain defendants