2024-cv-07505

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-22384777.

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 Lucas Allen Peterson

CASE ASSIGNED to the Honorable Jeremy C. Daniel. 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.

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[13]

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

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Teena Bohi regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 3 Parts 1-2 regarding declaration[16]

Exhibit 3-1

(Exhibit 3-2)

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[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 temporary restraining order[13], motion for miscellaneous relief[18], motion for leave to file[3] before Honorable Jeremy C. Daniel on 8/28/2024 at 09:30 AM.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Kahlia Roe Halpern

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. The plaintiff's motions for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13] and motion for electronic service of process pursuant to FED.R.CIV.P. 4(f)(3) [18] are granted. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 8/28/2024. Mailed notice.

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

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

SURETY BOND in the amount of $ 10,000.00 posted by Toyota Motor Sales, U.S.A., Inc. (Document not scanned).

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of extension of time[27]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[28]

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time[27] before Honorable Jeremy C. Daniel on 9/11/2024 at 09:30 AM.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Andrew Daniel Burnham

EXTENSION OF TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 9/11/2024. Motion hearing held. Plaintiff's motion to extend the temporary restraining order [27] is granted. The TRO now expires on 9/25/2024. Mailed notice.

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

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction[35]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[36]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[35] before Honorable Jeremy C. Daniel on 9/25/2024 at 09:30 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 9/20/2024, answer due 10/11/2024.

Declaration of Lucas A Peterson

Exhibit A

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 9/25/2024. Motion hearing held. Plaintiff's motion for entry of a preliminary injunction [35] is granted. The plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on court's website located at www.ilnd.uscourts.gov/instructions. Mailed notice.

NEW PARTIES: Anhui Pingyao Trading Co., Ltd., Dongguan Lebei Craft Products Co., Ltd., Guangzhou Bosen Textile Co., Ltd., Guangzhou Teaimei Trade Development Co., Ltd., Guangzhou Toni Auto Parts Co., Ltd., Hadson Auto Parts (foshan) Co., Ltd., LONG-TIME METAL & CRAFTS CO., LTD, Suzhou Custom Garment Accessory Co., Ltd., Wenzhou Feisheng Crafts Co., Ltd., Yiwu Chiwang Technology Co., Ltd., A3112ECJDO3KEU, Asel store, chengduzhongkunguangliangkejiyouxiangongsi, hefeibangrongshangmaoyouxiangongsi, Hefeitongjiamaoyiyouxiangongsi, honghuus, Jupiterise, kunmingwuhuaqumingchenpashangmaoyouxiangongsi, liuliangliang2024, nanningshimoranwenhuachuanmeiyouxiangongsi, PARTEN, pengliu, TarkoAuto, Unifolectron, wwvjjjxxx, Xinshop-us, yangfushangmaoyouxiangongsi, ZeYunWan, 0zhongjian, AOSTIRMOTOR OFFICIAL STORE, Auto Axle, auto-bestone, auto-brake, automotors_cyltd, autoparts-doris, BULL MOTORS, chenqingwangluo2024, Conscience Shop, czauto-1, d5014334, factory-motors, FZB887, hcxzxy, heatautopart, hezi-auto, infiniteltd_us, iwuhuaquhua, lifehouse66, muqoptic, nfrebr, oemparts_2207, oldda08, pro-auto-parts_2, relang, rosier-660, shipautoparts1, syujs07, Technology-auto, wangzhiqiang-5416, yvaine-us, zmy-kaden, zvr764, Xunze, qingyunxianqinhaoshoujixiaosh, ANNIJS11, asjioicje, bfurkdp, gcailaizou, Le Bellece, luqinghuaicu, qapock, vhufhuc, wangjinglo, wrdifhih and XIAOYAOLU added to case caption.

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

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

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to a Certain Defendant

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

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment[44]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment[44] before Honorable Jeremy C. Daniel on 10/22/2024 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin Tyler Joseph

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 10/22/2024. Motion hearing held. Plaintiff's motion for entry of default and default judgment [44] is granted. Civil case terminated. Mailed notice.

MAILED trademark report with order dated 10/22/2024 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case 49 in the amount of $50,000 as to certain defendant

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Toyota Motor Sales, U.S.A., Inc. to Greer, Burns & Crain Ltd. 200 West Madison St Suite 2100 Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7784 99.

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case 49 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case 49 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case 49 in the amount of $50,000 as to certain defendant