2024-cv-10464

COMPLAINT filed by Brabus GmbH; Jury Demand. Filing fee $ 405, receipt number AILNDC-22609514.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Brabus GmbH by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Brabus GmbH by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Brabus GmbH by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Brabus GmbH by John Wilson

MOTION by Plaintiff Brabus GmbH to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Brabus GmbH Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Brabus GmbH

CASE ASSIGNED to the Honorable Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MOTION by Plaintiff Brabus GmbH for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Brabus GmbH for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Brabus GmbH in support of motion for temporary restraining order, 11

Declaration Hosters Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 1 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 2 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 3 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 4 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 5 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 6 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 7 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 8 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 9 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 10 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 11 of Hosters Declaration

Notice of Claims Involving Trademarks by Brabus GmbH

MINUTE entry before the Honorable Rebecca R. Pallmeyer: A telephone conference hearing is set for 10/21/2024 at 12:45 p.m. regarding Plaintiff's motions 7 10 11. To join the telephone hearing, please dial (877) 336-1839 and enter access code: 6708061#. Instructions and a link to the conference number are located on Judge Pallmeyer's website. 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.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Telephone motion hearing held. For the reasons stated on the record, the complaint 1 is stricken, as it provides no notice of the nature of Plaintiff's claimed intellectual property or of the alleged infringement. A review of the attached exhibits might enable to the court to make determinations, but it is Plaintiff, not the court, that is responsible for drafting a short and plain statement of the claim for relief. Plaintiff's oral motion for leave to file an amended complaint within seven days is granted. Plaintiff's pending motions 7, 10, and 11 are stricken without prejudice. Mailed notice.

AMENDED complaint by Brabus GmbH against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Brabus GmbH Sealed Schedule A

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff has filed an amended complaint but has not proceeded with service or filed any renewed motion; counsel is directed to advise the court within 14 days whether Plaintiff intends to proceed further. Mailed notice.

STATUS Report by Brabus GmbH

MOTION by Plaintiff Brabus GmbH to seal document Plaintiff's Motion for Leave to File Under Seal

MOTION by Plaintiff Brabus GmbH for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Brabus GmbH for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Brabus GmbH in support of motion for temporary restraining order, 34

Declaration Hosters Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 1 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 2 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 3 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 4 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 5 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 6 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 7 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 8 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 9 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 10 of Hosters Declaration

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit 2 Part 11 of Hosters Declaration

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's renewed motion for leave to file under seal 32 is granted. Plaintiff's motion to exceed page limitation 33 is granted. Plaintiff's renewed ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 34 is granted. Order to enter. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Rebecca R. Pallmeyer on 2/7/2025.

MOTION by Plaintiff Brabus GmbH for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

SURETY BOND in the amount of $ 50,000.00 posted by Brabus GmbH

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Ex-Parte Motion To Extend the Temporary Restraining Order 49 is granted. The Temporary Restraining Order is extended to March 7, 2025. Mailed notice.

MOTION by Plaintiff Brabus GmbH for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Defendant Nos. 1-111

MEMORANDUM by Brabus GmbH in support of motion for preliminary injunction 53

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 53

MOTION by Plaintiff Brabus GmbH for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

(Exhibit B)

SEALED DOCUMENT by Plaintiff Brabus GmbH Exhibit A

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

SUMMONS Returned Executed by Brabus GmbH as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 3/4/2025, answer due 3/25/2025.

ATTORNEY Appearance for Defendants Guangzhou Yuantuo Trading Co., Ltd, Guangzhou Explorer Auto Parts Co., Ltd by Adam Edward Urbanczyk

MOTION by Defendants Guangzhou Explorer Auto Parts Co., Ltd, Guangzhou Yuantuo Trading Co., Ltd to set a briefing schedule re: [Dkt. 53] and unseal [Dkts. 36-46 and 57].

ATTORNEY Appearance for Defendants Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltd by Adam Edward Urbanczyk

ATTORNEY Appearance for Defendants Guangzhou Explorer Auto Parts Co., Ltd, Guangzhou Yuantuo Trading Co., Ltd by Adam Edward Urbanczyk

NOTICE by Guangzhou Explorer Auto Parts Co., Ltd, Guangzhou Yuantuo Trading Co., Ltd re MOTION by Defendants Guangzhou Explorer Auto Parts Co., Ltd, Guangzhou Yuantuo Trading Co., Ltd to set a briefing schedule re: [Dkt. 53] and unseal [Dkts. 36-46 and 57]. [62] withdrawal of motion

MOTION by Defendants Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltd to set a briefing schedule re: Dkt. 53, and unseal Dkts. 36-46 and 57

MOTION by Defendants Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltd to set a briefing schedule re: Dkt. 53, and unseal Dkts. 36-46 and 57, Amended

MINUTE entry before the Honorable Rebecca R. Pallmeyer: On the court's own motion and by agreement of the parties, an in-person hearing is set for 3/20/2025 at 2:00 p.m. in courtroom 2503 regarding pending motions. Mailed notice.

ATTORNEY Appearance for Defendant Ningbo Summer Auto Parts Co. Ltd. by Jianyin Liu

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendants Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltd by Brian Swift

MOTION by Plaintiff Brabus GmbH for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Brabus GmbH in support of motion for preliminary injunction[72]

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction[72]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: In-person hearing on Plaintiff's motion for preliminary injunction. That motion [53, 72] is stricken without prejudice. In response to the court's request for hard copies of the exhibits, Plaintiff produced a box full of pages without page numbers or tab, making the court's review very difficult. In a spot-check of some of these documents, the court found materials that appear to advertise after-market products "compatible with" Plaintiff's or products that otherwise do not appear to be infringing. Plaintiff has leave to submit a revised motion, but counsel is expected to certify that an attorney has reviewed the exhibits and is satisfied that its claims against each Defendant comply with Federal Rule of Civil Procedure 11. Defendant Changzhhou 's motion to set a briefing schedule [66, 67] is granted. The clerk is directed to unseal docket entries [36] through [46] and [57]. Plaintiff 's response is due by close of business on March 21, 2025; reply, if any, to be filed on March 28, 2025. Mailed notice.

ATTORNEY Appearance for Defendant Chengdu Jiangzao Auto Parts Co., Ltd. by Pete Scott Wolfgram

MOTION by Defendant Ningbo Summer Auto Parts Co. Ltd. to dismiss for lack of jurisdiction

AMENDED MINUTE entry before the Honorable Rebecca R. Pallmeyer : In-person hearing on Plaintiff's motion for preliminary injunction. That motion [53, 72] is stricken without prejudice. In response to the court's request for hard copies of the exhibits, Plaintiff produced a box full of pages without page numbers or tab, making the court's review very difficult. In a spot-check of some of these documents, the court found materials that appear to advertise after-market products "compatible with" Plaintiff's or products that otherwise do not appear to be infringing. Plaintiff has leave to submit a revised motion, but counsel is expected to certify that an attorney has reviewed the exhibits and is satisfied that its claims against each Defendant comply with Federal Rule of Civil Procedure 11. Defendant Changzhhou 's motion to set a briefing schedule [66, 67] is granted. The clerk is directed to unseal docket entries 36 through 46 and 57. Defendant's response is due by close of business on March 21, 2025; reply, if any, to be filed on March 28, 2025. (Amended minute order entered on 3/20/2025 [75] correcting last sentence). Mailed notice.

RESPONSE by Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltdin Opposition to MOTION by Plaintiff Brabus GmbH for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Against Defendant Nos. 1-111 [53]

Declaration of Suqin Meng

DECLARATION of Lina Guo regarding motion to dismiss/lack of jurisdiction[77] in Support of Motion to Dismiss

MINUTE entry before the Honorable Rebecca R. Pallmeyer: The court sets a briefing schedule for Defendant Ningbo Summer Auto Parts Co.'s motion to dismiss [77]: Response is due by 4/14/2025; and reply by 4/21/2025. Mailed notice.

MOTION by Defendants Changzhou shengyu auto parts Co.,Ltd, Changzhou pullo vehicle accessories Co.,Ltd to dismiss for lack of jurisdiction (personal)

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Rebecca R. Pallmeyer: As agreed by the parties, the following briefing schedule is set for Defendants' motion to dismiss [82]: Response is due by 4/24/2025; and reply by 5/1/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Plaintiff Brabus GmbH for preliminary injunction Plaintiff's Renewed Motion for Entry of a Preliminary Injunction Against Certain Defendants

MEMORANDUM by Brabus GmbH in support of motion for preliminary injunction[86]

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction[86]

Certification by Brabus GmbH

MINUTE entry before the Honorable Rebecca R. Pallmeyer: On the court's own motion, a telephone hearing is set on 4/9/2025 at 9:00 a.m. for Plaintiff's renewed motion for entry of a preliminary injunction [86]. To join the telephone hearing please dial 1-650-479-3207 or 1-855-244-8681 (toll free) and enter access code 2313 755 6066##. 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.

RESPONSE by Defendants Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltd in opposition to Plaintiff's Renewed Motion for Entry of a Preliminary Injunction [Dkt. 86]

RESPONSE by Chengdu Jiangzao Auto Parts Co., Ltd.in Opposition to MOTION by Plaintiff Brabus GmbH for preliminary injunction Plaintiff's Renewed Motion for Entry of a Preliminary Injunction Against Certain Defendants [86]

Declaration of Liuxinfu

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Telephone motion hearing convened. As the court noted, exhibits presented in support of Plaintiff's motion for preliminary injunction confirm that many of the Defendants are marketing products "compatible for" or "compatible with" Plaintiff's products. A reasonable consumer would not be confused by this language or misled to believe that Plaintiff is the source, particularly because the Amazon listings in question often identify the supplier. The court expects counsel to take care before seeking to enjoin what appears to be legitimate activity. The motion for preliminary injunction [53, 72, 86] and motion to extend the TRO [56] are denied without prejudice to renewal as against Defendants that Plaintiff alleges, consistent with Rule 11, are infringing. The next telephone status hearing is set for 6/12/2025 at 11:00 a.m. To join the telephone hearing please dial 1-650-479-3207 or 1-855-244-8681 (toll free) and enter access code 2313 755 6066##. 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.

RESPONSE by Plaintiff Brabus GmbH Plaintiff's Response to Defendant's Motion to Dismiss [Dkt. No. 77]

Exhibit A

Exhibit B

REPLY by Ningbo Summer Auto Parts Co. Ltd. to MOTION by Defendant Ningbo Summer Auto Parts Co. Ltd. to dismiss for lack of jurisdiction [77]

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Chengdu Jiangzao Auto Parts Co., Ltd. pursuant to R. 12(b)(6) and 12(b)(2)

Exhibit A

Declaration of Liuxinfu

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Rebecca R. Pallmeyer: The following briefing schedule is set for Defendant Chengdu Jiangzao Auto Parts Co., Ltd's motion to dismiss [97]: Plaintiff's response is due by 5/20/2025; reply due by 6/3/2025. Mailed notice.

RESPONSE by Plaintiff Brabus GmbH Plaintiff's Response to Defendants' Motion to Dismiss [Dkt. No. 82]

Exhibit Group Exhibit A

Exhibit B

ATTORNEY Appearance for Defendant Chengdu Qiangwujia Auto Parts Co., Ltd. by Xingyi Tao

MOTION by Defendant Chengdu Qiangwujia Auto Parts Co., Ltd. to join Defendant Chengdu Jiangzao Auto Parts Co., Ltd.s Motion to Dismiss

Exhibit A

Exhibit B

REPLY by Defendants Changzhou pullo vehicle accessories Co.,Ltd, Changzhou shengyu auto parts Co.,Ltd to Response[100]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Without objection, Defendant's motion to consolidate and join defendant Chengdu Jiangzao Auto Parts Co, Ltd.'s motion to dismiss 102 is granted. Mailed notice.

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 116

RESPONSE by Plaintiff Brabus GmbH Plaintiff's Response to Defendants' Motion to Dismiss [Dkt No. 82]

Exhibit 1

Exhibit 2

(Exhibit 3)

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 77

REPLY by Defendant Chengdu Jiangzao Auto Parts Co., Ltd. to Motion to Dismiss for Failure to State a Claim[97]

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 36

MINUTE entry before the Honorable Rebecca R. Pallmeyer:Telephone motion hearing convened. For the reasons stated on the record, the court grants the following defendants' motions to dismiss. With respect to Defendants whose products are "for" or "compatible with" Plaintiff's products, the court does not believe Plaintiff has alleged infringement or a likelihood of confusion. With respect to Defendants who have engaged in no transactions in Illinois and have no other contacts here, the court lacks personal jurisdiction: Defendant, Chengdu Jiangzao Auto Parts Co. Ltd.'s [97], Defendant Chengdu Qiangwujia Auto Parts Co., Ltd. [102] joining Motion [97]; Defendants' Changzhou Pullo Vehicle Accessories Co., Ltd, Changzhou Shengyu Auto Parts Co., Ltd [82], and Defendant, Ningbo Summer Auto Parts Co. Ltd. [77]. Defendants' motion for a briefing schedule on Plaintiff's motion for preliminary injunction [62] is withdrawn without prejudice. Plaintiff's further submissions in this case will be filed no later than June 26, 2025. The court notes that compliance with Rule 11 requires that Plaintiff's counsel review evidence in support of its claims as against each Defendant before filing a complaint or motion against that Defendant. This is the responsibility of counsel, not of the court. Mailed notice.

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 71

MOTION by Plaintiff Brabus GmbH for preliminary injunction Plaintiff's Renewed Motion for Entry of a Preliminary Injunction Against Defendants

MEMORANDUM by Brabus GmbH in support of motion for preliminary injunction[112]

Exhibit 3

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction[112]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion for preliminary injunction [112] is granted. The Clerk's Office is directed to unseal Plaintiff's Schedule A to the Amended Complaint [Dkt. No. [28]], Exhibit 2 to the Declaration of Stefan Gerhard Hosters [Dkt. Nos. [36]-46] and the TRO [Dkt. No. [48]]. Enter Order. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Rebecca R. Pallmeyer on 6/27/2025. Mailed notice

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Minute entry and orders [115] and [116] are stricken as entered in error. The Clerk is directed to remove the order [116] from the docket. An in person motion hearing on the motion for preliminary injunction [112] is set for 7/2/2025 at 9:45 a.m. Mailed notice

ATTORNEY Appearance for Plaintiff Brabus GmbH by Elizabeth Aubree Miller

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Rebecca R. Pallmeyer: In-person motion hearing convened. As stated on the record, Plaintiff's renewed motion for entry of a preliminary injunction against all defendants [112] is granted as follows: Plaintiff to add language specifying the freeze of assets are only with respect to assets traceable to the subject infringing activity. Plaintiff is directed to submit a proposed preliminary injunction with these revisions. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 7/3/2025. Mailed notice.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: The Clerk of the Court is directed to unseal: Plaintiff's Schedule A to the Amended Complaint [Dkt. No. 28], Exhibit 2 to the Declaration of Stefan Gerhard Hosters [Dkt. Nos. 36-46] and the TRO [Dkt. No. 48], per Preliminary Injunction Order entered on 7/3/25 125. The Law Firm of Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add all defendant names listed in Schedule A to the docket within three business days. 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. Mailed notice.

MOTION by Plaintiff Brabus GmbH for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Brabus GmbH for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

Exhibit A

MEMORANDUM by Brabus GmbH in support of motion for default judgment[128]

Exhibit 1

Exhibit 2

DECLARATION of Michael A. Hierl regarding motion for default judgment[128]

Exhibit Hierl Exhibit 1

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion to exceed page limitation [127] is granted. Plaintiff is directed to file a brief supplemental memorandum explaining in greater detail why the proposed judgment amount of $150,000 is appropriate with respect to each defendant or group of defendants. Mailed notice.

MEMORANDUM by Brabus GmbH Plaintiff's Supplemental Memorandum in Support of at Least $30,000 Damage Award Per Defaulting Defendant

Amended Schedule A Part 1

Amended Schedule A Part 2

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

Exhibit F

Exhibit G

NOTICE of Voluntary Dismissal by Brabus GmbH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants