2025-cv-06646

COMPLAINT filed by Robert Bosch Gmbh and Robert Bosch LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23631974.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Robert Bosch Gmbh and Robert Bosch LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Robert Bosch Gmbh and Robert Bosch LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Robert Bosch Gmbh and Robert Bosch LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Robert Bosch Gmbh and Robert Bosch LLC by John Wilson

ATTORNEY Appearance for Plaintiff Robert Bosch Gmbh and Robert Bosch LLC by Elizabeth Aubree Miller

MOTION by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Robert Bosch Gmbh and Robert Bosch LLC

Notice of Claims Involving Trademarks by Robert Bosch Gmbh and Robert Bosch LLC

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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.

NEW PARTIES: zhou office, yushunhw, Wenzhou Ouxun Electronic Techn, Super Parts BB, mingchi, lansoubaihuo, JNUO auto parts, hengrunn, First specials local, Roxy, foshanshijiadanhumaoyi, Tartikaily, chaohongtaimaoyi, zzbjhs, Yurney, Wondersmith, tongyingfushi, szdilanqianshi, suohongjixieshebei, niutiandianzi, jiujiangzhiguoguishangmaoyouxiangongsi, houepaixun1967511l, XCJKFHAA, WZHENGYI, New domestic, KEWITY, Indian Blessings, VERDEXXL, yahegochengeg, YIMA MALL, runhuayour, Performance Basic, Lulemay, KenanKe Parts, PANGUL, LANshikeji, Adabus, yinsx, MOUNTAIN RAIN, Limbs, Hamos, GET OFF, BEST, zhangxiancun, ZFD Auto Parts, XvvvX, Mxyangyi, huangfujun, Fengfengxia, fengfengjian and Ezify Homeware added to case caption.

NEW PARTIES: DJDJDW, dingbailiang, AutoPartsProVV, Oemassive-direct, Nilight Autos, Manruonan Trading Co., Ltd., LONGKUO E-COMMERCE Co.ltd, Lixinda Co. Ltd, Kkonetoy, Jinruis, FEIYIJIA HOME, CCIYU, Spider Super Store, speedygo2020, RASTuningParts, JINLANKEJI CO.LTD, Jarbalai, HYZ SERVICE, huizhoushichengqiandianziyouxiangongsi, HuiGood, Happy Notebook Store, gulatiautotrader, FITHOOD, Chanjuan Co., Ltd., SHMPSM Co.Ltd, ZIXMMO, ziteng123, zhushanele, ZhuhaiChonglihulianwangkeji Co.Itd, Zachager, yusen132, YOUNG188, yongjianbbdgasj, wqlelaishangmaoyouxiangongsi, WPCS2022, weifangwubaowangluokejiyouxiangongsi, WEASCH, UMcar, susongxiancaianbaihuoshanghang, SmartHouzzz Direct, shanliyijianzahuodian, REM-Store, OEMPartsUSA, OEMASSIVE, MQparts LLC, Ly Tran INC, Kaifa elec, JornKery Direct, IRHAPSODY Store, HMC Maoyi, Hisenic, guangchengbaiguoshanghang, FUQUANU, DEWHEL Direct, Delgado Store, BiliaoStove, Baixinde and Auto Dianke Parts added to case caption.

MOTION by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC 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 Robert Bosch Gmbh and Robert Bosch LLC in support of motion for temporary restraining order, 13

Declaration Paragoso Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED EXHIBIT by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC Exhibit 2 Part 1 of Paragoso Declaration regarding memorandum in support of motion, 14

SEALED EXHIBIT by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC Exhibit 2 Part 2 of Paragoso Declaration regarding memorandum in support of motion, 14

SEALED EXHIBIT by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC Exhibit 2 Part 3 of Paragoso Declaration regarding memorandum in support of motion, 14

SEALED DOCUMENT by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC Exhibit 2 Part 4 of Paragoso Declaration

SEALED EXHIBIT by Plaintiff Robert Bosch Gmbh and Robert Bosch LLC Exhibit 2 Part 5 of Paragoso Declaration regarding memorandum in support of motion, 14

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 13, motion for leave to file excess pages 12, motion to seal document 8 before Honorable Jorge L. Alonso on 6/25/2025 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 8 12 13 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $116,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 6/25/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 6/25/2025. Notice mailed by Judge's staff

MOTION by Plaintiff Robert Bosch GMBH for extension of time Plaintiff's Ex-Parte Motion to Extend the Temporary Restraining Order

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 25 before Honorable Jorge L. Alonso on 7/9/2025 at 09:30 AM.

SURETY BOND in the amount of $ 116,000 posted by Robert Bosch GMBH (document not imaged)

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order 25 is granted. The temporary restraining order is extended for 14 days to 7/23/25. Motion hearing date of 7/9/25 is stricken. Telephonic status hearing set for 7/23/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ORDER To Extend The Temporary Restraining Order. Signed by the Honorable Jorge L. Alonso on 7/8/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

SUMMONS Issued (Court Participant) as to Defendant Auto Dianke Parts and all other Defendants identified in the Complaint

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 107

MOTION by Plaintiff Robert Bosch GMBH for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Robert Bosch GMBH in support of motion for preliminary injunction 34

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 34

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 34 before Honorable Jorge L. Alonso on 7/23/2025 at 09:30 AM.

CERTIFICATE of Service by Elizabeth Aubree Miller on behalf of Robert Bosch GMBH

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 9/4/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiffs' Motion for entry of a preliminary injunction 34 is granted. Enter Preliminary injunction order. The Clerk's office is directed to unseal all previously sealed documents. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 7/23/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 2

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 29

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendants FUQUANU, ZIXMMO by Yong Chen

MOTION by Defendants FUQUANU, ZIXMMO for extension of time to file answer regarding complaint 1 UNOPPOSED

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Robert Bosch GMBH Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 72