2025-cv-06721

COMPLAINT filed by Detroit Diesel Corporation, Daimler Truck AG, Thomas Built Buses, Inc., Daimler Truck North America LLC; Filing fee $ 405, receipt number AILNDC-23638548.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Trevor C. Talhami

Declaration of Hannah A. Abes

(Exhibit A)

Exhibit 1

(Exhibit 1)

SEALED EXHIBIT by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. Schedule A regarding complaint[1]

Exhibit A

(Exhibit 2-1)

MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc.

Notice of Claims Involving Trademarks by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc.

ATTORNEY Appearance for Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

NEW PARTIES: dunjingjing, liujing-Business, TWO MAI, xiaoxi202512, xiejun-nj, Carcoresolutions, jiangji8, lingling69, mengbo-auto, ProPartsMasters, SpeadsStar-zone, ta-558789, aggbang, Airy Garments, Aluminum Home Decor, Apricot whale, banahuo, Blossom AK, BOYIQIUBAIHUO, Bright car stickers, Brown whale, CABA Online, Cast iron art decoration painting, catgood, CBENGALCBD, Changes clothes, chanliuji, chanqiqi, chanyuyu, Chen Acrylic, Civic Couture, Clothes Collector, colored sika deer, Cousin car decal small world, createfantasy, Custom aluminum skin painting, Cyan waves, Darks Tiger, DDAMAIAA, DLKOIJXC, DPDC GlobalLink, DYIQWJHB, Easy lane Athree, enging, EWTGEW SHOP, Fanyushe, Fashion Hunter A, Fashion Sunshine and fenggegao added to case caption. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. in support of motion for temporary restraining order, [13]

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

DECLARATION of Sven-Eric Widmayer regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. Exhibit 2 regarding declaration[16]

MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. in support of motion for miscellaneous relief[18]

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

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs' Motion for Leave to File Under Seal [3], Motion For Electronic Service Of Process Pursuant To Fed. R. Civ. P. 4(f)(3), and Plaintiffs' Ex Parte Motion For Entry Of A Temporary Restraining Order, Including A Temporary Injunction, A Temporary Asset Restraint, And Expedited Discovery [13] are granted. Enter sealed order. Telephonic hearing set for 7/1/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 6/20/2025. Emailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc.

Registry Deposit Information Form by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. in support of extension of time 26

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 27

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs' Ex Parte Motion To Extend The Temporary Restraining Order 27 is granted. The TRO entered on 6/20/2026 22 is extended through 7/18/2025. Telephonic hearing set for 7/1/2025 is stricken and reset to 7/17/2025 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable Robert W. Gettleman on 6/26/2025. Emailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc.

MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for preliminary injunction

MEMORANDUM by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. in support of motion for preliminary injunction[32]

SUMMONS Returned Executed by Detroit Diesel Corporation, Daimler Truck AG, Thomas Built Buses, Inc., Daimler Truck North America LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/7/2025, answer due 7/28/2025.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 7/17/2025. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiffs' Motion for Entry of a Preliminary Injunction [32] is granted. Enter order. The Law Firm of Greer, Burns & Crain Ltd., 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: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf The Clerk is directed to unseal Schedule A to the Complaint [2], Seller Aliases screenshots attached to the Declaration of Sven-Eric Widmayer [17] and the TRO [22]. Telephonic hearing set for 8/28/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 1809 88 3385. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 7/17/2025. Emailed notice

NOTICE of Voluntary Dismissal by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. as to certain defendants

MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for entry of default, MOTION by Plaintiffs Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. for default judgment as to all Defendants

MEMORANDUM by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. in support of motion for entry of default, motion for default judgment, 38

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion, 39

ATTORNEY Appearance for Defendant Carcoresolutions by Christopher Paul Keleher

MOTION by Defendant Carcoresolutions for extension of time to file answer regarding complaint[1] (Opposed)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 8/28/2025. No defense counsel appeared., Based on counsel's representation that defendant Carcoresolutions will be dismissed, First Motion of Defendant for Extension of Time to Answer or Plead [42] is stricken as moot. For the reasons stated on the record Plaintiffs' Motion for Entry of Default and Default Judgment as to All Remaining Defendants [38] is granted. Enter Judgment order. The Clerk is directed to return the ten thousand dollar ($10,000) surety bond posted by Plaintiff is hereby released to Plaintiffs or their counsel, Greer, Burns & Crain, Ltd. 200 West Madison St, Suite 2100, Chicago, IL 60606. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 8/28/2025. Emailed notice

NOTICE of Voluntary Dismissal by Daimler Truck AG, Daimler Truck North America LLC, Detroit Diesel Corporation, Thomas Built Buses, Inc. as to certain defendant