2025-cv-07437

COMPLAINT filed by FCA US LLC ; Filing fee $ 405, receipt number AILNDC-23701067.

Exhibit 1

Exhibit 1

Exhibit 2-1

(Exhibit A)

Declaration of Hannah A. Abes

Exhibit A

Appendix List of Parties on whose behalf the appearance is filed.

Exhibit Store representative declarations and platform screenshots

Exhibit Amazon listing

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiff FCA US LLC Schedule A regarding complaint[1]

(Exhibit 2-2)

(Exhibit A)

Exhibit Store representative declarations and platform screenshots

Exhibit Amazon listing

Exhibit 2

MOTION by Plaintiff FCA US LLC for leave to file under seal

Exhibit Store representative declarations and platform screenshots

Exhibit Amazon listing

CIVIL Cover Sheet

Exhibit Summary of figures

Exhibit Amazon listing

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FCA US LLC

Exhibit Amazon listing

Notice of Claims Involving Trademarks by FCA US LLC

Exhibit Amazon listing

ATTORNEY Appearance for Plaintiff FCA US LLC by Justin R. Gaudio

Exhibit Amazon listing

ATTORNEY Appearance for Plaintiff FCA US LLC by Amy Crout Ziegler

Exhibit Amazon listing

ATTORNEY Appearance for Plaintiff FCA US LLC by Berel Yonathan Lakovitsky

Exhibit Amazon listing

ATTORNEY Appearance for Plaintiff FCA US LLC by Hannah Alexa Abes

Exhibit Amazon listing

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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.)

NEW PARTIES: 365autoparts, AdultUS, AJUNJIIL, Arcosucu, AUTOMOVE, AutoRiverMap STORE, bigbangauto, BlueSkyz SHOP, BRLUCKY, Bufeeters, byictpc, Chenglanhsjg, CloudLampShop, CogitoErgoSum Autocarft Store, dahuixiong, Dawn Jade, DIDUO SHOP, DTJFKJ, DXSTREW, GaoYoushangmao, GaweGuru, GGD AutoStore, GTAL Autoparts, HAOXINQI, HELIHL, hongparts, Huawen Hansheng Network Technology Co., Ltd, HUILIZHONGCHENG, Iminecomm, jian's automotive, aksakahparts, AUTO GLOBEASE, Auto Plus 03Store, autoall1, auto-car-hui, Autofan-zone, AutoFit Supply, auto-jks, automaker-sales, autoparts-5a, bellpartss, billiontons, carlei014, car-shop69, cydazzling, Drivexyzpert-zone, erhaiou, feelingauto, garciaya, GearNestMaster, huang caixia, James-us3, Artistic Print Tee Boutique, BASEHAIRTIII, Dazzle Decor, FIERCE MAN TSHIRT, GracefulM, HPNY mall, dajun Zhong and Drimzate Furniture added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff FCA US LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

Exhibit Amazon listing

MEMORANDUM by FCA US LLC in support of motion for temporary restraining order[11]

Exhibit Amazon listing

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

Exhibit Amazon listing

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion[12]

Exhibit Amazon listing

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Parts 1-2 regarding declaration 14

Exhibit Amazon listing

MOTION by Plaintiff FCA US LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

Exhibit Amazon listing

MEMORANDUM by FCA US LLC in support of motion for miscellaneous relief[16]

Exhibit Amazon listing

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

Exhibit Amazon listing

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 16 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order 11 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 7/21/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 7/16/2025. Mailed notice.

Exhibit ND Illinois Judge Alonso Order

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 7/7/2025.

Registry Deposit Information Form by FCA US LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff FCA US LLC

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and all other Defendants identified in the Complaint

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

SURETY BOND in the amount of $ 10,000 posted by FCA US LLC (Document not scanned)

MOTION by Plaintiff FCA US LLC for extension of time of Temporary Restraining Order

MEMORANDUM by FCA US LLC in support of extension of time 27

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion 28

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/15/2025, answer due 8/5/2025.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of the temporary restraining order [27] is granted; the ex parte TRO entered by the Court on 7/7/2025 is extended through 8/4/2025. The telephonic preliminary injunction hearing set for 7/21/2025 is vacated and reset to 8/4/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction must be filed by 7/31/2025. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

MOTION by Plaintiff FCA US LLC for preliminary injunction

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction[32]

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[33]

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or an answer or a response to the motion for preliminary injunction. The telephonic preliminary injunction hearing set for 8/4/2025 is vacated. Plaintiff's motion for preliminary injunction 32 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. 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. 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 telephonic status hearing on 10/8/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 10/1/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 7/30/2025:. Mailed notice.

ATTORNEY Appearance for Defendants 365autoparts, Arcosucu, AutoRiverMap STORE, BRLUCKY, BlueSkyz SHOP, CloudLampShop, CogitoErgoSum Autocarft Store, DTJFKJ, Dawn Jade, GGD AutoStore, GTAL Autoparts, GaoYoushangmao, HAOXINQI, Huawen Hansheng Network Technology Co., Ltd, bigbangauto, byictpc, hongparts, jian's automotive by Xiaojun Wang

MOTION by Defendants 365autoparts, Arcosucu, AutoRiverMap STORE, BRLUCKY, BlueSkyz SHOP, CloudLampShop, CogitoErgoSum Autocarft Store, DTJFKJ, Dawn Jade, GGD AutoStore, GTAL Autoparts, GaoYoushangmao, HAOXINQI, Huawen Hansheng Network Technology Co., Ltd, bigbangauto, byictpc, hongparts, jian's automotive for extension of time to file answer

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendants 365autoparts, Arcosucu, AutoRiverMap STORE, BRLUCKY, BlueSkyz SHOP, CloudLampShop, CogitoErgoSum Autocarft Store, DTJFKJ, Dawn Jade, GGD AutoStore, GTAL Autoparts, GaoYoushangmao, HAOXINQI, Huawen Hansheng Network Technology Co., Ltd, bigbangauto, byictpc, hongparts, and jian's automotive for extension of time [38] is granted; response to complaint is to be filed by 8/26/2025. This does not affect any other date or deadline set by the Court.

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendants

ATTORNEY Appearance for Defendants 365autoparts, Arcosucu, AutoRiverMap STORE, BRLUCKY, BlueSkyz SHOP, CloudLampShop, CogitoErgoSum Autocarft Store, DTJFKJ, Dawn Jade, GGD AutoStore, GTAL Autoparts, GaoYoushangmao, HAOXINQI, Huawen Hansheng Network Technology Co., Ltd, bigbangauto, byictpc, hongparts, jian's automotive by Christopher Paul Keleher

MOTION by Defendants 365autoparts, Arcosucu, AutoRiverMap STORE, BRLUCKY, BlueSkyz SHOP, CloudLampShop, CogitoErgoSum Autocarft Store, DTJFKJ, Dawn Jade, GGD AutoStore, GTAL Autoparts, GaoYoushangmao, HAOXINQI, Huawen Hansheng Network Technology Co., Ltd, bigbangauto, byictpc, hongparts, jian's automotive Modify Asset Restraint

NOTICE of Voluntary Dismissal by FCA US LLC as to certain defendant

MINUTE entry before the Honorable Matthew F. Kennelly: Response to motion by certain defendants to modify asset restraint [42] is to be filed by 9/8/2025; reply to response is to be filed by 9/15/2025. Telephonic hearing is set for 9/22/2025 at 9:10 AM, using call-in number 650-479-3207, access code 2305-915-8729. The Court encourages the parties to attempt to reach a reasonable accommodation regarding the relief sought by defendants in the motion.

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants 365autoparts, Arcosucu, AutoRiverMap STORE, BRLUCKY, BlueSkyz SHOP, CloudLampShop, CogitoErgoSum Autocarft Store, DTJFKJ, Dawn Jade, GGD AutoStore, GTAL Autoparts, GaoYoushangmao, HAOXINQI, Huawen Hansheng Network Technology Co., Ltd, bigbangauto, byictpc, hongparts, jian's automotive

MINUTE entry before the Honorable Matthew F. Kennelly: Certain defendants' motion to dismiss for failure to state a claim [45] is denied--without prejudice to refiling as a properly supported motion for summary judgment==because it relies on material outside the complaint in seeking dismissal. This is not a proper Rule 12(b)(6) motion.

MOTION by Plaintiff FCA US LLC for entry of default, MOTION by Plaintiff FCA US LLC for default judgment as to all Defendants with the exception of certain Defendants

MEMORANDUM by FCA US LLC in support of motion for entry of default, motion for default judgment, [47]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

DEFAULT JUDGMENT ORDER AS TO CERTAIN DEFENDANTS signed by the Honorable Matthew F. Kennelly on 8/30/2025: Plaintiff's motion for entry of default judgment as to certain defendants [47] is granted.

MOTION by Plaintiff FCA US LLC to Extend the Briefing Schedule in Order [44] (Joint)

MINUTE entry before the Honorable Matthew F. Kennelly: Joint motion to extend schedule [51] is granted. Response to motion to modify asset restraint is now due 9/15/2025; reply to response is now due 9/22/2025; and the telephonic status hearing set for 9/22/2025 is vacated and reset to 9/30/2025 at 9:05 AM, using call-in number 650-479-3207, access code 2305-915-8729.