2025-cv-07655

COMPLAINT filed by FCA US LLC ; Filing fee $ 405, receipt number AILNDC-23719077.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Berel Y. Lakovitsky

Declaration of Hannah A. Abes

Exhibit A

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

Exhibit List

(Exhibit A)

Exhibit Store representative declarations and platform screenshots

Exhibit A

Exhibit 1

Exhibit 1

Exhibit Amazon listing

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

Exhibit A

Declaration Guowei Han

(Exhibit Summary of figures)

Exhibit 2

Exhibit 2

Exhibit Amazon listing

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

Exhibit 1 LABLT Accused Sales

Exhibit Amazon listing

CIVIL Cover Sheet

Exhibit 2 LABLT Restrained Balance

Exhibit Amazon listing

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

Exhibit 3 LABLT Active Listings of Other Products

Exhibit Amazon listing

Notice of Claims Involving Trademarks by FCA US LLC

Exhibit A LABLT Accused Product

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 Mary M. Rowland. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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: JiangLiLi0510, Jilin Province Lingdu Cultural Media Co., Ltd, jilinshengzhiweichuanmeiyouxiangongsi, Jingu Autostore, JITUIHOM, kaisudi, KJ-ZJ, Lemon Automation, LLiYYU, LLUChen, Lokmobiek, MaoNianHua-us, MINHQUANPHAN767, WangJun---us, mcbrockman, mccreparts, minnoun, nvcccauto, oisdeparts, RelikeParts, sawyerdealss, scshscarpart, shangpeng chen, SMG_Show, swiftflyerr, through-power, vvworlf, westernrocky1999, y1301873, zerenzhixin13, zhiweilai-22, zutina, Meishan SHOP, Mijia mall, one for rose local, One stay, Yino Clothing, Greenweave, Klxi and Verenity Dream added to case caption. (Text entry; no document attached.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

Exhibit Amazon listing

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

Exhibit Amazon listing

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[13]

(Exhibit ND Illinois Judge Alonso Order)

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

DECLARATION of Thomas H. Hipelius regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff FCA US LLC Exhibit 2 - Part 1 regarding declaration[16]

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

MEMORANDUM by FCA US LLC 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 Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13] is granted. Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [18] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 7/10/2025.

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

SURETY BOND in the amount of $58,000.00 posted by FCA US LLC

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

MOTION by Plaintiff FCA US LLC for preliminary injunction

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction[27]

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/21/2025, answer due 8/11/2025.

MINUTE entry before the Honorable Mary M. Rowland: Responses to the motion for preliminary injunction are due 8/13/25. Status report due 8/20/25. Mailed notice.

CERTIFICATE of Service by Plaintiff FCA US LLC regarding set motion and R&R deadlines/hearings, set deadlines/hearings[30]

ATTORNEY Appearance for Defendant LABLT by Steven G Kalberg

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

ATTORNEY Appearance for Defendant The Partnerships and Unincorporated Associations Identified on Schedule A by Xiaojun Wang

MOTION by Defendants Jing Dian Chang Xing, JKSXIX Autopart, JYYQ store1, KAIHUIXING, kexin-jp, KuaSheng, Lcskuajing, LIJWLFEE, LIMMEI, Ling-us, LiXinshangmao, LongShengfei, loxilories for extension of time to file answer

MINUTE entry before the Honorable Mary M. Rowland: Defenadnts Jing Dian Chang Xing, JKSXIX Autopart, JYYQ store1, KAIHUIXING, kexin-jp, KuaSheng, Lcskuajing, LIJWLFEE, LIMMEI, Ling-us, LiXinshangmao, LongShengfei, and loxilories' unopposed motion for extension of time to file answer [35] is granted. Jing Dian Chang Xing, JKSXIX Autopart, JYYQ store1, KAIHUIXING, kexin-jp, KuaSheng, Lcskuajing, LIJWLFEE, LIMMEI, Ling-us, LiXinshangmao, LongShengfei, and loxilories to answer or otherwise plead in response to complaint by August 11, 2025. Mailed notice.

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

MOTION by Defendant LABLT for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

MINUTE entry before the Honorable Mary M. Rowland: Defendant No. 14 LABLT's unopposed motion for extension of time to file answer [38] is granted. Defendant No. 14 LABLT is to answer or otherwise plead in response to the complaint by 9/10/25. Mailed notice.

MEMORANDUM by LABLT in Opposition to motion for preliminary injunction[27]

Joint STATEMENT by FCA US LLC Regarding Defendant No. 14 LABLT's Opposition to Plaintiff's Motion for Entry of a Preliminary Injunction 40

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's response in support of preliminary injunction due 9/4/25. Parties are to notify the court if they resolve this matter. Mailed notice.

STATUS Report Pursuant to 30 by FCA US LLC

ATTORNEY Appearance for Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories by Christopher Paul Keleher

MOTION by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories Modify Asset Restraint

MOTION by Plaintiff FCA US LLC for Entry of an Agreed Asset Restraint Order as to Defendant LABLT (Joint)

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]

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [43], the motion for preliminary injunction and motion by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories Modify Asset Restraint [45]. Defendant LABLT (Def. No. 14) ("LABLT") opposed the motion for preliminary injunction. [40]. Plaintiff's motion for preliminary injunction is granted ONLY in part. First it is denied at to LABLT. Next as to the defendants who did not object. As to the objecting defendants identified at docket entry [45], there is no asset restraint on those defendants at this time. The court grants Plaintiff's motion for preliminary injunction limited to the amount of the sales of the accused items. Plaintiff is to send a revised preliminary injunction to the court's proposed order box. Mailed notice.

RESPONSE by LABLTin Opposition to MOTION by Plaintiff FCA US LLC for Entry of an Agreed Asset Restraint Order as to Defendant LABLT (Joint) [46]

MINUTE entry before the Honorable Mary M. Rowland: Agreed motion for asset restraint 46 is denied as LABLT now opposes it. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Response to the motion for default is due 9/9/25. Status report due 9/16/25. Mailed notice.

MOTION by Plaintiff FCA US LLC to Reconsider Minute Order 52

MEMORANDUM by LABLT in Opposition to motion for miscellaneous relief 54 Plaintiff's Motion to Reconsider

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants JKSXIX Autopart, JYYQ store1, Jing Dian Chang Xing, KAIHUIXING, KuaSheng, LIJWLFEE, LIMMEI, Lcskuajing, LiXinshangmao, Ling-us, LongShengfei, kexin-jp, loxilories

MINUTE entry before the Honorable Mary M. Rowland: Motion to reconsider set for in-person hearing on 9/3/25 at 1:30 PM. Mailed notice.

ATTORNEY Appearance for Defendant LABLT by David Randolph Bennett

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 8/28/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Motion hearing held. By 9/5/25, Plaintiff and defendant LABLT are to file the agreed motion for asset restraint. By 9/22/25, these same two parties are to file a status report informing the court: (1) if parties are interested in moving forward with discovery or (2) if they need more time to work it out. Plaintiff's response to [56] due by 10/8/25. Mailed notice.

MOTION by Defendant LABLT for an Agreed Asset Restraint Order as to Defendant LABLT (Agreed)

MINUTE entry before the Honorable Mary M. Rowland: Agreed motion by Defendant LABLT 61 for asset restraint in an amount certain is granted. Parties are to send a proposed order to the court. Mailed notice.

AGREED ASSET RESTRAINT ORDER as to LABLT Signed by the Honorable Mary M. Rowland on 9/8/2025. Mailed notice.