2025-cv-07793

COMPLAINT filed by FCA US LLC ; Filing fee $ 405, receipt number AILNDC-23731781.

Exhibit 1

(Exhibit 1)

Exhibit 2-1

Exhibit A

Declaration of Hannah A. Abes

(Exhibit List of Defendants for Whom Appearance Has Been Filed)

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

(Exhibit 2-2)

Exhibit A

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

CIVIL Cover Sheet

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

Notice of Claims Involving Trademarks by FCA US LLC

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

ATTORNEY Appearance for Plaintiff FCA US LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff FCA US LLC by Berel Yonathan Lakovitsky

ATTORNEY Appearance for Plaintiff FCA US LLC by Hannah Alexa Abes

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.)

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2). Modified on 7/11/2025. (Text entry; no document attached.)

NEW PARTIES: AurareTorq, ChiLi, deyuan storefront, Firefly's Store, GURUNXIV, HOUXIAHUA, HSUTVXPRO Store, Jiayue Auto Parts, Nadiyue, nanchangmuyixinshangmaoyouxiangongsi, Ningxia San ge po niang electronic commerce co ltd, NO.2 AUTOSTORE, Novello Auto Parts & Outdoor Store, NuanQinYi Store, onone autopart, paracoche, Parts and Accessories Shop, Pidanida autoparts, pinkmomo_autoparts, PRIMAL LIFE HALL, qingdaoyunshangzhilianshangmaoyouxiangongsi, QQQI-US, QY Auto Parts Store, Rainstow, Rwrfejoe, SAIQINGSP, SHenT, SIPEIRUI, Sunhohi Shop, Sunway Warehouse, taiyuanjujiekejiyouxiangongsi, Tianbing Trading, Tianyuechepin, TLHUA-USA, TOPLISTING, TSHTLAO Auto Parts Hub, Wairau Valley, Wangcmcol, Wangcongjun-us, WeiDong2057, WFNIHONHON, WGBNIF Autopart, Wuxi Hongtian, Wynne Warehouse, XBATOA, xiaxiaseeworld, Xinan AutoStore, XIOUMAAN, Xiyin stores, XoYixoYi, XueWei's store, Yan Fang Trade Shop, Yangping-us, Yazyu shop, yijuntianjinshangmaoyouxiangongsi, yingparts, Yushu Technology Co., Ltd, ZHONGXINGGUOJI, Zlibirary, Zynkor, allroous, Auto-More-Lover, backyard-best, barton_family, bdch6894, besthuoran03, BluePHX, fanclucarss, han123_6, harspart, koueiparts, DISMISSED, lukecarspart, MenBager, motor012, motorzones, tankatuo, topnotch-turi, toyotano1, viraglo44, yibei-tech, Findmall Industry, Moto mark, gang' store, LabltParts, Lixinda Co. Ltd, qixianweixinyuanshangmao and Supagat- Auto Parts 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 Plaintiff FCA US LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by FCA US LLC in support of motion for temporary restraining order 13

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 - Parts 1-2 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 Andrea R. Wood: Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are set for a telephonic motion hearing on 7/30/2025 at 9:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 Andrea R. Wood: Telephonic motion hearing held on 7/30/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A regarding complaint [2], and (2) Exhibit 2 - Parts 1-2 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 7/30/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 8/13/2025 at 10:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 7/30/2025. Mailed notice

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 Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 10,000.00 posted by FCA US LLC

MOTION by Plaintiff FCA US LLC for preliminary injunction

MEMORANDUM by FCA US LLC in support of motion for preliminary injunction 28

DECLARATION of Berel Y. Lakovitsky regarding memorandum in support of motion[29]

SUMMONS Returned Executed by FCA US LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/8/2025, answer due 8/29/2025.

NOTICE of Voluntary Dismissal by FCA US LLC as to a Certain Defendant

MINUTE entry before the Honorable Andrea R. Wood: Due to a change in the Court's schedule, the telephonic status hearing set for 8/13/2025 at 11:15 A.M. is reset for 8/13/2025 at 1:45 P.M. [TIME CHANGE ONLY]. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 (aw,)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/13/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [28] is granted. By 8/20/2025, Plaintiff shall file a supplemental submission that reflects the amount of frozen funds for each defendant. Plaintiff is granted leave to file the document under seal. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint [2], (2) Exhibit 2 - Parts 1-2 [17], and (3) the sealed temporary restraining order [23]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Term inate_Instructions.pdf. Telephonic status hearing set for 9/24/2025 at 10:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

PRELIMINARY INJUNCTION ORDER signed by the Honorable Andrea R. Wood on 8/13/2025. Mailed notice

SEALED DOCUMENT by Plaintiff FCA US LLC Supplement Regarding Defendants' Accounts Balances

ATTORNEY Appearance for Defendant motor012 by Mingbo Ye

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

ATTORNEY Appearance for Defendants AurareTorq, Firefly's Store, HOUXIAHUA, NO.2 AUTOSTORE, Novello Auto Parts & Outdoor Store, PRIMAL LIFE HALL, Parts and Accessories Shop, Pidanida autoparts, QQQI-US, Rainstow, Rwrfejoe, SHenT, SIPEIRUI, Sunhohi Shop, Sunway Warehouse, TLHUA-USA, TSHTLAO Auto Parts Hub, Tianbing Trading, WGBNIF Autopart, Wairau Valley, Wangcongjun-us, Wynne Warehouse, XBATOA, XIOUMAAN, Xinan AutoStore, Xiyin stores, XueWei's store, Yan Fang Trade Shop, Yangping-us, Yazyu shop, Zlibirary, Zynkor, deyuan storefront, gang' store, nanchangmuyixinshangmaoyouxiangongsi, onone autopart, pinkmomo_autoparts, taiyuanjujiekejiyouxiangongsi, yingparts by Xiaojun Wang

MOTION by Defendants AurareTorq, Firefly's Store, HOUXIAHUA, NO.2 AUTOSTORE, Novello Auto Parts & Outdoor Store, PRIMAL LIFE HALL, Parts and Accessories Shop, Pidanida autoparts, QQQI-US, Rainstow, Rwrfejoe, SHenT, SIPEIRUI, Sunhohi Shop, Sunway Warehouse, TLHUA-USA, TSHTLAO Auto Parts Hub, Tianbing Trading, WGBNIF Autopart, Wairau Valley, Wangcongjun-us, Wynne Warehouse, XBATOA, XIOUMAAN, Xinan AutoStore, Xiyin stores, XueWei's store, Yan Fang Trade Shop, Yangping-us, Yazyu shop, Zlibirary, Zynkor, deyuan storefront, gang' store, nanchangmuyixinshangmaoyouxiangongsi, onone autopart, pinkmomo_autoparts, taiyuanjujiekejiyouxiangongsi, yingparts for extension of time to file answer

MINUTE entry before the Honorable Andrea R. Wood: Defendants' motion for extension of time 40 is granted. Those Defendants shall answer or otherwise respond to the complaint by 9/19/2025. Mailed notice