2025-cv-08563

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 405, receipt number AILNDC-23793179.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Trevor C. Talhami

Declaration of Thomas J. Juettner

Exhibit A

Exhibit 1

Exhibit 1

Exhibit A

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A regarding complaint[1]

Exhibit A

Exhibit 2-1

Exhibit 2

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for leave to file under seal

Exhibit 2-2

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Toyota Motor Sales, U.S.A., Inc.

Notice of Claims Involving Trademarks by Toyota Motor Sales, U.S.A., Inc.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin R. Gaudio

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Albert Berry, III. 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: guangxihuizhaomaoyiyouxiangongsi, Tangerine white, xianlongx, xiejunxiandht, YAETCHiEA, YUANWENYUAN, yuzhoushiyingqishangmaoyouxiangongsi, ZhenPingXianYuZhiDianZiShangWuYouXianGongSi, zhenzhenwang123, 18ronlayn, aimaha46, ashtrayed, AutoAxle, ava-in-japan, avocadooauto, bearing123, Beautiful Wedding Shop, Bestlink, bmwautopartsllc, cheerautoparts, chengc_autoparts, chengc-99, Connectpluss, dq-aut, Evolens co, fjsclfmy, gengmaluoaimaoyiyouxiangongsi, HENZIKON Brake, HHT AUTO PARTS, huangkunhu, ihaoyu, joseph-in-japan-771, kaylx-parts, kingmen, lixiao-46, magicalmagic4, makuang888, mattops369, Orizzonte01, Orizzonte02, pigletauto, shaunyauto, SolidMach, Top Star_AutoParts, vviperauto, Windmill-car-parts, wongr_54, xieyushop, yjxparts, yo_907445, youfi3627, yousm53, KaiCiGuoJi, Mens Value, MyCaseStory, Qian mo Bei, Amazing Sunglasses Store, Easyglow Tech, Huada Electronics, KanYouCheng, LchangH-JH, LIKEFLYWATER, liqi-Properties, Neypto shop, NiuKailinShop, pingyi, Sjing, taiyuangangzhengfushangmao, TaiYuanQiu, taiyuansizheshangmao, tangzhihaodedian, XIAOX, yangjiangshiduokuishangmao and Yi Yun Teeth Whitening added to case caption. (Text entry; no document attached.)

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Thomas Joseph Juettner

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for temporary restraining order[11]

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

DECLARATION of Teena Bohi regarding memorandum in support of motion[12]

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 2 Parts 1-2 regarding declaration[14]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for miscellaneous relief[16]

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

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 [11] is granted. Plaintiff's motion for leave to file certain documents under seal [3] and motion for electronic service of process [16] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 7/28/2025.

Registry Deposit Information Form by Toyota Motor Sales, U.S.A., Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Toyota Motor Sales, U.S.A., Inc.

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

SURETY BOND in the amount of $ 89,000 posted by Toyota Motor Sales, U.S.A., Inc. (Document not scanned)

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction[27]

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/5/2025, answer due 8/26/2025.

MINUTE entry before the Honorable Mary M. Rowland: Response to motion for preliminary injunction due 8/27/25. Status report due 9/4/25. Mailed notice.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain Defendants

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for entry of default, MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for default judgment as to all remaining Defendants

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment, [32]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[33]

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

STATUS Report Pursuant to [30] by Toyota Motor Sales, U.S.A., Inc.

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the status report [36]. The court grants the Plaintiff's motion for preliminary injunction [27]. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 9/5/2025. Mailed notice.