Audi, Lamborghini, and Volkswagen U.S. companies sue a Brooklyn company over alleged counterfeit scale model cars and toy cars

What was filed

The complaint is ECF No. 1 in Audi of America, LLC v. Everbright Trading, Inc., No. 2:26-cv-14138-LJM-DRG (E.D. Mich.), filed October 28, 2026. The docket lists District Judge Laurie J. Michelson and Magistrate Judge David R. Grand. The plaintiffs are Audi of America, LLC, a Delaware company based in Auburn Hills, Michigan; Automobili Lamborghini America, LLC, a Delaware company based in Reston, Virginia; and Volkswagen Group of America, Inc., a New Jersey corporation based in Auburn Hills, Michigan. The complaint says they enforce in the United States the trademarks and trade dress owned by Audi AG, Automobili Lamborghini S.p.A., and Volkswagen AG. The defendants are Everbright Trading, Inc., a New York corporation based in Brooklyn, New York, and Lisen Pan, whom the complaint describes as its principal and as a moving, conscious, and active force behind the infringing acts.

What the complaint alleges

The complaint alleges that the defendants import, manufacture, advertise, or sell scale model vehicles and toy cars that carry counterfeits of the Audi, Lamborghini, and Volkswagen marks, and that they feature the marks in advertising and on their website. It names four registrations: the Lamborghini "BULL RUN LOGO" marks, Reg. Nos. 1,375,514 and 7,804,938; the Volkswagen "BUG Design" mark, Reg. No. 3,038,741; and the Audi "FOUR RINGS LOGO," Reg. No. 3,007,305. It also alleges that the vehicles' body shapes and appearance are non-functional, distinctive trade dress. The complaint says the plaintiffs sent a cease and desist letter, that the defendants responded that they had stopped, and that an invoice dated August 24, 2026 shows they had not. USPTO TSDR lists Reg. Nos. 1,375,514 and 7,804,938 as owned by Automobili Lamborghini S.p.A., Reg. No. 3,038,741 as owned by Volkswagen Aktiengesellschaft, and Reg. No. 3,007,305, a mark of four interlocking rings, as owned by Audi A.G., each registered or renewed.

Claims and relief

The plaintiffs plead four claims against both defendants: trademark counterfeiting and infringement under 15 U.S.C. § 1114; false designation of origin or sponsorship and false advertising under 15 U.S.C. § 1125(a); trade dress infringement under 15 U.S.C. § 1125(a); and trademark dilution under 15 U.S.C. § 1125(c). They ask for preliminary and permanent injunctions; an order to sequester the goods and business records; delivery of infringing goods and the means of making them for destruction under 15 U.S.C. § 1118; other relief to keep the public from believing the defendants' goods are authorized by the plaintiffs; a sworn compliance report; a six-month audit of the defendants' books; costs and reasonable attorneys' fees under 15 U.S.C. § 1117(a); an accounting; three times the defendants' profits under 15 U.S.C. § 1117(b) or, alternatively, statutory damages of $1,000 to $2,000,000 per counterfeit mark per type of goods under 15 U.S.C. § 1117(c); interest; transfer of the domain everbright.catalog.to to the plaintiffs; and other relief.