Toyota Motor Sales sues over alleged counterfeit Toyota and Lexus marks on automotive accessories, then amends to name Shop1103944094 Store

What was filed

The original complaint, ECF No. 1, is captioned Toyota Motor Sales, U.S.A., Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 1:26-cv-13542 (N.D. Ill., Eastern Division), filed November 2, 2026 (15 pages). Schedule A and Exhibit 2 to the complaint were filed under seal (ECF Nos. 2 and 3), and Toyota moved for leave to file under seal (ECF No. 4). The case was randomly assigned to Judge Lindsay C. Jenkins on November 2, 2026. On November 3, 2026, Toyota filed an amended complaint (ECF No. 14) against Shop1103944094 Store, terminating the Schedule A defendants, and filed a notice withdrawing its motion for leave to file under seal. The same day, Judge Jenkins denied the motion to seal as withdrawn, directed the clerk to update the caption to reflect that the defendant is Shop1103944094 Store, said Toyota can proceed on its amended complaint, and ordered Toyota to take some action to advance the case by November 17, 2026. The amended complaint is not available.

The marks

The November 2 complaint lists 29 U.S. registrations as the Toyota Trademarks and attaches the registration certificates as Exhibit 1: four TOYOTA registrations (Reg. Nos. 843,138; 1,589,552; 1,721,365; and 2,115,623); CAMRY (1,262,925), C-HR (5,256,854), HIGHLANDER (2,249,838), LAND CRUISER (2,590,587), PRIUS (2,485,614), RAV4 (2,171,261), 4RUNNER (1,854,126), SEQUOIA (2,462,106), SIENNA (2,145,102), SUPRA (5,932,399), TACOMA (2,650,486), TUNDRA (3,247,860), YARIS (3,159,930), and TRD (2,823,668); two LEXUS registrations (1,574,718 and 5,810,473); and nine registrations the complaint shows as images, which United States Patent and Trademark Office records identify as a stylized T (1,797,716), COROLLA in stylized letters (867,434), a stylized S (2,510,985), LEXUS with a design (1,834,147 and 2,852,290), a stylized L inside a circle above LEXUS (3,805,350), a stylized L in an oval (1,619,755 and 5,803,480), and T TOYOTA GENUINE PARTS L LEXUS GENUINE PARTS, a three-dimensional product-packaging configuration (6,938,649). USPTO records list a Japanese corporation as the owner of each registration and show all 29 live: 24 renewed, four with combined Sections 8 and 15 declarations accepted and acknowledged (Reg. Nos. 5,256,854; 5,932,399; 5,810,473; and 5,803,480), and Reg. No. 6,938,649 registered January 3, 2023. The complaint says Toyota Motor Sales is the exclusive importer and authorized distributor of Toyota-branded vehicles, parts, and accessories in the continental United States, Alaska, Puerto Rico, and the U.S. Virgin Islands, holds a license to distribute them in connection with the Toyota trademarks, and has the right to enforce those rights.

What the complaint alleges

The November 2 complaint alleges that e-commerce store operators doing business under the seller aliases identified on Schedule A offer for sale and sell unauthorized and unlicensed automotive accessory products using infringing and counterfeit versions of the federally registered Toyota trademarks, target U.S. consumers including Illinois residents, and, on information and belief, have sold those products to Illinois residents. It alleges, on information and belief, that the defendants reside or operate in the People's Republic of China or other foreign jurisdictions, or redistribute products from the same or similar sources there, and it alleges that they operate under seller aliases to conceal their identities. It alleges, on information and belief, that the defendants know of Toyota's rights and are willfully infringing and intentionally using counterfeits of the Toyota trademarks.

Claims and relief

The November 2 complaint pleads two counts: trademark infringement and counterfeiting under 15 U.S.C. § 1114 (Count I) and false designation of origin under 15 U.S.C. § 1125(a) (Count II). The prayer seeks temporary, preliminary, and permanent injunctions against use of the Toyota trademarks or counterfeit imitations on products that are not genuine or authorized; an order that those with notice of the injunction, including online marketplace platforms, disable advertisements associated with the defendants' sale of counterfeit and infringing goods; an accounting and payment of profits; damages increased up to three times under 15 U.S.C. § 1117, or in the alternative statutory damages under 15 U.S.C. § 1117(c)(2) of $2,000,000 for each use of the Toyota trademarks; attorney fees and costs; and other relief.