2024-cv-60734

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-17498179, filed by Purple Innovation, LLC.

Exhibit 1

Exhibit 2

Exhibit 3

(Civil Cover Sheet)

Clerk's Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

(Complaint) (caw)

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by Purple Innovation, LLC identifying Corporate Parent Purple Innovation, Inc. for Purple Innovation, LLC

Plaintiff's MOTION for Leave to File Excess Pages by Purple Innovation, LLC.

SYSTEM ENTRY - Docket Entry 6 [motion] restricted/sealed until further notice. (1811244) (Text entry; no document attached.)

(Text of Proposed Order)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Purple Innovation, LLC.

(Text of Proposed Order)

PAPERLESS ORDER granting 5 Motion for Leave to File Excess Pages. Signed by Judge Rodney Smith on 5/30/2024. (kv00)

SYSTEM ENTRY - Docket Entry 12 [order] restricted/sealed until further notice. (Text entry; no document attached.)

PAPERLESS ORDER granting 7 Motion to Seal Schedule "A" to Plaintiff's Complaint. Schedule A to the Plaintiff's Complaint shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge Rodney Smith on 5/30/2024. (kv00)

SYSTEM ENTRY - Docket Entry 10 [motion] restricted/sealed until further notice. (1811244) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 11 [misc] restricted/sealed until further notice. (1811244) (Text entry; no document attached.)

Order (Text entry; no document attached.)

NOTICE of Attorney Appearance by Leigh Benjamin Salomon on behalf of Purple Innovation, LLC. Attorney Leigh Benjamin Salomon added to party Purple Innovation, LLC(pty:pla).

NOTICE of Voluntary Dismissal of Certain Defendants by Purple Innovation, LLC

SYSTEM ENTRY - Docket Entry 15 [misc] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 16 [motion] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 17 [motion] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

NOTICE of Attorney Appearance by Jianyin Liu on behalf of Lupay, Super Seat. Attorney Jianyin Liu added to party Lupay(pty:dft), Attorney Jianyin Liu added to party Super Seat(pty:dft).

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Yi Yi. Filing Fee $ 250.00 Receipt # AFLSDC-18264091. Responses due by 3/21/2025.

Certification Attorney's Certification

(Text of Proposed Order)

PAPERLESS ORDER granting 19 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Yi Yi. Signed by Judge Rodney Smith on 3/7/2025. (kv00)

NOTICE of Voluntary Dismissal of Defendant Nos. 77 (Lupay) and 83 (Super Seat) by Purple Innovation, LLC

Order (Text entry; no document attached.)

Plaintiff's MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines by Purple Innovation, LLC. Responses due by 9/17/2025.

Declaration of Leigh Salomon

Text of Proposed Order

NOTICE of Voluntary Dismissal of Defendant Nos. 5 (Hangzhou Rika Textile Co., Ltd.), 6 (Hangzhou Surewal Technology Co., Ltd.), 8 (Henan Xinjiayuan Technology Co., Ltd.), 10 (Huizhou Housefar Technology Co., Ltd.), 11 (Langfang Development Zone Situo Import&Export Trade Co., Ltd.), 12 (Nantong Bulawo Home Textile Co., Ltd.), 13 (Nantong Genelsleep Home Co., Ltd.), 15 (Nantong Ruiqiyan Home Technology Co., Ltd.), 16 (Nantong Yizhixing Household Products Co., Ltd.), 19 (Ningbo Shiny Bright Import & Export Co., Ltd.), 20 (Qingdao Youmeng Home Furnishing Technology Co., Ltd.), 21 (Ruian Shenbr Household Articles Co., Ltd.), 22 (Sanying Polyurethane (nantong) Co., Ltd.), 23 (Shenzhen Huiguang Trading Co., Ltd.), 25 (Shenzhen Shiny Technology Co., Ltd.), 27 (Wenzhou Jiabo Latex Product Co., Ltd.), 28 (Xindao International Trading (shanghai) Co., Ltd.), 29 (Yiwu Diligu General Merchandise Co., Ltd.), 30 (Yiwu Jifei Trade Co., Ltd.), 31 (Zhengzhou Jourm Technology Co., Ltd.), 32 (8H Enjoy Home Store), 33 (8H Smart Home Store), 35 (China Shop11 Store), 37 (Coofull Smart And Secure Home Global Store), 38 (Decoration Home Furnishing Global Specialty Store), 40 (Duoxidao Comfortable Home Life Store), 41 (Factory Direct Selling 601 Store), 42 (FanYajia Store Store), 43 (Fedalo Homeware Store), 44 (Fyatto Textiles Store), 46 (Han Field Store), 47 (Haven Home Textiles Store), 48 (HG Good Seller Store), 49 (Home Has Love Store), 51 (Lifestyle Department Store), 52 (Lucky Home Textile), 53 (Lucky Xixi Store Store), 54 (OPLE Store), 56 (Perfect Boutique Home Furnishing Store), 57 (Rustic Charm Home Store), 58 (Seashells Personal Care Store Store), 61 (Shop1103053551 Store), 62 (Shop1103438516 Store), 63 (Shop5015159 Store), 64 (Shop5229044 Store), 65 (XIaomi 8H Home Store), and 124 (wholesale*factory*store888) by Purple Innovation, LLC

Clerks Receipt for Bond posted for TRO per order of the court (DE#23) received on 9/5/2025 in the amount of $ 10,000.00, receipt number FLS307334.

TRO BOND in the amount of $10,000.00 receipt # 307334 posted by Purple Innovation, LLC Approved by Judge Rodney Smith

NOTICE of Voluntary Dismissal of Certain Defendent 2 (Foshan Lelaikang Latex Co., Ltd.) Without Prejudice by Purple Innovation, LLC

NOTICE of Filing Proposed Summons(es) by Purple Innovation, LLC

Proposed Summons

Summons Issued as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A.

Set Telephonic Hearing pursuant to DE 27 Preliminary Injunction Hearing set for 9/30/2025 10:45 AM in Fort Lauderdale Division before Judge Rodney Smith. (Text entry; no document attached.)

Notice of Pending, Refiled, Related or Similar Actions by Purple Innovation, LLC

MOTION to Unseal Document by Purple Innovation, LLC. Responses due by 10/14/2025.

Text of Proposed Order Granting the Motion

SUMMONS (Affidavit) Returned Executed on [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Purple Innovation, LLC. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 9/24/2025, response/answer due 10/15/2025.

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Deqing Rina Household Products Co., Ltd., Foshan Mengruo Household Furniture Co., Ltd., Guangzhou Linsen Industrial Co., Ltd., Henan Osen Trading Co., Ltd., Ningbo Chenfeng Home Decor Co., Ltd., SHENZHEN YALV HOME AND DRESS DECORATION CO.,LTD, congcong homie Store, Dragonhawk Store, Good Life Home Store, HOMMING Store, Pandon Department Store, Shenbang factory Store, BINGZHEN, binzhouqufuziyibaihuodian, changhaokeji, chenhuiliUK, chenyi International Trade Store, jiujiangguojiageishangmaoyouxiangongsi, kunmingshuozongqianshangmaoyouxiangongsi, leyimaoyi, liuc1994, Lollipop88, NUOANUO Store, Ovan Molnet, PromithiDirect-us, Search Notice, shandongzhengtawangluokejiyouxiangongsi, VULORA, XLXLX, YoMee, zhijiangshidetingshangmaoyouxiangongsi, zhijiangshiyekaishangmaoyouxiangongsi, ZP, ZYYQZDPN, ZZCSYH, bai10, bian10, busanqing, cong09, dou08, encharm, householdd, jifengjh, keng10 Store, llchao, men09, nan0010, nian10, ning09, ren09, ren10, sufeiyaa, vaiduryd, wai10, zhong09, zhong10, GN-huahua, BOSON, CZX SHOP, Enjoying Simple Life, LHOTSE, Lovers weave lovers grass, travel home and WHRuoLinTech.

NOTICE of Filing the [Proposed] Order Granting Plaintiff's Motion For Preliminary Injunction by Purple Innovation, LLC

Text of Proposed Order

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Motion Hearing held on 9/30/2025, 10:50-10:53am re [24] Plaintiff's MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines filed by Purple Innovation, LLC. After hearing from plaintiff's counsel, the Court to enter preliminary injunction order. Attorney Appearance(s): Leigh Benjamin Salomon Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

ORDER Granting [33] Motion to Unseal. The Clerk is directed to unseal all docket entries in this case and return those portions of the file to the public records. Signed by Judge Rodney Smith on 9/30/2025. See attached document for full details.

NOTICE of Compliance re [38] Order on Motion to Unseal. All documents in this case have been unsealed per DE#38.

NOTICE of Voluntary Dismissal of Defendant Nos. 4 (Guangzhou Linsen Industrial Co., Ltd.), 75 (liuc1994), 80 (PromithiDirect-us), 85 (XLXLX), and 133 (LHOTSE) by Purple Innovation, LLC

Plaintiff's NOTICE of Filing Amended [Proposed] Order Granting Plaintiff's Motion for Preliminary Injunction by Purple Innovation, LLC re [17] Renewed EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Internet Stores, a Temporary Asset Restraint, and Expedited Discovery

Text of Amended [Proposed] Order Granting Plaintiff's Motion for Prelimina