2024-cv-60865

COMPLAINT against The Individuals, Partnerships and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-17547750, filed by Dongguan Saienchuangke Technology Co., Ltd.

Exhibit 1

Civil Cover Sheet

Summon(s)

(AO 120)

Clerks Notice of Judge Assignment to Judge Melissa Damian. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle 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.

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

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

(Complaint with Exhibits) (wce)

Corporate Disclosure Statement by Dongguan Saienchuangke Technology Co., Ltd.

MOTION to Seal certain file per Local Rule 5.4 by Dongguan Saienchuangke Technology Co., Ltd.

(Text of Proposed Order)

Clerk's Notice to Filer re 5 Certificate of Other Affiliates/Corporate Disclosure Statement. Other Affiliates/Corporate Parents Not Entered; ERROR - The Filer failed to enter all Other Affiliates/Corporate Parents from the Certificate of Other Affiliates/Corporate Disclosure Statement. Filer is instructed to refile their Certificate of Other Affiliates/Corporate Disclosure Statement and enter the missing Other Affiliates/Corp Parents. Note - Other Affiliates/Corporate Parents do not appear on the docket sheet.

EX PARTE MOTION ENTRY OF TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION, AND ORDER RESTRAINING TRANSFER OF ASSETS AND EXPEDITED DISCOVERY by Dongguan Saienchuangke Technology Co., Ltd.

Decl. of Liao

Exhibit 1

Exhibit 2

Decl. of Palmer

(Text of Proposed Order) Added MOTION for Preliminary Injunction, MOTION for Temporary Restraining Order on 5/23/2024 (scn). Modified security on 7/12/2024 (scn)

Ex Parte MOTION for Alternate service by Dongguan Saienchuangke Technology Co., Ltd.

Decl. of Palmer

Exhibit 1

(Text of Proposed Order) Modified text on 5/23/2024 (scn)

Corporate Disclosure Statement by Dongguan Saienchuangke Technology Co., Ltd., identifying Corporate Parent Huizhou Aosai Technology Co., Ltd for Dongguan Saienchuangke Technology Co., Ltd.

ORDER GRANTING PLAINTIFF'S MOTION TO SEAL CERTAIN DOCUMENTS [ECF NO. 6]. Signed by Judge Melissa Damian on 5/23/2024. See attached document for full details.

Document re DE# 11 Order on Motion to Seal by Dongguan Saienchuangke Technology Co., Ltd. Modified security on 7/12/2024

ORDER Granting 8 Ex Parte Motion for Order Authorizing Alternate Service of Process on Defendants. Signed by Judge Melissa Damian on 5/28/2024. See attached document for full details.

ORDER GRANTING EX PARTE MOTION FOR ENTRY OF TEMPORARY RESTRAINING ORDER [ECF NO. 7]: The Clerk of the Court is directed to issue a single original summons in the name of The Partnerships and all other Defendants identified in the Complaint that shall apply to all Defendants. Preliminary Injunction Hearing set for 6/26/2024 9:30 AM in Fort Lauderdale Division before Judge Melissa Damian. Response due 6/19/2024. Reply due 6/24/2024. Signed by Judge Melissa Damian on 6/12/2024. (scn) Modified security on 7/12/2024

Summons Issued as to all Defendants. Entered per DE# 14. (scn) Modified security on 7/12/2024

Order Setting Hearing by Zoom: Preliminary Injunction Hearing set for 6/26/2024 9:30 AM in Fort Lauderdale Division before Judge Melissa Damian via ZOOM. Signed by Judge Melissa Damian on 6/25/2024. (scn) Modified security on 7/12/2024

MOTION to Reset Hearing and extension of TRO by Dongguan Saienchuangke Technology Co., Ltd.

Decl. of Palmer

Exhibit 1

(Exhibit 2) Modified text on 6/26/2024 (scn)

PAPERLESS ORDER. Please take notice that, in light of Plaintiff's 17 Ex Parte Motion to Reset Preliminary Injunction Hearing and to Extend the Temporary Restraining Order, the Preliminary Injunction Hearing presently set on June 26, 2024, at 9:30 a.m. is hereby CANCELED. The Court will separately provide an Order resetting the Hearing and extending the Temporary Restraining Order at a later time. Signed by Judge Melissa Damian on 6/26/2024.

NOTICE of Voluntary Dismissal as to Defendant No.10 HZYan without prejudice by Dongguan Saienchuangke Technology Co., Ltd.

ORDER GRANTING 17 Plaintiff's Ex Parte Motion to Reset Preliminary Injunction Hearing and to Extend the Temporary Restraining Order. It is ORDERED AND ADJUDGED that the preliminary injunction hearing previously set for June 26, 2024, is RESET for July 10, 2024, at 1:00 PM. The Hearing will be held by Zoom, which information will be provided prior to the hearing. The Ex Parte Temporary Restraining Order, dated June 12, 2024 (ECF No. 14), shall remain in effect until after the conclusion of the preliminary injunction hearing. Signed by Judge Melissa Damian on 6/26/2024. See attached document for full details.

ORDER OF DISMISSAL AS TO DEFENDANT NO. 10 HZY: re 19 Notice of Voluntary Dismissal. Defendant No. 10 HZY is DISMISSED WITHOUT PREJUDICE. Plaintiff shall serve a copy of this Order on Defendant by e-mail via their corresponding e-mail address and/or online contact form or other means of electronic contact provided on the Internet based e-commerce store operating under the Seller ID; or by providing a copy of this Order by email to the marketplace platform for the Seller ID so that the registrar, or marketplace platform, in turn, notifies Defendant of the Order; or by other means reasonably calculated to give notice which is permitted by the Court. Signed by Judge Melissa Damian on 6/27/2024. See attached document for full details.

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Dongguan Saienchuangke Technology Co., Ltd. Nezun Store served on 7/2/2024, response/answer due 7/23/2024; WHDPETSCares served on 7/2/2024, response/answer due 7/23/2024; KYM MLSMYXGS served on 7/2/2024, response/answer due 7/23/2024; Ailevant served on 7/2/2024, response/answer due 7/23/2024; WELTRXE served on 7/2/2024, response/answer due 7/23/2024; Qidordour served on 7/2/2024, response/answer due 7/23/2024; JAY-US served on 7/2/2024, response/answer due 7/23/2024; LIN&BABAY Direct served on 7/2/2024, response/answer due 7/23/2024; P&C-Direct served on 7/2/2024, response/answer due 7/23/2024; VIVAVIVA served on 7/2/2024, response/answer due 7/23/2024; YZL123 served on 7/2/2024, response/answer due 7/23/2024; Aberzey served on 7/2/2024, response/answer due 7/23/2024; AOXUAN NIC served on 7/2/2024, response/answer due 7/23/2024; Mengfutong served on 7/2/2024, response/answer due 7/23/2024; SHUHEYAN KSR served on 7/2/2024, response/answer due 7/23/2024; NaBeiYing served on 7/2/2024, response/answer due 7/23/2024; Granze Tech served on 7/2/2024, response/answer due 7/23/2024; HECLIFE served on 7/2/2024, response/answer due 7/23/2024; DaWikity Kids served on 7/2/2024, response/answer due 7/23/2024; Bossel served on 7/2/2024, response/answer due 7/23/2024; Hamsoo served on 7/2/2024, response/answer due 7/23/2024; Sosmar-US served on 7/2/2024, response/answer due 7/23/2024; Zhangyueyuan served on 7/2/2024, response/answer due 7/23/2024; Hugh. Grant served on 7/2/2024, response/answer due 7/23/2024; Sitengle served on 7/2/2024, response/answer due 7/23/2024; Daillshop served on 7/2/2024, response/answer due 7/23/2024; Huansihan-US served on 7/2/2024, response/answer due 7/23/2024; DING SHI fashion served on 7/2/2024, response/answer due 7/23/2024; ZRRHOO served on 7/2/2024, response/answer due 7/23/2024; WissTec served on 7/2/2024, response/answer due 7/23/2024; TravelRevealer served on 7/2/2024, response/answer due 7/23/2024; Helian Electronics served on 7/2/2024, response/answer due 7/23/2024; Koknwoa Direct served on 7/2/2024, response/answer due 7/23/2024; UZZOL STORE served on 7/2/2024, response/answer due 7/23/2024; UZSOMX served on 7/2/2024, response/answer due 7/23/2024; Lishx shop served on 7/2/2024, response/answer due 7/23/2024; F-A2Z served on 7/2/2024, response/answer due 7/23/2024; the red hat served on 7/2/2024, response/answer due 7/23/2024; BOOTLION served on 7/2/2024, response/answer due 7/23/2024; BNL Brands served on 7/2/2024, response/answer due 7/23/2024; sitong22 served on 7/2/2024, response/answer due 7/23/2024; TXKKEXP served on 7/2/2024, response/answer due 7/23/2024; MIGHTYCOS served on 7/2/2024, response/answer due 7/23/2024; Hiliop Reusable WB Direct served on 7/2/2024, response/answer due 7/23/2024; DXNONA served on 7/2/2024, response/answer due 7/23/2024; PETBSNVB served on 7/2/2024, response/answer due 7/23/2024; Furu Donghai served on 7/2/2024, response/answer due 7/23/2024.

(Exhibit 1)

NOTICE of Attorney Appearance by Jianyin Liu on behalf of Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR, Zhangyueyuan. Attorney Jianyin Liu added to party Furu Donghai(pty:dft), Attorney Jianyin Liu added to party KYM MLSMYXGS(pty:dft), Attorney Jianyin Liu added to party SHUHEYAN KSR(pty:dft), Attorney Jianyin Liu added to party Zhangyueyuan(pty:dft).

MOTION to Dismiss 1 Complaint, Motion to Dissolve Ex Parte TRO, and Opposition to Plaintiff's Motion for Preliminary Injunction by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Attorney Robert Houpt Thornburg added to party Granze Tech(pty:dft), Attorney Robert Houpt Thornburg added to party Hiliop Reusable WB Direct(pty:dft), Attorney Robert Houpt Thornburg added to party WHDPETSCares(pty:dft), Attorney Robert Houpt Thornburg added to party YZL123(pty:dft). Responses due by 7/17/2024.

RESPONSE in Opposition re 17 Motion for Extension of TRO and Motion to Reset Hearing and Motion for Temporary Restraining Order and Preliminary Injunction filed by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR, Zhangyueyuan. Replies due by 7/10/2024.

Exhibit A- Plf's Design Patent

Exhibit B- '430 Utility Patent

(Exhibit C- '826 Utility Patent)

NOTICE of Filing Declaration in Support of Response to Motion for Preliminary Injunction by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR, Zhangyueyuan re 25 Response in Opposition to Motion

(Exhibit A- '460 Patent)

PAPERLESS ORDER Requiring Briefing. THIS CAUSE is before the Court upon 24 Defendants Nos. 2, 12, 18, and 45's (the "Attorney Thornburg Defendants") Motion to Dismiss, Motion to Dissolve Ex Parte TRO and Opposition to Plaintiff's Motion for Preliminary Injunction and 25 Defendants' (the "Attorney Liu Defendants") Response in Opposition to Plaintiff's Motion for TRO. In light of the impending Preliminary Injunction hearing before the undersigned, presently set for July 10, 2024, it is hereby ORDERED that Plaintiff shall file a combined response/reply to the Attorney Thornburg Defendants' 24 Motion and the Attorney Liu Defendants' 25 Motion by close of business Tuesday, July 9, 2024. Signed by Judge Melissa Damian on 7/8/2024.

RESPONSE to Motion re 24 MOTION to Dismiss 1 Complaint, Motion to Dissolve Ex Parte TRO, and Opposition to Plaintiff's Motion for Preliminary Injunction filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 7/15/2024.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

REPLY to 25 Response in Opposition to Motion, by Dongguan Saienchuangke Technology Co., Ltd.

(Exhibit 1)

NOTICE of Attorney Appearance by Giulia Christine Farrior on behalf of Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Attorney Giulia Christine Farrior added to party Granze Tech(pty:dft), Attorney Giulia Christine Farrior added to party Hiliop Reusable WB Direct(pty:dft), Attorney Giulia Christine Farrior added to party WHDPETSCares(pty:dft), Attorney Giulia Christine Farrior added to party YZL123(pty:dft).

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Yizhou (Brad) Liu. Filing Fee $ 200.00 Receipt # AFLSDC-17662351 by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 7/23/2024.

(Text of Proposed Order)

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Xin (Sage) Wen. Filing Fee $ 200.00 Receipt # AFLSDC-17662384 by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 7/23/2024.

(Text of Proposed Order)

REPLY to 25 Response in Opposition to Motion, 24 MOTION to Dismiss 1 Complaint, Motion to Dissolve Ex Parte TRO, and Opposition to Plaintiff's Motion for Preliminary Injunction by Dongguan Saienchuangke Technology Co., Ltd.

Exhibit 1

Exhibit 2

(Exhibit 3)

ORDER Resetting Preliminary Injunction Hearing and Extending TRO. Preliminary Injunction Hearing set for 7/12/2024 at 03:00 PM via Zoom before Judge Melissa Damian. Signed by Judge Melissa Damian on 7/10/2024. See attached document for full details.

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Hongchang Deng. Filing Fee $ 200.00 Receipt # AFLSDC-17668967 by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 7/25/2024.

(Text of Proposed Order)

ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING [ECF NO. 31 ]: It is further ORDERED that Yizhou (Brad) Liu, Esq., of the law firm of Calfee, Halter & Griswold LLP, may appear and participate in this action on behalf of Defendants WHDPETSCares, YZL123, Granze Tech, and Hiliop Reusable. The Clerk shall provide electronic notification of all electronic filings to Yizhou (Brad) Liu, Esq., at bliu@calfee.com. Signed by Judge Melissa Damian on 7/11/2024. See attached document for full details.

ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING [ECF NO. 32 ]: It is further ORDERED that Xin (Sage) Wen, Esq., of the law firm of Calfee, Halter & Griswold LLP, may appear and participate in this action on behalf of Defendants WHDPETSCares, YZL123, Granze Tech, and Hiliop Reusable. The Clerk shall provide electronic notification of all electronic filings to Xin (Sage) Wen, Esq., at swen@calfee.com. Signed by Judge Melissa Damian on 7/11/2024. See attached document for full details.

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for R Joseph Trojan. Filing Fee $ 200.00 Receipt # AFLSDC-17671622 by P&C-Direct. Attorney David P. Reiner, II added to party P&C-Direct(pty:dft). Responses due by 7/25/2024.

(Text of Proposed Order)

NOTICE of Attorney Appearance by David P. Reiner, II on behalf of P&C-Direct

EMERGENCY MOTION with Certification of Emergency included by P&C-Direct. Responses due by 7/25/2024.

(Exhibit)

PAPERLESS ORDER on 40 Emergency Motion with Certification of Emergency. This Court has considered the Emergency Motion and the pertinent portions of the record, and is otherwise fully advised. In the Emergency Motion, Defendant P&C-Direct indicates that its counsel has attempted to confer with counsel for Plaintiff numerous times and that counsel for Plaintiff has failed to respond, in violation of Local Rule 7.1(a)(3), which requires counsel for the non-movant to "cooperate and act in good faith" with movant's counsel. Accordingly, it is hereby ORDERED that Plaintiff, through counsel, shall show cause by no later than 12:00 Noon on July 12, 2024, why the Emergency Motion should not be granted and Plaintiff should not be sanctioned for failing to cooperate with or respond to Defendant P&C-Direct's Counsel's conferral efforts.It is further ORDERED that all counsel who have received notice of the hearing scheduled to be held by Zoom on July 12, 2024, at 3:00PM shall appear so that they may be heard regarding whether and when to proceed with a preliminary injunction hearing and any other pending matters. Plaintiff's counsel shall be prepared to address which Defendants have received Notice and which Defendants, either directly or through counsel, have initiated contact with Plaintiffs. Responses due by 7/12/2024 at 12:00 NOON. Signed by Judge Melissa Damian on 7/11/2024.

ORDER SETTING HEARING BY ZOOM. Signed by Judge Melissa Damian on 7/12/2024. See attached document for full details.

REPLY to Response to Motion re 24 MOTION to Dismiss 1 Complaint, Motion to Dissolve Ex Parte TRO, and Opposition to Plaintiff's Motion for Preliminary Injunction filed by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123.

Exhibit A - Declaration of Liao Fu Jian on behalf of WHDPETSCares

Exhibit B - Declaration of Jianyong CAI of YZL123

Exhibit C - Declaration of Liang Huang of Granze Tech

Exhibit D - Declaration of Erjun Che of Hiliop

Exhibit E - Declaration of Liu Xiao Dong of Yunxin

(Exhibit F - Declaration of Brad Liu)

ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING [ECF NO. 35 ]: It is further ORDERED that Hongchang Deng, of the SHM Law Firm, may appear and participate in this action on behalf of Defendants WHDPETSCares, YZL123, Granze Tech, and Hiliop Reusable. The Clerk shall provide electronic notification of all electronic filings to Hongchang Deng at deng.hongchang@shm.law. Signed by Judge Melissa Damian on 7/12/2024. See attached document for full details.

RESPONSE TO ORDER TO SHOW CAUSE re 41 Order on Emergency Motion with Certification of Emergency, by Dongguan Saienchuangke Technology Co., Ltd.

ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING [ECF NO. 38 ]: It is further ORDERED that R. Joseph Trojan, of the Trojan Law Offices, may appear and participate in this action on behalf of Defendant Shenzhen Seven Stars Education Technology Co. Ltd. d/b/a P&C-Direct. The Clerk shall provide electronic notification of all electronic filings to R. Joseph Trojan at trojan@trojanlawoffices.com. Signed by Judge Melissa Damian on 7/12/2024. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge Melissa Damian: Status Conference RE: Preliminary Injunction Hearing held via Zoom on 7/12/2024. Order to Follow. Total time in court: 1 hour: 6 minutes. Attorney Appearance(s): Andrew Jonathan Palmer, Jianyin Liu, Robert Houpt Thornburg, Xin Sage Wen, Hongchang Deng, David P. Reiner, II, and R. Joseph Trojan. Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov.

PAPERLESS ORDER. THIS CAUSE came before the Court following a hearing held via Zoom on July 12, 2024, and upon Plaintiff's Ore Tenus Motion to Unseal, asserted at the hearing. THE COURT has reviewed the pertinent portions of the record and heard from counsel for the parties who appeared at the July 12 hearing. For the reasons stated and further detailed on the record, it is hereby ORDERED AND ADJUDGED that Plaintiff's Ore Tenus Motion to Unseal is GRANTED. The Clerk of Court is directed to unseal any presently sealed filings in this case. Signed by Judge Melissa Damian on 7/12/2024.

NOTICE of Compliance re 48 Order. All documents in this case have been unsealed per order at DE#48.

OMNIBUS ORDER FOLLOWING HEARING AND LIFTING TEMPORARY RESTRAINING ORDER. Preliminary Injunction Hearing set for 7/31/2024 at 01:00 PM in the Fort Lauderdale Division before Judge Melissa Damian. Responses due by 7/23/2024. Replies due by 7/26/2024. Status Report due by 7/17/2024. Signed by Judge Melissa Damian on 7/12/2024. See attached document for full details.

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Todd R. Tucker. Filing Fee $ 200.00 Receipt # AFLSDC-17683819 by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 7/31/2024.

(Text of Proposed Order)

MOTION for Extension of Time to Respond to Complaint re 1 Complaint, by P&C-Direct. Responses due by 7/31/2024.

(Text of Proposed Order)

NOTICE of Declaration of Andrew J. Palmer in support of Preliminary Injunction by Dongguan Saienchuangke Technology Co., Ltd., re 50 Order on Emergency Motion with Certification of Emergency

Decl. of Kang

Exhibit 1

(Exhibit 2)

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

Unopposed MOTION for Extension of Time to Respond to the Complaint re 1 Complaint, by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 8/1/2024.

(Text of Proposed Order)

ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING [ECF NO. 51 ]: It is further ORDERED that Todd R. Tucker, of the law firm of Calfee, Halter & Griswold LLP, may appear and participate in this action on behalf of Defendants WHDPETSCares, YZL123, Granze Tech, and Hiliop Reusable. The Clerk shall provide electronic notification of all electronic filings to Todd R. Tucker at ttucker@calfee.com. Signed by Judge Melissa Damian on 7/19/2024. See attached document for full details.

NOTICE of Attorney Appearance by Jianyin Liu on behalf of LIN&BABAY Direct. Attorney Jianyin Liu added to party LIN&BABAY Direct(pty:dft).

NOTICE of Filing Supplemental Declaration of Hongjun Zhang in Support of Motion to Dismiss and Opposition to Plaintiff's Motion for Preliminary Injunction by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123 re 24 MOTION to Dismiss 1 Complaint, Motion to Dissolve Ex Parte TRO, and Opposition to Plaintiff's Motion for Preliminary Injunction

(Affidavit -- Declaration of Hongjun Zhang)

MOTION to Dismiss for Lack of Jurisdiction 1 Complaint, by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan. Responses due by 8/6/2024.

Exhibit A- Evidence 1

Exhibit B- Evidence 2

Exhibit C- Evidence 3

Exhibit D- Evidence 4

Exhibit E- Evidence 5

(Affidavit Liu Decl.)

RESPONSE in Opposition re 7 EX PARTE MOTION ENTRY OF TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION, AND ORDER RESTRAINING TRANSFER OF ASSETS AND EXPEDITED DISCOVERY MOTION for Preliminary Injunction MOTION for Temporary Restraining Order filed by Furu Donghai. Replies due by 7/30/2024.

Exhibit A- '139 Patent

Exhibit B- '460 Patent

Exhibit C- USPTO Non-Final Rejection

Exhibit D- Plf's Response to Rejection of USPTO

(Exhibit E- Infringing Evidence)

RESPONSE in Opposition re 7 EX PARTE MOTION ENTRY OF TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION, AND ORDER RESTRAINING TRANSFER OF ASSETS AND EXPEDITED DISCOVERY MOTION for Preliminary Injunction MOTION for Temporary Restraining Order filed by KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan. Replies due by 7/30/2024.

Exhibit A- Zhangyueyuan Evidence

Exhibit B- Shuheyan KSR Evidence

Exhibit C- KYM Evidence

Exhibit D- Lin&BABAY Direct Evidence

Exhibit E- '139 Patent

Exhibit F- '460 Patent

Exhibit G- USPTO Rejection

(Exhibit H - Plf's Response to Rejection)

RESPONSE in Opposition re 7 EX PARTE MOTION ENTRY OF TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION, AND ORDER RESTRAINING TRANSFER OF ASSETS AND EXPEDITED DISCOVERY MOTION for Preliminary Injunction MOTION for Temporary Restraining Order filed by P&C-Direct. Replies due by 7/30/2024.

DECLARATION OF LINA HONG

(DECLARATION OF R. JOSEPH TROJAN)

MOTION for Limited Discovery and to Stay the Preliminary Injunction hearing by Dongguan Saienchuangke Technology Co., Ltd.

(Text of Proposed Order) Added MOTION to Stay on 7/24/2024 (wce)

Clerk's Notice to Filer re 63 MOTION for Limited Discovery and to Stay the Preliminary Injunction hearing. Motion with Multiple Reliefs Filed as One Relief; ERROR - The Filer selected only one relief event and failed to select the additional corresponding events for each relief requested in the motion. The docket entry was corrected by the Clerk. It is not necessary to refile this document but future filings must comply with the instructions in the CM/ECF Attorney User's Manual.

PAPERLESS ORDER GRANTING 52 Defendant's Motion for Extension of Time and 55 Defendants' Unopposed Motion for Extension of Time. Finding good cause for the requested extensions of time, and noting Plaintiff does not object to either request, it is ORDERED AND ADJUDGED that the Motions are GRANTED nunc pro tunc to July 23, 2024. Accordingly, Defendants P&C Direct, Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, and YZL123 shall respectively respond to 1 Plaintiff's Complaint by August 6, 2024. Signed by Judge Melissa Damian on 7/24/2024.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

Defendant's NOTICE of Remote Attendance of Witness and Interpreter for Hearing on Motion for Preliminary Injunction by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123

Defendant's NOTICE of Remote Attendance of Witness and Interpreter for Hearing on Motion for Preliminary Injunction by P&C-Direct

AFFIDAVIT in Support re 63 MOTION for Limited Discovery and to Stay the Preliminary Injunction hearing MOTION to Stay filed by Dongguan Saienchuangke Technology Co., Ltd.

PAPERLESS ORDER. THIS CAUSE is before the Court on 63 Plaintiff's Motion for Limited Discovery and to Stay Preliminary Injunction Hearing. The Court has reviewed the Motion and the pertinent portions of the record and is otherwise fully advised in the premises. The Motion is due to be denied because Plaintiff has failed to certify that they conferred or made reasonable efforts to confer with Defendants, and what the results of that conferral were, pursuant to Local Rule 7.1(a)(3) of the U.S. District Court for the Southern District of Florida. Accordingly, it is ORDERED AND ADJUDGED that the Motion is DENIED WITHOUT PREJUDICE. Signed by Judge Melissa Damian on 7/26/2024.

Exhibit List for Hearing on Preliminary Injunction by P&C-Direct.

Witness List for Hearing on Preliminary Injunction by P&C-Direct.

Witness List For Hearing on Motion for Preliminary Injunction by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123.

Exhibit List For Hearing on Motion for Preliminary Injunction by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123.

Renewed MOTION for Limited Discovery by Dongguan Saienchuangke Technology Co., Ltd.

Exhibit 1

(Text of Proposed Order)

Renewed MOTION to Stay Preliminary Injunction by Dongguan Saienchuangke Technology Co., Ltd. Responses due by 8/9/2024.

Exhibit 1

Affidavit Affidavit of Palmer

(Text of Proposed Order)

Exhibit List by Dongguan Saienchuangke Technology Co., Ltd.

Witness List by Dongguan Saienchuangke Technology Co., Ltd.

REPLY to 61 Response in Opposition to Motion, 60 Response in Opposition to Motion, by Dongguan Saienchuangke Technology Co., Ltd.

REPLY to 62 Response in Opposition to Motion, by Dongguan Saienchuangke Technology Co., Ltd.

(Exhibit 1)

RESPONSE in Opposition re 75 Renewed MOTION for Limited Discovery, 76 Renewed MOTION to Stay Preliminary Injunction filed by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Replies due by 8/5/2024.

OMNIBUS ORDER DENYING WITHOUT PREJUDICE MOTION FOR PRELIMINARY INJUNCTION [ECF NO. 7], CANCELING PRELIMINARY INJUNCTION HEARING, AND ADDRESSING OTHER PENDING MOTIONS: The Motion for Preliminary Injunction [ECF No. 7 ] is DENIED WITHOUT PREJUDICE. The Renewed Motion to Stay Preliminary Injunction Hearing [ECF No. 76 ] is DENIED AS MOOT. The Renewed Motion for Limited Discovery [ECF No. 75 ] is DENIED AS MOOT. The Preliminary Injunction hearing presently set for July 31, 2024, is CANCELED. No later than August 19, 2024, the parties shall meet and participate in a scheduling conference pursuant to Federal Rule of Civil Procedure 26(f), and, by August 26, 2024, the parties shall prepare and file a joint scheduling report. Signed by Judge Melissa Damian on 7/29/2024. See attached document for full details.

TRANSCRIPT of Status Conference Re: Preliminary Injunction Hearing Held Via Zoom - Part 2 of 2 held on July 12, 2024 before Judge Melissa Damian, 1 - 36 pages, Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/19/2024. Redacted Transcript Deadline set for 8/29/2024. Release of Transcript Restriction set for 10/28/2024.

Oppositon to 67 Notice (Other) of Remote Attendance of Witness by Dongguan Saienchuangke Technology Co., Ltd.

MOTION to Withdraw Document 84 Response/Reply (Other) by Dongguan Saienchuangke Technology Co., Ltd. Responses due by 8/12/2024.

NOTICE of Voluntary Dismissal as to Defendant WissTec by Dongguan Saienchuangke Technology Co., Ltd.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

MOTION TO DISMISS 1 Complaint, FOR FAILURE TO STATE A CLAIM by P&C-Direct. Responses due by 8/20/2024.

(Affidavit of Huanbiao Chen)

MOTION to Stay re 65 Order on Motion for Extension of Time, -- Motion to Stay Answer Deadline Pending Ruling on Motion to Dismiss (Dkt. 24) by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 8/20/2024.

RESPONSE in Opposition re 59 MOTION to Dismiss for Lack of Jurisdiction 1 Complaint, filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 8/13/2024.

(Decl. of Palmer)

REPLY to Response to Motion re 59 MOTION to Dismiss for Lack of Jurisdiction 1 Complaint, filed by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

MOTION for Clerk's Entry of Default as to AOXUAN NIC, Aberzey, Ailevant, BNL Brands, BOOTLION, Bossel, DING SHI fashion, DXNONA, DaWikity Kids, F-A2Z, HECLIFE, Huansihan-US, Hugh. Grant, JAY-US, Lishx shop, MIGHTYCOS, Mengfutong, NaBeiYing, Nezun Store, Qidordour, Sitengle, Sosmar-US, TXKKEXP, TravelRevealer, UZSOMX, UZZOL STORE, WELTRXE, sitong22, the red hat by Dongguan Saienchuangke Technology Co., Ltd.

Decl of Palmer

(Text of Proposed Order)

CLERK'S ENTRY OF DEFAULT: Granting 93 MOTION for Clerk's Entry of Default as to AOXUAN NIC, Aberzey, Ailevant, BNL Brands, BOOTLION, Bossel, DING SHI fashion, DXNONA, DaWikity Kids, F-A2Z, HECLIFE, Huansihan-US, Hugh. Grant, JAY-US, Lishx shop, MIGHTYCOS, Mengfutong, NaBeiYing, filed by Dongguan Saienchuangke Technology Co., Ltd. Signed by DEPUTY CLERK on 8/12/2024. See attached document for full details.

Defendant's MOTION to Quash Plaintiff's Subpoena Duces Tecum to Amazon, Defendant's MOTION for Protective Order by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123.

Exhibit A

(Exhibit B)

TRANSCRIPT of Status Conference Re: Preliminary Injunction Hearing Held Via Zoom - Part 1 of 2 held on July 12. 2024 before Judge Melissa Damian, 1 - 12 pages, Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/3/2024. Redacted Transcript Deadline set for 9/13/2024. Release of Transcript Restriction set for 11/12/2024.

MOTION to Quash Plaintiff's Subpoena Duces Tecum Issued to Amazon by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

RESPONSE in Opposition re 89 MOTION to Stay re 65 Order on Motion for Extension of Time, -- Motion to Stay Answer Deadline Pending Ruling on Motion to Dismiss (Dkt. 24) filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 8/27/2024.

(STRICKEN PER DE 102) Corporate Disclosure Statement by P&C-Direct Modified Text on 8/22/2024

Clerk's Notice to Filer re 100 Certificate of Other Affiliates/Corporate Disclosure Statement. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and LR 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules.

NOTICE of Striking 100 Certificate of Other Affiliates/Corporate Disclosure Statement filed by P&C-Direct by P&C-Direct

Corporate Disclosure Statement by P&C-Direct

NOTICE of Voluntary Dismissal as to Defendant DaillShop without prejudice by Dongguan Saienchuangke Technology Co., Ltd.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

MOTION to Sever and Dismiss for Misjoinder by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan. Responses due by 9/6/2024.

RESPONSE in Opposition re 88 MOTION TO DISMISS 1 Complaint, FOR FAILURE TO STATE A CLAIM filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 9/3/2024.

RESPONSE in Opposition re 95 Defendant's MOTION to Quash Plaintiff's Subpoena Duces Tecum to AmazonDefendant's MOTION for Protective Order filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 9/3/2024.

(Exhibit 1)

SCHEDULING REPORT - Rule 16.1 by Dongguan Saienchuangke Technology Co., Ltd.

Text of Proposed Order Plaintiff's proposed order

(Text of Proposed Order Attorney Thornburg Defendants Proposed Order)

Defendant's REPLY to Response to Motion re 89 MOTION to Stay re 65 Order on Motion for Extension of Time, -- Motion to Stay Answer Deadline Pending Ruling on Motion to Dismiss (Dkt. 24) filed by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123.

RESPONSE in Opposition re 97 MOTION to Quash Plaintiff's Subpoena Duces Tecum Issued to Amazon filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 9/4/2024.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

REPLY to Response to Motion re 88 MOTION TO DISMISS 1 Complaint, FOR FAILURE TO STATE A CLAIM filed by P&C-Direct.

Defendant's REPLY to Response to Motion re 95 Defendant's MOTION to Quash Plaintiff's Subpoena Duces Tecum to AmazonDefendant's MOTION for Protective Order filed by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

RESPONSE in Opposition re 106 MOTION to Sever and Dismiss for Misjoinder filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 9/13/2024.

REPLY to Response to Motion re 106 MOTION to Sever and Dismiss for Misjoinder filed by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan.

NOTICE of Voluntary Dismissal as to Defendant PETBSNVB without prejudice by Dongguan Saienchuangke Technology Co., Ltd.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

MOTION for Clerk's Entry of Default as to Hamsoo, Helian Electronics, Koknwoa Direct, VIVAVIVA, ZRRHOO by Dongguan Saienchuangke Technology Co., Ltd.

Decl. of Palmer

(Text of Proposed Order)

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

CLERK'S DEFAULT ENTRY Granting 120 MOTION for Clerk's Entry of Default as to Hamsoo, Helian Electronics, Koknwoa Direct, VIVAVIVA, ZRRHOO filed by Dongguan Saienchuangke Technology Co., Ltd. Signed by DEPUTY CLERK on 9/19/2024. See attached document for full details.

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan

STATUS REPORT by Dongguan Saienchuangke Technology Co., Ltd.

Defendant's Corporate Disclosure Statement by WHDPETSCares

Defendant's Corporate Disclosure Statement by YZL123

Defendant's Corporate Disclosure Statement by Granze Tech

Defendant's Corporate Disclosure Statement by Hiliop Reusable WB Direct

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE: re 94 and 122 Clerk's Entries of Default. Accordingly, it is ORDERED AND ADJUDGED that Plaintiff must file one of the following two responses by October 25, 2024: Plaintiff's failure to file a Motion for Default Final Judgment or Notice of Joint Liability within the specified time will result in sanctions, including but not limited to, dismissal without prejudice as to these Defendants. Signed by Judge Melissa Damian on 10/11/2024. See attached document for full details.

OMNIBUS ORDER: It is hereby ORDERED AND ADJUDGED that Plaintiff's Withdrawal of Opposition to Notice of Remote Attendance of Witness [ECF No. 85 ] is GRANTED. It is further ORDERED AND ADJUDGED that Defendants' Motion to Stay Answer Deadline Pending Ruling on Motion to Dismiss [ECF No. 89 ] is GRANTED. Accordingly, the deadline for all Defendants to respond to Plaintiff's Complaint is hereby STAYED until further Order of the Court. Signed by Judge Melissa Damian on 10/11/2024. See attached document for full details.

ORDER OF REFERRAL TO MAGISTRATE JUDGE: All pretrial non-dispositive motions and discovery matters are referred to United States Magistrate Judge Alicia O. Valle. In particular, Defendants, WHDPETSCares, YZL123, Granze Tech; and Hiliop Reusable WB Direct's, Motion to Quash Plaintiff's Subpoena Duces Tecum to Amazon and for a Protective Order [ECF No. 95 ], filed August 12, 2024, and Defendants, Zhangyueyuan, Furu Donghai, SHUHEYAN KSR, KYM MLSMYXGS and LIN&BABAY Direct's Motion to Quash Plaintiff's Subpoena Duces Tecum [ECF No. 97 ], filed August 14, 2024 are REFERRED to Magistrate Judge Valle to take all necessary and proper action as required by law. Signed by Judge Melissa Damian on 10/11/2024. See attached document for full details.

ORDER OF DISMISSAL AS TO CERTAIN DEFENDANTS: re Notices of Voluntary Dismissal as to Certain Defendants [ECF Nos. 86, 104, 118 ("Notices")]. The above-styled case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: WissTec, Daillshop, and PETBSNVB. To the extent not otherwise disposed of, all pending motions are DENIED AS MOOT and all deadlines are TERMINATED with respect to the above-listed Defendants only. Signed by Judge Melissa Damian on 10/11/2024. See attached document for full details.

MOTION for Default Judgment by Dongguan Saienchuangke Technology Co., Ltd.

Decl. of Palmer

Exhibit 1

Exhibit 2

Text of Proposed Order Proposed granting final default judgment

(Text of Proposed Order Proposed Final judgment order)

CERTIFICATE OF SERVICE by Dongguan Saienchuangke Technology Co., Ltd., re 134 MOTION for Default Judgment

ORDER Setting Hearing on Motions: It is ORDERED AND ADJUDGED that this matter is set for a Motions Hearing on Tuesday, December 11, 2024, at 2:00 p.m., at the United States Federal Building and Courthouse, 299 East Broward Boulevard, Courtroom 205C, Fort Lauderdale, Florida 33301. Signed by Judge Melissa Damian on 11/7/2024. See attached document for full details.

NOTICE of Attorney Appearance by Brandon Todd Holmes on behalf of Dongguan Saienchuangke Technology Co., Ltd. Attorney Brandon Todd Holmes added to party Dongguan Saienchuangke Technology Co., Ltd.,(pty:pla).

NOTICE of Attorney Appearance by Luca Lee Hickman on behalf of Dongguan Saienchuangke Technology Co., Ltd. Attorney Luca Lee Hickman added to party Dongguan Saienchuangke Technology Co., Ltd.,(pty:pla).

NOTICE of Voluntary Dismissal as to Defendant VIVAVIVA without prejudice by Dongguan Saienchuangke Technology Co., Ltd.

Plaintiff's MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Tianyu Ju. Filing Fee $ 200.00 Receipt # AFLSDC-17982200 by Dongguan Saienchuangke Technology Co., Ltd. Responses due by 11/27/2024.

(Text of Proposed Order [PROPOSED]ORDER GRANTING MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING)

PAPERLESS ORDER GRANTING 140 Plaintiff's Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. All pretrial non-dispositive motions have been referred to the undersigned for appropriate disposition. ECF No. 132 at 1. Accordingly, it is hereby ORDERED AND ADJUDGED that Attorney Tianyu Ju, of the law firm of Glacier Law LLP, may appear and participate in this action as co-counsel on behalf of Plaintiff Dongguan Saienchuangke Technology Co., LTD. Further, the Clerk shall provide electronic notification of all electronic filings to Attorney Ju at iris.ju@glacier.law. Signed by Magistrate Judge Alicia O. Valle on 11/14/2024.

MOTION to Withdraw as Attorney by Andrew J. Palmer for / by Dongguan Saienchuangke Technology Co., Ltd. Responses due by 12/4/2024.

(Text of Proposed Order)

PAPERLESS ORDER GRANTING 142 Plaintiff's Motion to Withdraw Attorney Andrew J. Palmer (the "Motion"). Based on a review of the record and for efficient case management, a response to the Motion is unnecessary. In the Motion, Attorney Andrew J. Palmer, of the law firm Palmer Law Group, PA, seeks to withdraw as counsel for Plaintiff and represents that Attorneys Brandon Todd Holmes and Luca Lee Hickman, of the law firm Dinsmore & Shohl LLP, along with Tianyu Ju (admitted pro hac vice), of the law firm Glacier Law LLP, will continue to represent Plaintiff in this case. ECF No. 142 at 1. Further, Plaintiff consents to the requested withdrawal. Id. Accordingly, Attorney Andrew J. Palmer is withdrawn as counsel for all purposes in this case. The Clerk shall remove Attorney Palmer from the docket and cease delivery of notifications of electronic filings to him. Signed by Magistrate Judge Alicia O. Valle on 11/21/2024.

MOTION for Leave to Appear Remotely at December 11, 2024 Hearing at 2:00 p.m. Attorney/Representative: R. Joseph Trojan by P&C-Direct. Responses due by 12/9/2024.

(Text of Proposed Order)

ORDER DENYING MOTION FOR DEFENSE COUNSEL TO ATTEND HEARING VIA REMOTE VIDEO CONFERENCE [ECF NO. 144 ]: All parties shall appear in person for the hearing set for December 11, 2024. Signed by Judge Melissa Damian on 12/3/2024. See attached document for full details.

ORDER GRANTING IN PART AND DENYING IN PART 95 and 97 Defendants' Motions to Quash. Signed by Magistrate Judge Alicia O. Valle on 12/5/2024. See attached document for full details.

NOTICE of Attorney Appearance by James Robert Leahy on behalf of Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Attorney James Robert Leahy added to party Granze Tech(pty:dft), Attorney James Robert Leahy added to party Hiliop Reusable WB Direct(pty:dft), Attorney James Robert Leahy added to party WHDPETSCares(pty:dft), Attorney James Robert Leahy added to party YZL123(pty:dft).

NOTICE of Change of Address/Contact Information; by Giulia Christine Farrior

CLERK'S NOTICE - Attorney Admissions has not updated address and/or email information for attorney(s) Giulia Christine Farrior re 148 Notice of Change of Address, Email or Law Firm Name. Attorney Giulia Christine Farrior has not completed the required procedures for updating their information with the Court. After filing something in any pending cases, Attorney is instructed to go to their PACER account, Manage My Account, to complete the process of updating their information. The Court is NOT responsible for updating secondary email addresses. See the Courts website for detailed instructions. www.flsd.uscourts.gov/updating-your-information

NOTICE of Change of Address/Contact Information; by James Robert Leahy

NOTICE of Change of Address/Contact Information; by Robert Houpt Thornburg

CLERK'S NOTICE - Attorney Admissions has updated the address information as submitted through attorneys PACER account for attorney Giulia Christine Farrior

CLERK'S NOTICE - Attorney Admissions has updated the address information as submitted through attorneys PACER account for attorney James Robert Leahy

CLERK'S NOTICE - Attorney Admissions has updated the address information as submitted through attorneys PACER account for attorney Robert Houpt Thornburg

PAPERLESS Minute Entry for proceedings held before Judge Melissa Damian: Motions Hearing held on 12/11/2024 at the Fort Lauderdale Division regarding 24 Motion to Dismiss, 59 Motion to Dismiss, 88 Motion to Dismiss, 106 Motion to Dismiss for Misjoinder. Total time in court: 2 hour(s) : 22 minutes. Order to follow. Attorney Appearance(s): Luca Lee Hickman, Jianyin Liu, Robert Houpt Thornburg, Giulia Christine Farrior, and David P. Reiner, II. Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov.

Defendant's NOTICE of Filing Presentation from the December 11th, 2024 Hearing by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123

(Exhibit 1)

OMNIBUS ORDER ON MOTIONS TO DISMISS [ECF NOS. 24, 59, 88, 106 ]: The Thornburg Defendants' Motion to Dismiss [ECF No. 24 ] is GRANTED. The Liu Defendants' First Motion to Dismiss [ECF No. 59 ] is DENIED. P&C-Direct's Motion to Dismiss [ECF No. 88 ] is GRANTED. The Liu Defendants' Second Motion to Dismiss for Misjoinder [ECF No. 106 ]. Plaintiff shall file an Amended Complaint on or before January 3, 2025. Signed by Judge Melissa Damian on 12/17/2024. See attached document for full details.

Plaintiff's OBJECTION of Magistrate Judge 146 Order on Motion to Quash, Order on Motion for Protective/Confidentiality Order, to District Court

First AMENDED COMPLAINT against Furu Donghai, Granze Tech, Hiliop Reusable WB Direct, KYM MLSMYXGS, LIN&BABAY Direct, P&C-Direct, SHUHEYAN KSR, WHDPETSCares, YZL123, Zhangyueyuan filed in response to Order Granting Motion for Leave, filed by Dongguan Saienchuangke Technology Co., Ltd.

Exhibit 1 - D139 Patent

Exhibit 2 - Amazon Listing Printouts

Exhibit 3 - Complaint

(Exhibit 4 - Test Purchases)

MOTION to Dismiss for Lack of Jurisdiction 159 Amended Complaint/Amended Notice of Removal, by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan. Responses due by 1/23/2025.

(Exhibit A-Amazon Business Solution Agreement)

Amended SCHEDULING REPORT - Rule 16.1 by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123

(Text of Proposed Order)

ANSWER and Affirmative Defenses to Amended Complaint by P&C-Direct.

Defendant's MOTION TO DISMISS 159 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM WITH PREJUDICE by Granze Tech, Hiliop Reusable WB Direct, WHDPETSCares, YZL123. Responses due by 1/31/2025.

ORDER SETTING TRIAL AND PRE-TRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MATTERS TO MAGISTRATE JUDGE: Jury Trial set for 3/9/2026 in Fort Lauderdale Division before Judge Melissa Damian. Calendar Call set for 3/4/2026 1:30 PM in Fort Lauderdale Division before Judge Melissa Damian. Mediation Deadline 11/14/2025. Pursuant to 28 U.S.C. § 636(b)(1) and this Districts Magistrate Judge Rules, all pretrial non-dispositive motions are referred to United States Magistrate Judge Alicia O. Valle. Signed by Judge Melissa Damian on 1/21/2025. See attached document for full details. (wce) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here.

RESPONSE in Opposition re 160 MOTION to Dismiss for Lack of Jurisdiction 159 Amended Complaint/Amended Notice of Removal, filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 1/30/2025.

(Declaration of Li Yang)

TRIAL BRIEF - Opening Claim Construction Brief by Dongguan Saienchuangke Technology Co., Ltd.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 163 Defendant's MOTION TO DISMISS 159 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM WITH PREJUDICE by Dongguan Saienchuangke Technology Co., Ltd.

TRIAL BRIEF Thornburg Defendants Opening Claim Construction Brief by Hiliop Reusable WB Direct, WHDPETSCares, YZL123, Granze Tech.

Declaration of Yizhou Liu

Exhibit 1 to Declaration of Yizhou Liu

Exhibit 2 to Declaration of Yizhou Liu

(Exhibit 3 to Declaration of Yizhou Liu)

Unopposed MOTION to Withdraw as Attorney by R. Joseph Trojan and David P. Reiner for / by P&C-Direct. Responses due by 2/11/2025.

(Text of Proposed Order)

REPLY in Support of Motion re 160 MOTION to Dismiss for Lack of Jurisdiction 159 Amended Complaint/Amended Notice of Removal. filed by Furu Donghai, KYM MLSMYXGS, LIN&BABAY Direct, SHUHEYAN KSR, Zhangyueyuan.

PAPERLESS ORDER GRANTING 167 Plaintiff's Unopposed Motion for a One Week Extension of Time (the "Motion"). All pretrial non-dispositive motions have been referred to the undersigned for appropriate disposition. See ECF No. 164 at 3. Accordingly, by Friday, February 7, 2025, Plaintiff must respond to 163 Defendants' Motion to Dismiss First Amended Complaint. Signed by Magistrate Judge Alicia O. Valle on 1/28/2025.

PAPERLESS ORDER GRANTING 169 Unopposed Motion to Withdraw as Counsel for Defendant Shenzhen Seven Stars Education Technology Co. Ltd., dba P&C-Direct ("Defendant") (the "Motion"). In the Motion, counsel for Defendant seeks to withdraw as counsel of record "for reasons including non-payment of attorney's fees and a fundamental disagreement about how to proceed with the defense of the case." ECF No. 169 at 1. Under these circumstances, the undersigned finds good cause exists to permit Defendant's counsel to withdraw from the case. Accordingly, other than as set forth below, Attorneys R. Joseph Trojan, of Trojan Law Offices, and David P. Reiner, of Reiner & Reiner PA, are relieved of any further obligation in this matter. A corporate entity like Defendant, however, may not appear before this Court without an attorney and must be represented by counsel. Palazzo v. Gulf Oil Corp., 764 F.2d 1381, 1385 (11th Cir. 1985). Thus, by February 27, 2025, Defendant must retain new counsel (who must file a Notice of Appearance). Within two days from the date of this Order, Defendant's former counsel must: (i) serve this Order on Defendant via First Class U.S. Mail and email to the last known address listed in the Motion, see ECF No. 169 at 3; and (ii) file a Notice confirming service. Lastly, if Defendant fails to timely comply with this Order, Plaintiff may file a motion for default judgment against Defendant. Signed by Magistrate Judge Alicia O. Valle on 1/28/2025. (lbe) Modified text/status per Chambers on 2/14/2025

CERTIFICATE OF SERVICE by P&C-Direct re 172 Order on Motion to Withdraw as Attorney

RESPONSE in Opposition re 163 Defendant's MOTION TO DISMISS 159 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM WITH PREJUDICE filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 2/14/2025.

Declaration of Wang Naiying

Exhibit 1 to Declaration

Exhibit 2 to Declaration

Exhibit 3 to Declaration

Exhibit 4 to Declaration

Exhibit 5 to Declaration

(Exhibit 6 to Declaration)

ORDER REQUIRING RESPONSE TO PLAINTIFF'S OBJECTION TO MAGISTRATE JUDGE'SORDER GRANTING IN PART MOTIONS TO QUASH SUBPOENA [ECF NO. 158 ]: It is hereby ORDERED AND ADJUDGED that by February 18, 2025, Defendants shall file a response to Plaintiff's Objection [ECF No. 158]. Signed by Judge Melissa Damian on 2/10/2025. See attached document for full details.

ORDER DENYING MOTION FOR DEFAULT JUDGMENT [ECF NO. 134 ]. Signed by Judge Melissa Damian on 2/10/2025. See attached document for full details.

MOTION to Sever by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR. Responses due by 2/24/2025.

Activation of terminated local counsel David Reiner (Text entry; no document attached.)

TRIAL BRIEF PLAINTIFFS RESPONSE IN OPPOSITION TO THE THORNBURG DEFENDANTS OPENING CLAIM CONSTRUCTION BRIEF [ECF. No. 168] by Dongguan Saienchuangke Technology Co., Ltd.

TRIAL BRIEF Thornburg Defendants Responsive Claim Construction Brief by Hiliop Reusable WB Direct, WHDPETSCares, YZL123, Granze Tech.

NOTICE Regarding Mediation by Dongguan Saienchuangke Technology Co., Ltd.

Clerk's Notice to Filer re 180 Notice (Other). Parties/Mediator Not Added; ERROR - The Filer failed to add all parties from the complaint/petition/removal, etc. or the mediator. Filer is instructed to file a Notice of Entry of Parties Listed into CM/ECF and add the additional parties/mediator.

AFFIDAVIT in Support signed by: Fusheng Kang re 177 MOTION to Sever by Furu Donghai

AFFIDAVIT in Support signed by: Yumei Kang re 177 MOTION to Sever by KYM MLSMYXGS

AFFIDAVIT in Support signed by: Shuren Kang re 177 MOTION to Sever by SHUHEYAN KSR

MOTION for Extension of Time to File an Opening Claim Construction Brief re 164 Scheduling Order, Order Referring Case to Mediation, Order Referring Case to Magistrate Judge, by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR. Responses due by 2/25/2025.

NOTICE of Attorney Appearance by David P. Reiner, II on behalf of P&C-Direct

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Zheng "Andy" Liu. Filing Fee $ 250.00 Receipt # AFLSDC-18199549 by P&C-Direct. Responses due by 2/26/2025.

(Text of Proposed Order)

RESPONSE in Opposition re 185 MOTION for Extension of Time to File an Opening Claim Construction Brief re 164 Scheduling Order, Order Referring Case to Mediation, Order Referring Case to Magistrate Judge, filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 2/19/2025.

(Exhibit A - Liu Email)

Unopposed MOTION to Withdraw as Attorney by JIANYIN LIU for / by LIN&BABAY Direct, Zhangyueyuan. Responses due by 2/27/2025.

REPLY in Support of Motion re 185 MOTION for Extension of Time to File an Opening Claim Construction Brief re 164 Scheduling Order, Order Referring Case to Mediation, Order Referring Case to Magistrate Judge. filed by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR.

PAPERLESS ORDER GRANTING 187 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. All pretrial non-dispositive motions have been referred to the undersigned for appropriate disposition. ECF No. 164 at 3. Accordingly, it is hereby ORDERED AND ADJUDGED that Attorney Zheng "Andy" Liu, of the law firm of Aptum Law, may appear and participate in this action as counsel on behalf of Defendant Shenzhen Seven Stars Education Technology Co. Ltd. d/b/a P&C-Direct. Further, the Clerk shall provide electronic notification of all electronic filings to Attorney Liu at bjliuzheng@gmail.com. Signed by Magistrate Judge Alicia O. Valle on 2/14/2025.

PAPERLESS ORDER GRANTING 189 Unopposed Motion to Withdraw as Attorney (the "Motion"). In the Motion, counsel for Defendants Zhangyueyuan and LINBABY Direct (the "Corporate Defendants") seeks to withdraw as counsel of record due to "Defendants' failure to pay further attorney fees and unwillingness to continue the litigation." ECF No. 189 at 2. Under these circumstances, the undersigned finds good cause exists to permit the Corporate Defendants' counsel to withdraw from the case. Accordingly, other than as set forth below, Attorney Jianyin Liu, of the Law Offices of James Liu PLLC, is relieved of any further obligation in this matter. Corporate entities like Corporate Defendants Zhangyueyuan and LINBABY Direct, however, may not appear before this Court without an attorney and must be represented by counsel. Palazzo v. Gulf Oil Corp., 764 F.2d 1381, 1385 (11th Cir. 1985). Thus, by March 17, 2025, Corporate Defendants Zhangyueyuan and LINBABY Direct must retain new counsel (who must file a Notice of Appearance). Within two business days from the date of this Order, the Corporate Defendants' former counsel must: (i) serve this Order on Corporate Defendants Zhangyueyuan and LINBABY Direct via First Class U.S. Mail and email to the last known email addresses listed in the Motion, see ECF No. 189 at 2; and (ii) file a Notice confirming service. Lastly, if Corporate Defendants Zhangyueyuan and LINBABY Direct fail to timely comply with this Order, Plaintiff may file a motion for default judgment against the Corporate Defendants. Signed by Magistrate Judge Alicia O. Valle on 2/14/2025. (lbe) Modified Text on 2/18/2025

Defendant's REPLY in Support of Motion re 163 Defendant's MOTION TO DISMISS 159 Amended Complaint/Amended Notice of Removal, FOR FAILURE TO STATE A CLAIM WITH PREJUDICE. filed by Hiliop Reusable WB Direct, WHDPETSCares, YZL123, Granze Tech.

NOTICE of Compliance to Serve Defendants Order of Court by The Law Offices of James Liu PLLC re 192 Order on Motion to Withdraw as Attorney. Attorney Jianyin Liu added to party The Law Offices of James Liu PLLC(pty:ip).

TRIAL BRIEF Thornburg Defendants Reply in Support of Opening Claim Construction Brief by Hiliop Reusable WB Direct, WHDPETSCares, YZL123, Granze Tech.

TRIAL BRIEF Plaintiff's Reply in Support of Opening Claim Construction (Markman) Brief by Dongguan Saienchuangke Technology Co., Ltd.

Defendant's RESPONSE to 158 Plaintiff's OBJECTION of Magistrate Judge 146 Order on Motion to Quash, Order on Motion for Protective/Confidentiality Order, to District Court by Hiliop Reusable WB Direct, WHDPETSCares, YZL123, Granze Tech.

RESPONSE in Opposition re 177 MOTION to Sever filed by Dongguan Saienchuangke Technology Co., Ltd. Replies due by 3/3/2025.

(Liu, Jianyin) (Entered: 02/26/2025) (Text entry; no document attached.)

REPLY in Support of Motion re 177 MOTION to Sever. filed by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR.

ORDER CONTINUING MARKMAN HEARING: It is ORDERED that the Markman hearing set by the Scheduling Order [ECF No. 164 at 2] on March 14, 2025, is hereby CONTINUED. The Court, in due course, will enter an Order resetting the Markman hearing. It is further ORDERED that the parties are expected to comply with all remaining and active deadlines set forth in this Court's Scheduling Order. Signed by Judge Melissa Damian on 3/12/2025. See attached document for full details.

ORDER ON MOTION FOR EXTENSION TO FILE BRIEF [ECF NO. 185 ]: Accordingly, it isORDERED AND ADJUDGED that the Moving Defendants' Motion for Extension to File Brief [ECF No. 185] is GRANTED nunc pro tunc to February 15, 2025. Signed by Judge Melissa Damian on 3/12/2025. See attached document for full details.

TRANSCRIPT of Motion Hearing held on December 11, 2024 before Judge Melissa Damian, 1 - 104 pages, Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/4/2025. Redacted Transcript Deadline set for 4/14/2025. Release of Transcript Restriction set for 6/12/2025.

NOTICE of Filing Opening Claim Construction Brief by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR re 201 Order on Motion for Extension of Time, 164 Scheduling Order, Order Referring Case to Mediation, Order Referring Case to Magistrate Judge

Exhibit A-`139 Patent

(Exhibit B- USPTO Final Rejection)

TRIAL BRIEF Response in Opposition to Liu Defendants' Opening Claim Construction Brief (ECF No. 203) by Dongguan Saienchuangke Technology Co., Ltd.

(Exhibit Ex. A - Dictionary Printouts)

REPLY to 204 Trial Brief by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR.

ORDER ON PLAINTIFF'S OBJECTION TO THE MAGISTRATE JUDGE'S ORDER ON DEFENDANTS' MOTIONS TO QUASH [ECF NO. 158] overruling 158 Appeal/Objection of Magistrate Judge Order to District Court. Signed by Judge Melissa Damian on 4/9/2025. See attached document for full details.

PAPERLESS ORDER TO SHOW CAUSE. This cause comes before the Court upon a sua sponte review of the record. The undersigned previously granted former counsel's 189 Unopposed Motion to Withdraw as Attorney for Defendants Zhangyueyuan and LINBABY Direct (the "Corporate Defendants") and ordered that the Corporate Defendants retain new counsel (who must file a Notice of Appearance) by March 17, 2025. See ECF No. 192. To date, however, the Corporate Defendants have not complied with the Order. Accordingly, within ten days from the date of this Order, the Corporate Defendants shall: (i) retain new counsel (who must file a Notice of Appearance); and (ii) show cause why a default judgment should not be entered against them. If the Corporate Defendants fail to timely comply with this Order, Plaintiff is directed to file a motion for default judgment against the Corporate Defendants. Signed by Magistrate Judge Alicia O. Valle on 4/17/2025.

PAPERLESS ORDER TO SHOW CAUSE. This cause comes before the Court upon a sua sponte review of the record. The undersigned previously issued an Order to Show Cause, requiring Defendants Zhangyueyuan and LINBABY Direct (the "Corporate Defendants") to retain new counsel and show cause why a default judgment should not be entered against them. See ECF No. 207; see also ECF No. 192. The undersigned also instructed Plaintiff to file a motion for default judgment against the Corporate Defendants if they failed to timely comply with the Order to Show Cause. ECF No. 207. To date, the Corporate Defendants have not complied with the Order to Show Cause, and the deadline for compliance has passed. See id. Accordingly, within seven days from the date of this Order, Plaintiff is directed to file a motion for default judgment against the Corporate Defendants. Signed by Magistrate Judge Alicia O. Valle on 5/2/2025.

ORDER SETTING HEARING ON MOTIONS Motion Hearing set for 5/23/2025 10:00 AM in Fort Lauderdale Division before Judge Melissa Damian. Signed by Judge Melissa Damian on 5/6/2025. See attached document for full details.

MOTION for Default Judgment Against Defendants Lin&Babay Direct and Zhangyueyuan by Dongguan Saienchuangke Technology Co., Ltd.

Exhibit Ex. 1 - Hickman Declaration

Exhibit Ex. 2 - Liao Declaration

Exhibit Ex. 3 - US D1,026,139

Exhibit Ex. 4 - Amazon Printout

Exhibit Ex. 5 - Amazon Printout

(Exhibit Ex. 6 - Summary Charts)

PAPERLESS Minute Entry for proceedings held before Judge Melissa Damian: Motion Hearing held on 5/23/2025 in the Fort Lauderdale Division re 163 Defendants' Motion to Dismiss for Failure to State a Claim filed by WHDPETSCares, Granze Tech, Hiliop Reusable WB Direct, YZL123; 160 Defendants' Motion to Dismiss for Lack of Jurisdiction filed by Furu Donghai, LIN&BABAY Direct, Zhangyueyuan, KYM MLSMYXGS, SHUHEYAN KSR; 177 Defendants' Motion to Dismiss for Misjoinder filed by Furu Donghai, KYM MLSMYXGS, SHUHEYAN KSR. Total time in court: 3 hour(s) : 10 minutes. Order to follow. Attorney Appearance(s): Luca Lee Hickman, Robert Houpt Thornburg, Giulia Christine Farrior, and Jianyin Liu. Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov.

Defendant's NOTICE of Filing Presentation from the May 23rd, 2025 Hearing by Hiliop Reusable WB Direct, WHDPETSCares, YZL123, Granze Tech

(Exhibit 1)

OMNIBUS ORDER FOLLOWING HEARING ON DEFENDANTS' MOTIONS TO DISMISS [ECF NOS. 160, 163, 177], SEVERING CERTAIN DEFENDANTS, DISMISSING FIRST AMENDED COMPLAINT, AND DENYING PLAINTIFF'S MOTION FOR DEFAULT JUDGMENT [ECF NO. 210]. Denying 160 Motion to Dismiss for Lack of Jurisdiction; granting in part 163 Motion to Dismiss for Failure to State a Claim; granting in part 177 Motion to Sever; denying 210 Motion for Default Judgment. Parties Hiliop Reusable WB Direct, KYM MLSMYXGS, LIN&BABAY Direct, P&C-Direct, SHUHEYAN KSR, WHDPETSCares, YZL123, Zhangyueyuan, Furu Donghai and Granze Tech are severed from case. Case is Administratively Closed. Signed by Judge Melissa Damian on 5/27/2025. See attached document for full details.