2025-cv-60239

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18193335, filed by Purple Innovation, LLC.

Exhibit 1

Exhibit 2

(Civil Cover Sheet)

Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jared M. Strauss 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.

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

(Complaint) (ksr)

NOTICE OF COURT PRACTICE Unless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes. Multiple Plaintiffs or Defendants shall file joint motions (and responses to motions) with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions (and responses). Motions for Extension of Time Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Labeling Exhibits on CM/ECF Exhibits to pleadings and motions shall be docketed in accordance with the Court's CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket Entry A party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Notices of Settlement Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings. Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 2/12/2025.

Within SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 2/12/2025.

Plaintiff's AMENDED COMPLAINT against The Individual, Corporation, Limited Liability Company, Partnership, and/or Unincorporated Association Identified on Schedule A, filed by Purple Innovation, LLC.

Exhibit 1 - Trademarks

Exhibit 2 - Patents

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

Order

Order

Order

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

Text of Proposed Order to Seal

ORDER granting 9 Motion To file under Seal. Signed by Judge Raag Singhal on 2/18/2025. See attached document for full details.

Summons Issued as to The Individual, Corporation, Limited Liability Company, Partnership, and/or Unincorporated Association Identified on Schedule A.

Clerks Receipt for bond posted per order of the court (DE#14) received on 3/11/2025 in the amount of $ 5,000.00, receipt number FLS299785.

SUMMONS (Affidavit) Returned Executed on [6] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Purple Innovation, LLC. The Individual, Corporation, Limited Liability Company, Partnership, and/or Unincorporated Association Identified on Schedule A served on 3/5/2025, response/answer due 3/26/2025.

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): qinxingdedian.

Cash BOND in the amount of $5,000.00 receipt # 299785 posted by Purple Innovation, LLC Approved by Judge Raag Singhal

Bond Receipt

PAPERLESS Minute Entry for proceedings held before Judge Raag Singhal: Preliminary Injunction Hearing held on 3/12/2025. Attorney Appearance(s): Leigh Benjamin Salomon, Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

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

Text of Proposed Order Granting Plaintiff's Motion for Preliminary Injuncti

ORDER GRANTING PRELIMINARY INJUNCTION: The CLERK is DIRECTED to unseal Plaintiff's Schedule A to the Complaint, Exhibit 3 to the Declaration of James Larson, and the Sealed Temporary Restraining Order entered in this action. Signed by Judge Raag Singhal on 4/15/2025. See attached document for full details.

ORDER TO SHOW CAUSE Show Cause Response due by 4/25/2025. Signed by Judge Raag Singhal on 4/15/2025. See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to The Individual, Corporation, Limited Liability Company, Partnership, and/or Unincorporated Association Identified on Schedule A by Purple Innovation, LLC.

Declaration of Leigh Salomon

Clerk's Entry of Default as to qinxingdedian Signed by DEPUTY CLERK on 4/22/2025.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE, (Motions due by 5/22/2025.) Signed by Judge Raag Singhal on 4/22/2025. See attached document for full details.

RESPONSE TO ORDER TO SHOW CAUSE re [23] Order to Show Cause by Purple Innovation, LLC.

ORDER re to unseal all docket entries in this case. Signed by Judge Raag Singhal on 4/24/2025. See attached document for full details.

CLERK'S NOTICE of Compliance (ALL Docket Entries in this Case have been Unsealed) re [28] Order

Plaintiff's MOTION for Default Judgment by Purple Innovation, LLC.

Declaration of Leigh Salomon

Exhibit 1 - Defendant Evidence

Exhibit 2 - Lost Profits

Text of Proposed Order on Motion for Entry of Final Default Judgment

(Text of Proposed Final Default Judgment and Permanent Injunction)

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