2025-cv-60756

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18381124, filed by CRIMPIT GROUP LTD.

Exhibit 1 - Trademark Registrations

Exhibit 2 - Patent Registrations

(Civil Cover Sheet)

Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas. 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. (ar24)

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

Complaint

(Exhibit) (ar24)

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by CRIMPIT GROUP LTD.

Order

Plaintiff's MOTION to Seal Schedule A per Local Rule 5.4 by CRIMPIT GROUP LTD.

Text of Proposed Order Granting Motion to Seal

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT. Signed by Judge William P. Dimitrouleas on 4/22/2025. See attached document for full details. (ar24)

ORDER granting 6 Motion to File Under Seal. Signed by Judge William P. Dimitrouleas on 4/22/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 9 [order] restricted/sealed until further notice.

SYSTEM ENTRY - Docket Entry 10 [motion] restricted/sealed until further notice. (2195053)

SYSTEM ENTRY - Docket Entry 11 [misc] restricted/sealed until further notice. (2195053)

ORDER TO SHOW CAUSE FOR FAILURE TO COMPLY WITH RULE 4(M) OF THE FEDERAL RULES OF CIVIL PROCEDURE Show Cause Response due by 7/25/2025. Signed by Judge William P. Dimitrouleas on 7/18/2025. See attached document for full details. (ar24)

RESPONSE TO ORDER TO SHOW CAUSE re 12 Order to Show Cause, by CRIMPIT GROUP LTD.

SYSTEM ENTRY - Docket Entry 14 [order] restricted/sealed until further notice.

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 CRIMPIT GROUP LTD. Responses due by 8/21/2025.

Declaration of Leigh Salomon in support of Motion to Extend Temporary Restraining Order

(Text of Proposed Order in support of Motion to Extend Temporary Restraining Order)

NOTICE of Filing Proposed Summons(es) in Compliance with the Court's Sealed Order Granting Ex Parte Application for Entry of Temporary Restraining Order [DE 14] by CRIMPIT GROUP LTD.

(Proposed Summons)

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

ORDER Denying 15 Motion to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines. Signed by Judge William P. Dimitrouleas on 8/11/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendants Nos. 14 (Alison Electronic Commerce Co., Ltd.) and 60 (edenbenmoshe) by CRIMPIT GROUP LTD.

Text of Proposed Order Approving Voluntary Dismissal

ORDER APPROVING 19 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: Alison Electronic Commerce Co., Ltdand edenbenmoshe. Signed by Judge William P. Dimitrouleas on 8/13/2025. See attached document for full details.

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of JIAXIN Co.Ltd, QUANLONG Co.Ltd, SHUXUAN Co.Ltd, MOHAO Co.Ltd, XUEWU Co.Ltd, BAOBIN Co.Ltd. Attorney Andrew Jonathan Palmer added to party JIAXIN Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party QUANLONG Co.Ltd,(pty:dft), Attorney Andrew Jonathan Palmer added to party SHUXUAN Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party MOHAO Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party XUEWU Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party BAOBIN Co.Ltd(pty:dft).

STIPULATION TO EXTEND TIME TO FILE OPPOSITION TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION by BAOBIN Co.Ltd, JIAXIN Co.Ltd, MOHAO Co.Ltd, QUANLONG Co.Ltd, SHUXUAN Co.Ltd, XUEWU Co.Ltd

(Text of Proposed Order for JOINT STIPULATION TO EXTEND TIME FOR DEFENDANTS TO FILE OPPOSITION TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION)

ORDER granting [22] Stipulation to Extend Time for Defendants to file and serve their Opposition to Plaintiff's Motion for Preliminary Injunction filed by JIAXIN Co.Ltd, SHUXUAN Co.Ltd, QUANLONG Co.Ltd, MOHAO Co.Ltd, BAOBIN Co.Ltd, XUEWU Co.Ltd (Responses due by 8/18/2025., Replies due by 8/21/2025.) Signed by Judge William P. Dimitrouleas on 8/14/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendants Nos. 3 (3C Digital Tech Club Store Store), 4 (All satisfied Store), 5 (BESTOYARD LOLOVE Store), 6 (Bob D-I-Y Store), 7 (Digital&Game Killer Store), 8 (House Suncatcher Store), 9 (Shenzhen Moonlight Houseware Co., Ltd. Store), 10 (Shop1102988304 Store), 11 (Shop1104061206 Store), 12 (Starting Point -- Qin99 Store), and 13 (Xiao Dun Cleaning Store Store) by CRIMPIT GROUP LTD.

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): Dongguan Charm Star Houseware&Gift Co.,Ltd, Yichang Heartkey International Trade Co., Ltd., D Linjia, DIDIDADAA, GUANC QC, GutChoice, hanmadedian, heweitiyu, HKBHD, Huangshan Huizhou District Pingqiu Trading Co., Ltd., JieXing, joxipe--US, KaiRuiI, kunxianshangmao, Langfengxiangmaoyishanghang, Lgxshop, limingmingss, LingjingKongjian, lingxun shop, luyixianguanqingshangmaoyouxianzerengongsi, Mdsks, nanningshileerchengshangmao store, OFFEREAL Store, PRUDENCE01, Qankark, RubyDunes, sandakankeji, Senhaoguankeji, Song Changxin123, STDDBH, Tongliao Yunbo daily necessities firm, US Dawen Store, Wdengh, wufangjing, wuhanshifumengjiaobaihuoyouxiangongsi, WuRiHen, wuxiwalijidianshebeiyouxiangongsi, xiaofeixiazi, xiepode, yahsenn, yangheshangmaogongsi, Yangxiao miao, Yinanqiyu, yuexingshangmaoCo.Ltd., Zhangjiagang Jinyi Trading Co., Ltd., zhaozhengliangfseg, ZhuoZhongQiCheFuWu, elekto_markt, FASTSHIPPINGUSA, Fatbar, Herkastore, kadird-46, kandaig, keepup22, modernshop44, thevaluemaxmarket, winupdate, ZHENDUI, BAOBIN Co.Ltd, baoliqing, bnGAJN, Crystar, ONKER, GARENAS, GEHGWP, Ghislaine Direct, HONGE Co.Ltd, hongywl, HSGTRH, indepenlibr, JIAXIN Co.Ltd, JKLJNXA, langli69666, ljghsam, lunaluna, MGEHAP, MOHAO Co.Ltd, Nehiwhazk, Nutedom, OUHGE, QUANLONG Co.Ltd, Shenzhenshi Juxiaomi dianzishangwu youxiangongsi, SHUXUAN Co.Ltd, TJJMKIJSHUGDS, UsQueen, Wealth Co.Ltd, XUEWU Co.Ltd, yanwan and Zcmowue.

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by CRIMPIT GROUP LTD. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 8/11/2025, response/answer due 9/2/2025.

ORDER APPROVING 24 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: BESTOYARD LOLOVE Store, Bob D-I-Y Store, Digital&Game Killer Store, House Suncatcher Store, Shenzhen Moonlight Houseware co. Ltd. Store, Shop1102988304 Store, Shop1104061206 Store, Starting Point -- Qin99 Store, Xiao Dun Cleaning Store Store, 3C Digital Tech Club Store Store and All satisfied Store. Signed by Judge William P. Dimitrouleas on 8/18/2025. See attached document for full details.

RESPONSE in Opposition to Plaintiff's Motion for Entry of Preliminary Injunction 10 by BAOBIN Co.Ltd, JIAXIN Co.Ltd, MOHAO Co.Ltd, QUANLONG Co.Ltd, SHUXUAN Co.Ltd, XUEWU Co.Ltd.

Exhibit Ex. 1 - Infringing Evidence Provided by Plaintiff

Exhibit Ex. 2 - Declaration by SU in support of Defendant's opposition to preliminary injunction

Exhibit Ex. 3 - Declaration by MO in support of Defendant's opposition to preliminary injunction

Exhibit Ex. 4 - Declaration by LIN in support of Defendant's opposition to preliminary injunction

Exhibit Ex. 5 - Declaration by DU in support of Defendant's opposition to preliminary injunction

Exhibit Ex. 6 - Declaration by QI in support of Defendant's opposition to preliminary injunction

(Exhibit Ex. 7 - Declaration by FANG in support of Defendant's opposition to preliminary injunction)

Clerks Receipt for deposit into the registry of the court (DE#14) received on 8/20/2025 in the amount of $ 100,000.00, receipt number FLS306801 by Crimpit Group LTD.

NOTICE of Posting Bond by CRIMPIT GROUP LTD.

NOTICE of Settlement by BAOBIN Co.Ltd, JIAXIN Co.Ltd, MOHAO Co.Ltd, QUANLONG Co.Ltd, SHUXUAN Co.Ltd, XUEWU Co.Ltd

NOTICE TO WITHDRAW Defendants' Opposition to Plaintiff's Motion for Entry of a Preliminary Injunction filed on August 19, 2025 28 by BAOBIN Co.Ltd, JIAXIN Co.Ltd, MOHAO Co.Ltd, QUANLONG Co.Ltd, SHUXUAN Co.Ltd, XUEWU Co.Ltd Modified Text on 8/21/2025

NOTICE of Voluntary Dismissal of Defendants Nos. 72 (BAOBIN Co.Ltd), 84 (JIAXIN Co.Ltd), 90 (MOHAO Co.Ltd), 94 (QUANLONG Co.Ltd), 96 (SHUXUAN Co.Ltd), and 100 (XUEWU Co.Ltd) by CRIMPIT GROUP LTD.

Plaintiff's NOTICE of Filing Proposed Order Approving Plaintiff's Voluntary Dismissal by CRIMPIT GROUP LTD. re 33 Notice of Voluntary Dismissal

(Proposed Order Approving Voluntary Dismissal)

Plaintiff's NOTICE of Filing Proposed Order Granting Plaintiff's Motion for Preliminary Injunction by CRIMPIT GROUP LTD.

(Proposed Order Granting Plaintiff's Motion for Preliminary Injunction)

ORDER APPROVING 33 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: JIAXIN Co.Ltd, MOHAO Co.Ltd, QUANLONG Co.Ltd, SHUXUAN Co.Ltd, XUEWU Co.Ltd, BAOBIN Co.Ltd. Signed by Judge William P. Dimitrouleas on 8/22/2025. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 8/22/2025 re 10 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery filed by CRIMPIT GROUP LTD. No Defendants appeared. The Court will enter an Order Granting Plaintiff's Motion for Preliminary Injunction. Total time in court: 5 minutes. Attorney Appearance(s): Leigh Benjamin Salomon, Court Reporter: Patricia Bailey-Entin, 305-523-5631 / Patricia_BaileyEntin@flsd.uscourts.gov.

ORDER GRANTING PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION, granting 10 Ex Parte Motion for Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery. The Clerk is DIRECTED to UNSEAL all sealed docket entries in this case. Signed by Judge William P. Dimitrouleas on 8/22/2025. See attached document for full details.

Clerk's NOTICE of Compliance re 38 Order on Motion for Preliminary Injunction: All Docket Entries Unsealed.

NOTICE of Voluntary Dismissal of Defendants Nos. 33 (Mdsks), 98 (UsQueen), and 99 (Wealth Co.Ltd) by CRIMPIT GROUP LTD.

(Text of Proposed Order Approving Voluntary Dismissal)

ORDER APPROVING VOLUNTARY DISMISSAL: re 40 Notice of Voluntary Dismissal. This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: Doe No 33. Mdsks, Doe No. 98 UsQueen and Do No. 99 Wealth Co. Ltd. Signed by Judge William P. Dimitrouleas on 8/25/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendants Nos. 56 (yuexingshangmaoCo.Ltd.), 58 (zhaozhengliangfseg), and 63 (Fatbar) by CRIMPIT GROUP LTD.

(Proposed Order Approving Voluntary Dismissal of Defendants Nos. 56 (yuexingshangmaoCo.Ltd.), 58 (zhaozhengliangfseg), and 63 (Fatbar))

ORDER APPROVING 42 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: zhaozhengliangfseg, Fatbar and yuexingshangmaoCo.Ltd. Signed by Judge William P. Dimitrouleas on 8/28/2025. See attached document for full details.

ORDER To Show Cause Why Sanctions Should Not Be Imposed For Using Rule 41(A)(1) To Engage In Impermissible Judge-Shopping. Show Cause Response due by 9/18/2025. Signed by Judge William P. Dimitrouleas on 9/8/2025. See attached document for full details.

RESPONSE TO ORDER TO SHOW CAUSE re 44 Order to Show Cause, by CRIMPIT GROUP LTD.

MOTION for Extension of Time to Respond to the Complaint (Out of Time) Pursuant to Fed. R. Civ P. 6(b)(1)(B), and Incorporated Memorandum of Lase re 1 Complaint, by thevaluemaxmarket.

ANSWER and Affirmative Defenses to Complaint by thevaluemaxmarket.

Emergency MOTION to File by Email (Fed. R. Civ. P. 5(d)(3)(B)) and Permit Service/Notice by Email on Plaintiff's Counsel by thevaluemaxmarket.

Emergency MOTION to Modify Preliminary Injunction (Asset Restraint) to Cap the Freeze at $2,000 and Release All Excess Funds by thevaluemaxmarket.

Notice of Pro Se Appearance, Contact Information, and Consent to Email Service by thevaluemaxmarket at email address: elouk2251@gmail.com

Certificate of Other Affiliates/Corporate Disclosure Statement by thevaluemaxmarket identifying Other Affiliate eBay Inc., Other Affiliate Omer Eladi for thevaluemaxmarket (pcs) Modified on 9/17/2025

ORDER SETTING HEARING ON THE MATTER OF WHETHER SANCTIONS SHOULD BE IMPOSED FOR USING RULE 41(A)(1) TO ENGAGE IN IMPERMISSIBLE JUDGE-SHOPPING Show Cause Hearing set for 9/23/2025 10:30 AM in Fort Lauderdale Division before Judge William P. Dimitrouleas. Signed by Judge William P. Dimitrouleas on 9/18/2025. See attached document for full details.

OMNIBUS ORDER granting 46 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document thevaluemaxmarket. Response/Answer due 10/15/2025 ; granting in part and denying in part 48 Motion for Leave to File by Email (Fed. R. Civ. P. 5(d)(3)(B) and to Permit Service/Notice by Email on Plaintiff's Counsel, requiring expedited response to 49 Defendant Omer Elaldi d/b/a "thevalumaxmarket"'s Emergency Motion to Modify Preliminary Injuction (Asset Restraint) to Cap the Freeze at $2,000 and Release All Excess Funds(Responses due by 9/23/2025). Signed by Judge William P. Dimitrouleas on 9/19/2025. See attached document for full details.

Clerk's NOTICE of Compliance re 53 Omnibus Order: Email added to Defendant Omer Elaldi d/b/a "thevalumaxmarket", Order emailed to Defendant.

NOTICE of Settlement with Defendant No. 69 (thevaluemaxmarket) by CRIMPIT GROUP LTD.

NOTICE of Attorney Appearance by Marshall Dore Louis on behalf of CRIMPIT GROUP LTD. Attorney Marshall Dore Louis added to party CRIMPIT GROUP LTD.(pty:pla).

ORDER ON 55 JOINT NOTICE OF SETTLEMENT: Defendant Omer Elaldi d/b/a "thevalumaxmarket"'s Emergency Motion to Modify Preliminary Injuction (Asset Restraint) to Cap the Freeze at $2,000 and Release All Excess Funds [DE 49 ] is DENIED AS MOOT. Plaintiff Crimpit Group Ltd. shall file a Notice of Voluntary Dismissal as to Defendant Omer Elaldi d/b/a "thevalumaxmarket" on or before October 2, 2025. Signed by Judge William P. Dimitrouleas on 9/23/2025. See attached document for full details.

SANCTIONS FOR USING RULE 41(A)(1) TO ENGAGE IN IMPERMISSIBLE JUDGE-SHOPPING: The Court accepts Solomon's self-imposed sanctions and adopts them. [DE- 45, & 5(a-d)]. Additionally, Solomon is sanctioned a fine of $1,000 and must submit proof of payment to the Clerk's office by September 30, 2025. Upon receipt of this Order, Plaintiff and its counsel shall provide a copy of this Order to all 102 Defendants in this case and file a Notice of Compliance in the record stating the date and manner of service. Signed by Judge William P. Dimitrouleas on 9/23/2025. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Show Cause Hearing held on 9/23/2025. Hearing held, order to follow with court's ruling. Total time in court: 15 minutes. Attorney Appearance(s): Marshall Dore Louis, Leigh Benjamin Salomon, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

Notice of Pending, Refiled, Related or Similar Actions by CRIMPIT GROUP LTD.

NOTICE of Compliance by CRIMPIT GROUP LTD. re [58] Order

NOTICE OF WITHDRAWAL OF PRO SE FILINGS by thevaluemaxmarket.

Clerks Receipt for court sanctioned fine (DE#58) received on 9/25/2025 in the amount of $ 1,000.00, receipt number FLS308225 by Leigh Benjamin Salomon.

NOTICE of Voluntary Dismissal of Defendants Nos. 15 (D Linjia), 69 (thevaluemaxmarket), and 92 (Nutedom) by CRIMPIT GROUP LTD.

(Proposed Order Approving Voluntary Dismissal)

ORDER APPROVING 64 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: D Linjia, thevaluemaxmarket, Nutedom. Signed by Judge William P. Dimitrouleas on 9/26/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendants Nos. 39 (sandakankeji) and 79 (Ghislaine Direct) by CRIMPIT GROUP LTD.

(Proposed Order Approving Voluntary Dismissal)

ORDER APPROVING 66 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: DOE No. 39, sandakankeji and DOE No. 79, Ghislaine Direct Signed by Judge William P. Dimitrouleas on 9/29/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendants Nos. 61 (elekto_markt), 64 (Herkastore), 67 (keepup22), and 70 (winupdate) by CRIMPIT GROUP LTD.

(Proposed Order Approving Voluntary Dismissal)

ORDER APPROVING 68 VOLUNTARY DISMISSAL: This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants: keepup22, winupdate, Herkastore and elekto_markt. Signed by Judge William P. Dimitrouleas on 10/1/2025. See attached document for full details.