2025-cv-60807

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18400996, filed by Purple Innovation, LLC.

Exhibit 1 - Trademarks

Exhibit 2 - Patents

(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.

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

(Complaint) (blc)

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

SYSTEM ENTRY - Docket Entry 5 [motion] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

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

(Text of Proposed Order)

Order Requiring Joint Scheduling Report. Signed by Judge William P. Dimitrouleas on 4/29/2025. See attached document for full details.

ORDER granting 6 Motion to File Under Seal. Signed by Judge William P. Dimitrouleas on 4/29/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 9 [order] restricted/sealed until further notice. (Text entry; no document attached.)

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

SYSTEM ENTRY - Docket Entry 11 [misc] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

(Text of Proposed Order)

ORDER granting 10 Motion for Leave to File Excess Pages. Signed by Judge William P. Dimitrouleas on 5/1/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 13 [motion] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 14 [order] restricted/sealed until further notice. (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 6/6/2025.

Declaration of Leigh Salomon

(Text of Proposed Order)

ORDER granting 15 Motion for Extension of Time. Responses due by 6/25/2025. Replies due by 6/26/2025. Prelinjhrg Hearing set for 6/27/2025 01:40 PM before Judge William P. Dimitrouleas. Signed by Judge William P. Dimitrouleas on 5/27/2025. See attached document for full details.

MOTION to Dissolve Preliminary Injunction and Request for Electronic Access to Future Proceedings by Moran Feliba.

NOTICE of Attorney Appearance by Zhen Pan on behalf of Airllantry US, Inreak, KYSMOTIC-US. Attorney Zhen Pan added to party Airllantry US(pty:dft), Attorney Zhen Pan added to party Inreak(pty:dft), Attorney Zhen Pan added to party KYSMOTIC-US(pty:dft).

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Qianwu Yang. Filing Fee $ 250.00 Receipt # AFLSDC-18502039 by Airllantry US, Inreak, KYSMOTIC-US. Responses due by 6/17/2025.

Exhibit Certification of Qianwu Yang

(Exhibit Proposed Order Granting Motion to Appear Pro Hac Vice)

NOTICE of Voluntary Dismissal of Defendant Nos. 17 (Airllantry US), 32 (Inreak), and 35 (KYSMOTIC-US) by Purple Innovation, LLC

Order of Dismissal as to Certain Defendants Only Approving 20 Notice of Voluntary Dismissal; Dismissing Claims against Defendants KYSMOTIC-US, Airllantry US and Inreak without prejudice. Signed by Judge William P. Dimitrouleas on 6/4/2025. See attached document for full details.

ORDER REFERRING 17 MOTION to Dissolve Preliminary Injunction and Request for Electronic Access to Future Proceedings. Motions referred to Judge Patrick M. Hunt. Signed by Judge William P. Dimitrouleas on 6/6/2025. See attached document for full details.

CLERK'S NOTICE of Compliance re 22 Order Referring Motion.

ORDER granting 19 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney(s) Qianwu Yang. Signed by Judge William P. Dimitrouleas on 6/4/2025. See attached document for full details.

Clerks Receipt for deposit into the registry (Bond) per sealed order (DE#14) received on 6/5/2025 in the amount of $ 100,000.00, receipt number FLS303445.

NOTICE OF WITHDRAWAL OF MOTIONS by netanelkim32, Rotem1, Moran Feliba re 17 MOTION to Dissolve Preliminary Injunction and Request for Electronic Access to Future Proceedings filed by Moran Feliba

NOTICE OF POSTING BOND in the amount of $100,000.00 receipt # 303445 posted by Purple Innovation, LLC Approved by Judge William P. Dimitrouleas

NOTICE of Voluntary Dismissal of Defendant Nos. 1 (Nantong Super Sleep Textile Co.,ltd), 71 (around_photo_sound), 106 (Heritage Harbor Market), 136 (netanelkim32), 152 (rotem1), and 173 (Vintage Charm Find) by Purple Innovation, LLC

ORDER OF DISMISSAL AS TO CERTAIN DEFENDANTS ONLY, dismissing Defendants Nos. 1 (Nantong Super Sleep Textile Co.,ltd), 71 (around_photo_sound), 106 (Heritage Harbor Market), 136 (netanelkim32), 152 (rotem1), and 173 (Vintage Charm Find) Signed by Judge William P. Dimitrouleas on 6/6/2025. See attached document for full details.

NOTICE of Attorney Appearance by Jianyin Liu on behalf of GYDZSW. Attorney Jianyin Liu added to party GYDZSW(pty:dft).

NOTICE of Voluntary Dismissal of Defendants Nos. 207 (HANJIE Co.Ltd), 214 (JINWU Co.Ltd), 216 (JUNJIE Co.Ltd), 217 (JUNPI Co.Ltd), 225 (MINGKU Co.Ltd), 235 (SHENGQINGCo.Ltd), 236 (SHENWO Co.Ltd), 237 (SHUJIN Co.Ltd), 238 (SHUYING Co.Ltd), 249 (WEILANGCo.Ltd), 255 (YINQI Co.Ltd), and 257 (YUNLI Co.Ltd) by Purple Innovation, LLC

NOTICE of Attorney Appearance by Jianyin Liu on behalf of Auvivasital-US, Wiesumirt-US. Attorney Jianyin Liu added to party Auvivasital-US(pty:dft), Attorney Jianyin Liu added to party Wiesumirt-US(pty:dft).

ORDER APPROVING VOLUNTARY DISMISSAL re 31 Notice of Voluntary Dismissal. HANJIE Co.Ltd, JINWU Co.Ltd, JUNJIE Co.Ltd, MINGKU Co.Ltd, SHENGQINGCo.Ltd, SHENWO Co.Ltd, SHUJIN Co.Ltd, SHUYING Co.Ltd, WEILANGCo.Ltd, YINQI Co.Ltd, YUNLI Co.Ltd. Signed by Judge William P. Dimitrouleas on 6/16/2025. See attached document for full details.

MOTION for Telephonic or Video Appearance at Hearing by Tonos LLC. Responses due by 6/30/2025.

RESPONSE in Opposition re 17 MOTION to Dissolve Preliminary Injunction and Request for Electronic Access to Future Proceedings filed by Tonos LLC. Replies due by 6/24/2025.

NOTICE of Attorney Appearance by Zhen Pan on behalf of BREENHILL US. Attorney Zhen Pan added to party BREENHILL US(pty:dft).

NOTICE of Attorney Appearance by Zhen Pan on behalf of BREENHILL US

NOTICE of Attorney Appearance Pro Hac Vice for Additional Party Representation(s) for BREENHILL US. All information provided in support of the initial 19 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Qianwu Yang. Filing Fee $ 250.00 Receipt # AFLSDC-18502039 remains current and correct, including the sponsoring co-counsel.

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

(Summon(s))

NOTICE of Voluntary Dismissal of Defendant No. 19 (BREENHILL US) by Purple Innovation, LLC

CLERK'S NOTICE - PHV Attorney Qianwu Yang has been added to this case for party BREENHILL US re [38] Notice of Appearance Pro Hac Vice for Additional Party Representation

Order Approving [40] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendant BREENHILL US. Signed by Judge William P. Dimitrouleas on 6/23/2025. See attached document for full details.

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

ORDER denying without prejudice [35] Motion for Telephonic or Video Appearance at Hearing. Deadline to obtain new counsel 6/30/2025. Signed by Judge William P. Dimitrouleas on 6/23/2025. See attached document for full details.

CLERK'S NOTICE of Compliance re [44] Order on Motion for Leave to Appear.

NOTICE of Attorney Appearance by Zhen Pan on behalf of Tonos LLC. Attorney Zhen Pan added to party Tonos LLC(pty:dft).

NOTICE of Attorney Appearance Pro Hac Vice for Additional Party Representation(s) for Tonos LLC. All information provided in support of the initial [19] MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Qianwu Yang. Filing Fee $ 250.00 Receipt # AFLSDC-18502039 remains current and correct, including the sponsoring co-counsel.

RESPONSE in Opposition re [15] 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 Auvivasital-US, Wiesumirt-US. Replies due by 7/1/2025.

Exhibit A- Accused Product 1

Exhibit B- Accused Product 2

Exhibit C- Accused Product 3

Exhibit D- Accused Product 4

Exhibit E- Accused Product 5

Exhibit F- Prior Art `512 Patent

Exhibit G- Prior Art `977 Patent

CLERK'S NOTICE - PHV Attorney Qianwu Yang has been added to this case for party Tonos LLC re [47] Notice of Appearance Pro Hac Vice for Additional Party Representation

ORDER Requiring Plaintiff's Notice Listing Remaining Defendants and those Defendants Voluntarily Dismissed. Signed by Judge William P. Dimitrouleas on 6/25/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 54 (TONOS LLC), 94 (drbashi), 97 (ElyaGStore), 99 (Factory*Sales*Store), 123 (lamboone), 127 (lior26122008), 135 (NetBest), 138 (NO1.Mark), 140 (ofer26883), 151 (ronenmaman), 153 (sagib-6893), 158 (shlomisolomon), 162 (StoreITOne), 163 (sunshine-worldfactory), 174 (wholeale2022store), and 180 (yovelxl5363) by Purple Innovation, LLC

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): All-in-One Store, amabilis Store, Besito Franchise Store, BMAD Lighting Store, BWL Perfect Home Store, NorthPeak Life Store, Ping An Car Store, Shop1102982768 Store, Shop1103102358 Store, Shop1103838114 Store, SHUN YI TONG Store, superwind car Store, Vacclo666 Store, Worldmuma Store, Zhanglin Shop11 Store, Auvivasital-US, brother-home, CEECOLES, chengshangqixia, chenyuefabaihuo, CLLXDZ, Direct technology inc., famangmang, GuangFengQuHanHanBaiHuoDian, GYDZSW, H HOKIZU, HFDAMAI, Hongfan reputation shop, Janko, kunmingxiongkuoshangmaoyouxiangongsi, Latolinon US, light the stars, Ludovico, LUJAO, lyongt206, Maiku-US, MENGMENGXIAODIAN, Ommya, pinpinshop, poyangxianzhenqinjiubaihuodian11, PrimePick GS, QDWJD, qigelongdongqiang, REMEDIC, SANHEKEJI, shenmiaoamz, TaiYuanShiHaoShangMao, THRoyal, TWINKLES-AU, TWOCEUS, wangbingamzaa, WENXUEDEXIAODIAN, Wiesumirt-US, xiaodoushipindian, Xiaohanshangmao, yisen shop, ZYSMY-US, beauty_of_ting1, agri_82, akashpramu_2005, ak-super-mart, almog_store10, alvpil0, Amirg, AS MY, AsDDuf, asgar6_46, Automotive*Motorcycle*Shop, AVECHJAPAN, avigdor_Store34, ayse-new, baqdur, barak_store33, BDStore4U, beery_14, besty_liveayy, brightfai1990, charlyebooy, chasna_77, chuichui, cozy_home09, CUSTOMER SERVICETOP, Daniel_Elazar, deckoc, DirectDeals2023, dovydajaksta0, drorb, eldad_100, Everyday Picks, fecomp1, gbproducts_1719, glow.m43, gokhan0101, haim_shop09, hakara3905, Home*Gardon*Store, HundredPercentStore, ibrari-66, idanpin19, IEB's Store, imat-4325, inter-links, jaja's store, Jake's toy store, jarreyj40, jawad_2, johnmarketing35, jolie346, jorgecar-0, KamsssStore, kangaroos_shipping, ldliao321_shop, L'EMPOROP DEGLI SCONTI, lidors57, malkiel_Store321, Matanelli, mr.japan2021, muhaim-9476, na-871349, naler61, NeilasasSTORE, nir_store45, Nuwinen, pesachye0, pgu2012, pitaya520, pstiang, Pudding_Toys, purevaluestore, Raanana700, ralyn-77, ran-chen, ranotlior.08, salih, SampathSara, sams_store_1, shimshon_store45, SHRTEH, shturya, store_sell101, tamir_shop332, the_great_useful_things, theparts-garage, Thunder Penguin, Tour De Tools Tokyo, tousha-14, uisuiqu, ukaju-0, VARIEDITEMS STORE, World Gift Store, yaakovitzhakbiderman1, yasirulak2001-store, yehudan33, ymop3988, zen-zen7, Art, Just buy Fashion, Quanjiaxi Flagship Store, Verona Morris, Aoshet, Aoshet Warehouse, CORATED local, FlumyUS, ILLUSORY mall, Kiourp, Nancyl local, OUBAN, SLLAK local, Afoxsos, Caiboxing, Cailine Legend, Canelx, CAOCHENG, Deng rui Store, DingDing Shop, Dyang store, foshanshilishuangdushangmao, Guangxibianchuikuajingdianzishangwuyouxiangongsi, guangzhouhuanmeichuanmei, guangzhoujunxinganjiefuwuyouxiangongsi, Hanyge, Happylifeyou, hou ying wei Home Store, JADI, Jianhua Commercial Bank, JIAOCHU, Joystore, KEZHAO Co.Ltd, kft mall, KINGMAZI, Lingti Trading Co., Ltd, linlei, linxiaohao, LOXOMU, Mr.K, Myzhe, Nanjingkangchen Tech Co. Ltd, Needhep, ONFSLX, QmeDNh, QuLuJing, shaoshanshizicong, shenglixiaopu, Shuzhi Small Shop, Siqiy, StrataSph, sunhongshe666, TENGHEJIA, TrendTide, Triani, uepaijia, wangdandankj Co.ltd, wanghaihui, XH Studio Design, xisoushangmao, xiugourong99, Yajuhoy, yangxiaoqiang, YouyouEngin, zhaidingshangmao and zhengyizhi.

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 6/23/2025, response/answer due 7/14/2025.

Plaintiff's MOTION to Unseal Document by Purple Innovation, LLC. Responses due by 7/10/2025.

Text of Proposed Order

NOTICE of Attorney Appearance by Jianyin Liu on behalf of Ludovico, brother-home. Attorney Jianyin Liu added to party Ludovico(pty:dft), Attorney Jianyin Liu added to party brother-home(pty:dft).

Clerk's Notice to Filer re [53] Summons Returned Executed. Parties Not Selected; ERROR - The Filer failed to select all parties served from the Proof of Service. Filer is instructed to refile the document and select all Parties Listed as Served.

NOTICE of Withdrawal of Response to Motion for Preliminary Injunction [DE 48] by Auvivasital-US, Wiesumirt-US re [48] Response in Opposition to Motion. Attorney Jianyin Liu added to party Auvivasital-US(pty:dft), Attorney Jianyin Liu added to party Wiesumirt-US(pty:dft).

NOTICE of Voluntary Dismissal of Defendant Nos. 18 (Auvivasital-US), 24 (CLLXDZ), 28 (GYDZSW), 50 (SANHEKEJI), and 59 (Wiesumirt-US) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant Nos. 20 (brother-home) and 38 (Ludovico) by Purple Innovation, LLC

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. AS MY served on 6/23/2025, response/answer due 7/14/2025; AVECHJAPAN served on 6/23/2025, response/answer due 7/14/2025; Afoxsos served on 6/23/2025, response/answer due 7/14/2025; All-in-One Store served on 6/23/2025, response/answer due 7/14/2025; Amirg served on 6/23/2025, response/answer due 7/14/2025; Aoshet served on 6/23/2025, response/answer due 7/14/2025; Aoshet Warehouse served on 6/23/2025, response/answer due 7/14/2025; Art served on 6/23/2025, response/answer due 7/14/2025; AsDDuf served on 6/23/2025, response/answer due 7/14/2025; Auvivasital-US served on 6/23/2025, response/answer due 7/14/2025; BDStore4U served on 6/23/2025, response/answer due 7/14/2025; BMAD Lighting Store served on 6/23/2025, response/answer due 7/14/2025; BWL Perfect Home Store served on 6/23/2025, response/answer due 7/14/2025; Besito Franchise Store served on 6/23/2025, response/answer due 7/14/2025; CAOCHENG served on 6/23/2025, response/answer due 7/14/2025; CEECOLES served on 6/23/2025, response/answer due 7/14/2025; CLLXDZ served on 6/23/2025, response/answer due 7/14/2025; CORATED local served on 6/23/2025, response/answer due 7/14/2025; CUSTOMER SERVICETOP served on 6/23/2025, response/answer due 7/14/2025; Caiboxing served on 6/23/2025, response/answer due 7/14/2025; Cailine Legend served on 6/23/2025, response/answer due 7/14/2025; Canelx served on 6/23/2025, response/answer due 7/14/2025; Daniel_Elazar served on 6/23/2025, response/answer due 7/14/2025; Deng rui Store served on 6/23/2025, response/answer due 7/14/2025; DingDing Shop served on 6/23/2025, response/answer due 7/14/2025; Direct technology inc. served on 6/23/2025, response/answer due 7/14/2025; DirectDeals2023 served on 6/23/2025, response/answer due 7/14/2025; Dyang store served on 6/23/2025, response/answer due 7/14/2025; Everyday Picks served on 6/23/2025, response/answer due 7/14/2025; FlumyUS served on 6/23/2025, response/answer due 7/14/2025; GYDZSW served on 6/23/2025, response/answer due 7/14/2025; GuangFengQuHanHanBaiHuoDian served on 6/23/2025, response/answer due 7/14/2025; Guangxibianchuikuajingdianzishangwuyouxiangongsi served on 6/23/2025, response/answer due 7/14/2025; H HOKIZU served on 6/23/2025, response/answer due 7/14/2025; HFDAMAI served on 6/23/2025, response/answer due 7/14/2025; Hanyge served on 6/23/2025, response/answer due 7/14/2025; Happylifeyou served on 6/23/2025, response/answer due 7/14/2025; Hongfan reputation shop served on 6/23/2025, response/answer due 7/14/2025; HundredPercentStore served on 6/23/2025, response/answer due 7/14/2025; IEB's Store served on 6/23/2025, response/answer due 7/14/2025; ILLUSORY mall served on 6/23/2025, response/answer due 7/14/2025; JADI served on 6/23/2025, response/answer due 7/14/2025; JIAOCHU served on 6/23/2025, response/answer due 7/14/2025; Jake's toy store served on 6/23/2025, response/answer due 7/14/2025; Janko served on 6/23/2025, response/answer due 7/14/2025; Jianhua Commercial Bank served on 6/23/2025, response/answer due 7/14/2025; Joystore served on 6/23/2025, response/answer due 7/14/2025; Just buy Fashion served on 6/23/2025, response/answer due 7/14/2025; KEZHAO Co.Ltd served on 6/23/2025, response/answer due 7/14/2025; KINGMAZI served on 6/23/2025, response/answer due 7/14/2025; KamsssStore served on 6/23/2025, response/answer due 7/14/2025; Kiourp served on 6/23/2025, response/answer due 7/14/2025; L'EMPOROP DEGLI SCONTI served on 6/23/2025, response/answer due 7/14/2025; LOXOMU served on 6/23/2025, response/answer due 7/14/2025; LUJAO served on 6/23/2025, response/answer due 7/14/2025; Latolinon US served on 6/23/2025, response/answer due 7/14/2025; Lingti Trading Co., Ltd served on 6/23/2025, response/answer due 7/14/2025; Ludovico served on 6/23/2025, response/answer due 7/14/2025; MENGMENGXIAODIAN served on 6/23/2025, response/answer due 7/14/2025; Maiku-US served on 6/23/2025, response/answer due 7/14/2025; Matanelli served on 6/23/2025, response/answer due 7/14/2025; Mr.K served on 6/23/2025, response/answer due 7/14/2025; Myzhe served on 6/23/2025, response/answer due 7/14/2025; Nancyl local served on 6/23/2025, response/answer due 7/14/2025; Nanjingkangchen Tech Co. Ltd served on 6/23/2025, response/answer due 7/14/2025; Needhep served on 6/23/2025, response/answer due 7/14/2025; NorthPeak Life Store served on 6/23/2025, response/answer due 7/14/2025; Nuwinen served on 6/23/2025, response/answer due 7/14/2025; ONFSLX served on 6/23/2025, response/answer due 7/14/2025; OUBAN served on 6/23/2025, response/answer due 7/14/2025; Ommya served on 6/23/2025, response/answer due 7/14/2025; Ping An Car Store served on 6/23/2025, response/answer due 7/14/2025; PrimePick GS served on 6/23/2025, response/answer due 7/14/2025; Pudding_Toys served on 6/23/2025, response/answer due 7/14/2025; QDWJD served on 6/23/2025, response/answer due 7/14/2025; QmeDNh served on 6/23/2025, response/answer due 7/14/2025; QuLuJing served on 6/23/2025, response/answer due 7/14/2025; Quanjiaxi Flagship Store served on 6/23/2025, response/answer due 7/14/2025; REMEDIC served on 6/23/2025, response/answer due 7/14/2025; Raanana700 served on 6/23/2025, response/answer due 7/14/2025; SANHEKEJI served on 6/23/2025, response/answer due 7/14/2025; SHRTEH served on 6/23/2025, response/answer due 7/14/2025; SHUN YI TONG Store served on 6/23/2025, response/answer due 7/14/2025; SLLAK local served on 6/23/2025, response/answer due 7/14/2025; SampathSara served on 6/23/2025, response/answer due 7/14/2025; Shop1102982768 Store served on 6/23/2025, response/answer due 7/14/2025; Shop1103102358 Store served on 6/23/2025, response/answer due 7/14/2025; Shop1103838114 Store served on 6/23/2025, response/answer due 7/14/2025; Shuzhi Small Shop served on 6/23/2025, response/answer due 7/14/2025; Siqiy served on 6/23/2025, response/answer due 7/14/2025; StrataSph served on 6/23/2025, response/answer due 7/14/2025; TENGHEJIA served on 6/23/2025, response/answer due 7/14/2025; THRoyal served on 6/23/2025, response/answer due 7/14/2025; TWINKLES-AU served on 6/23/2025, response/answer due 7/14/2025; TWOCEUS served on 6/23/2025, response/answer due 7/14/2025; TaiYuanShiHaoShangMao served on 6/23/2025, response/answer due 7/14/2025; Thunder Penguin served on 6/23/2025, response/answer due 7/14/2025; Tonos LLC served on 6/23/2025, response/answer due 7/14/2025; Tour De Tools Tokyo served on 6/23/2025, response/answer due 7/14/2025; TrendTide served on 6/23/2025, response/answer due 7/14/2025; Triani served on 6/23/2025, response/answer due 7/14/2025; VARIEDITEMS STORE served on 6/23/2025, response/answer due 7/14/2025; Vacclo666 Store served on 6/23/2025, response/answer due 7/14/2025; Verona Morris served on 6/23/2025, response/answer due 7/14/2025; WENXUEDEXIAODIAN served on 6/23/2025, response/answer due 7/14/2025; Wiesumirt-US served on 6/23/2025, response/answer due 7/14/2025; World Gift Store served on 6/23/2025, response/answer due 7/14/2025; Worldmuma Store served on 6/23/2025, response/answer due 7/14/2025; XH Studio Design served on 6/23/2025, response/answer due 7/14/2025; Xiaohanshangmao served on 6/23/2025, response/answer due 7/14/2025; Yajuhoy served on 6/23/2025, response/answer due 7/14/2025; YouyouEngin served on 6/23/2025, response/answer due 7/14/2025; ZYSMY-US served on 6/23/2025, response/answer due 7/14/2025; Zhanglin Shop11 Store served on 6/23/2025, response/answer due 7/14/2025; agri_82 served on 6/23/2025, response/answer due 7/14/2025; ak-super-mart served on 6/23/2025, response/answer due 7/14/2025; akashpramu_2005 served on 6/23/2025, response/answer due 7/14/2025; almog_store10 served on 6/23/2025, response/answer due 7/14/2025; alvpil0 served on 6/23/2025, response/answer due 7/14/2025; amabilis Store served on 6/23/2025, response/answer due 7/14/2025; asgar6_46 served on 6/23/2025, response/answer due 7/14/2025; avigdor_Store34 served on 6/23/2025, response/answer due 7/14/2025; ayse-new served on 6/23/2025, response/answer due 7/14/2025; baqdur served on 6/23/2025, response/answer due 7/14/2025; barak_store33 served on 6/23/2025, response/answer due 7/14/2025; beauty_of_ting1 served on 6/23/2025, response/answer due 7/14/2025; beery_14 served on 6/23/2025, response/answer due 7/14/2025; besty_liveayy served on 6/23/2025, response/answer due 7/14/2025; brightfai1990 served on 6/23/2025, response/answer due 7/14/2025; brother-home served on 6/23/2025, response/answer due 7/14/2025; charlyebooy served on 6/23/2025, response/answer due 7/14/2025; chasna_77 served on 6/23/2025, response/answer due 7/14/2025; chengshangqixia served on 6/23/2025, response/answer due 7/14/2025; chenyuefabaihuo served on 6/23/2025, response/answer due 7/14/2025; chuichui served on 6/23/2025, response/answer due 7/14/2025; cozy_home09 served on 6/23/2025, response/answer due 7/14/2025; deckoc served on 6/23/2025, response/answer due 7/14/2025; dovydajaksta0 served on 6/23/2025, response/answer due 7/14/2025; drorb served on 6/23/2025, response/answer due 7/14/2025; eldad_100 served on 6/23/2025, response/answer due 7/14/2025; famangmang served on 6/23/2025, response/answer due 7/14/2025; fecomp1 served on 6/23/2025, response/answer due 7/14/2025; foshanshilishuangdushangmao served on 6/23/2025, response/answer due 7/14/2025; gbproducts_1719 served on 6/23/2025, response/answer due 7/14/2025; glow.m43 served on 6/23/2025, response/answer due 7/14/2025; gokhan0101 served on 6/23/2025, response/answer due 7/14/2025; guangzhouhuanmeichuanmei served on 6/23/2025, response/answer due 7/14/2025; guangzhoujunxinganjiefuwuyouxiangongsi served on 6/23/2025, response/answer due 7/14/2025; haim_shop09 served on 6/23/2025, response/answer due 7/14/2025; hakara3905 served on 6/23/2025, response/answer due 7/14/2025; hou ying wei Home Store served on 6/23/2025, response/answer due 7/14/2025; ibrari-66 served on 6/23/2025, response/answer due 7/14/2025; idanpin19 served on 6/23/2025, response/answer due 7/14/2025; imat-4325 served on 6/23/2025, response/answer due 7/14/2025; inter-links served on 6/23/2025, response/answer due 7/14/2025; jaja's store served on 6/23/2025, response/answer due 7/14/2025; jarreyj40 served on 6/23/2025, response/answer due 7/14/2025; jawad_2 served on 6/23/2025, response/answer due 7/14/2025; johnmarketing35 served on 6/23/2025, response/answer due 7/14/2025; jolie346 served on 6/23/2025, response/answer due 7/14/2025; jorgecar-0 served on 6/23/2025, response/answer due 7/14/2025; kangaroos_shipping served on 6/23/2025, response/answer due 7/14/2025; kft mall served on 6/23/2025, response/answer due 7/14/2025; kunmingxiongkuoshangmaoyouxiangongsi served on 6/23/2025, response/answer due 7/14/2025; ldliao321_shop served on 6/23/2025, response/answer due 7/14/2025; lidors57 served on 6/23/2025, response/answer due 7/14/2025; light the stars served on 6/23/2025, response/answer due 7/14/2025; linlei served on 6/23/2025, response/answer due 7/14/2025; linxiaohao served on 6/23/2025, response/answer due 7/14/2025; lyongt206 served on 6/23/2025, response/answer due 7/14/2025; malkiel_Store321 served on 6/23/2025, response/answer due 7/14/2025; mr.japan2021 served on 6/23/2025, response/answer due 7/14/2025; muhaim-9476 served on 6/23/2025, response/answer due 7/14/2025; na-871349 served on 6/23/2025, response/answer due 7/14/2025; naler61 served on 6/23/2025, response/answer due 7/14/2025; nir_store45 served on 6/23/2025, response/answer due 7/14/2025; pesachye0 served on 6/23/2025, response/answer due 7/14/2025; pgu2012 served on 6/23/2025, response/answer due 7/14/2025; pinpinshop served on 6/23/2025, response/answer due 7/14/2025; pitaya520 served on 6/23/2025, response/answer due 7/14/2025; poyangxianzhenqinjiubaihuodian11 served on 6/23/2025, response/answer due 7/14/2025; pstiang served on 6/23/2025, response/answer due 7/14/2025; purevaluestore served on 6/23/2025, response/answer due 7/14/2025; qigelongdongqiang served on 6/23/2025, response/answer due 7/14/2025; ralyn-77 served on 6/23/2025, response/answer due 7/14/2025; ran-chen served on 6/23/2025, response/answer due 7/14/2025; ranotlior.08 served on 6/23/2025, response/answer due 7/14/2025; salih served on 6/23/2025, response/answer due 7/14/2025; sams_store_1 served on 6/23/2025, response/answer due 7/14/2025; shaoshanshizicong served on 6/23/2025, response/answer due 7/14/2025; shenglixiaopu served on 6/23/2025, response/answer due 7/14/2025; shenmiaoamz served on 6/23/2025, response/answer due 7/14/2025; shimshon_store45 served on 6/23/2025, response/answer due 7/14/2025; shturya served on 6/23/2025, response/answer due 7/14/2025; store_sell101 served on 6/23/2025, response/answer due 7/14/2025; sunhongshe666 served on 6/23/2025, response/answer due 7/14/2025; superwind car Store served on 6/23/2025, response/answer due 7/14/2025; tamir_shop332 served on 6/23/2025, response/answer due 7/14/2025; the_great_useful_things served on 6/23/2025, response/answer due 7/14/2025; theparts-garage served on 6/23/2025, response/answer due 7/14/2025; tousha-14 served on 6/23/2025, response/answer due 7/14/2025; uepaijia served on 6/23/2025, response/answer due 7/14/2025; uisuiqu served on 6/23/2025, response/answer due 7/14/2025; ukaju-0 served on 6/23/2025, response/answer due 7/14/2025; wangbingamzaa served on 6/23/2025, response/answer due 7/14/2025; wangdandankj Co.ltd served on 6/23/2025, response/answer due 7/14/2025; wanghaihui served on 6/23/2025, response/answer due 7/14/2025; xiaodoushipindian served on 6/23/2025, response/answer due 7/14/2025; xisoushangmao served on 6/23/2025, response/answer due 7/14/2025; xiugourong99 served on 6/23/2025, response/answer due 7/14/2025; yaakovitzhakbiderman1 served on 6/23/2025, response/answer due 7/14/2025; yangxiaoqiang served on 6/23/2025, response/answer due 7/14/2025; yasirulak2001-store served on 6/23/2025, response/answer due 7/14/2025; yehudan33 served on 6/23/2025, response/answer due 7/14/2025; yisen shop served on 6/23/2025, response/answer due 7/14/2025; ymop3988 served on 6/23/2025, response/answer due 7/14/2025; zen-zen7 served on 6/23/2025, response/answer due 7/14/2025; zhaidingshangmao served on 6/23/2025, response/answer due 7/14/2025; zhengyizhi served on 6/23/2025, response/answer due 7/14/2025.

STATUS REPORT in Compliance with the Court's Order dated June 25, 2025 [DE 50] by Purple Innovation, LLC

Plaintiff's NOTICE of Filing [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 William P. Dimitrouleas: Preliminary Injunction Hearing held on 6/27/2025. Total time in court: 5 minutes. Attorney Appearance(s): Leigh Benjamin Salomon, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov.

ORDER Disapproving [59] Notice of Voluntary Dismissal, [58] Notice of Voluntary Dismissal, [51] Notice of Voluntary Dismissal. Signed by Judge William P. Dimitrouleas on 6/30/2025. See attached document for full details.

ORDER granting [54] Motion to Unseal Case. 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 William P. Dimitrouleas on 6/30/2025. See attached document for full details.

ORDER GRANTING PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION granting [13] Motion for Preliminary Injunction. Signed by Judge William P. Dimitrouleas on 6/27/2025. See attached document for full details.

Clerk's NOTICE of Compliance re [65] Order on Motion to Unseal Case. All Docket Entries Unsealed.

Plaintiff's NOTICE of Filing Proposed Order Approving Voluntary Dismissal by Purple Innovation, LLC re [64] Order, [59] Notice of Voluntary Dismissal, [51] Notice of Voluntary Dismissal

Text of Proposed Order Approving Voluntary Dismissal

Order Approving [59] Notice of Voluntary Dismissal, [58] Notice of Voluntary Dismissal, [51] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants Auvivasital-US, brother-home, CLLXDZ, GYDZSW, Ludovico, SANHEKEJI, TONOS LLC, Wiesumirt-US, drbashi, ElyaGStore, Factory*Sales*Store, lamboone, lior26122008, Net Best, NO1.Mark, ofer26883, ronenmaman, sagib-6893, shlomisolomon, StoreITOne, sunshine-worldfactory, wholeale2022store, yovelxl5363. Signed by Judge William P. Dimitrouleas on 7/1/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 29 (H HOKIZU), 46 (PrimePick GS), 85 (charlyebooy), 91 (deckoc), 120 (jorgecar-0), 142 (pgu2012), and 147 (Raanana700) by Purple Innovation, LLC

Text of Proposed Order Approving Voluntary Dismissal

NOTICE of Withdrawal of Motion to Dissolve Preliminary Injunction from Liat Orr

Order Approving [70] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants Raanana700, charlyebooy, deckoc, jorgecar-0, pgu2012, H HOKIZU and PrimePick GS. Signed by Judge William P. Dimitrouleas on 7/2/2025. See attached document for full details.

NOTICE of Attorney Appearance by Jianyin Liu on behalf of KINGMAZI. Attorney Jianyin Liu added to party KINGMAZI(pty:dft).

MOTION TO DISMISS [60] Summons Returned Executed, [1] Complaint, FOR FAILURE TO STATE A CLAIM by KINGMAZI. Responses due by 7/21/2025.

MOTION to Dismiss [1] Complaint, pursuant to Rule 12(B)(2) and Rule 12(B)(3) by Robert Nagovskyi. Responses due by 7/21/2025.

NOTICE of Voluntary Dismissal of Defendant Nos. 22 (chengshangqixia), 41 (Maiku-US), 47 (QDWJD), 49 (REMEDIC), 68 (almog_store10), 75 (Automotive*Motorcycle*Shop), 77 (avigdor_Store34), 80 (barak_store33), 89 (CUSTOMER SERVICETOP), 104 (haim_shop09), 107 (Home*Gardon*Store), 118 (johnmarketing35), 128 (malkiel_Store321), 137 (nir_store45), 157 (shimshon_store45), and 164 (tamir_shop332) by Purple Innovation, LLC

Text of Proposed Order Approving Voluntary Dismissal

Order Approving [76] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants Home*Gardon*Store, Maiku-US, QDWJD, REMEDIC, almog_store10, avigdor_Store34, barak_store33, chengshangqixia, haim_shop09, johnmarketing35, malkiel_Store321, nir_store45, shimshon_store45, tamir_shop332, Automotive*Motorcycle*Shop and CUSTOMER SERVICETOP. Signed by Judge William P. Dimitrouleas on 7/9/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 166 (theparts-garage) and 185 (Verona Morris) by Purple Innovation, LLC

Text of Proposed Order

NOTICE of Withdrawing Motion to Dismiss [DE 74] by KINGMAZI re [74] MOTION TO DISMISS [60] Summons Returned Executed, [1] Complaint, FOR FAILURE TO STATE A CLAIM

NOTICE OF WITHDRAWAL OF MOTION by KINGMAZI re [74] MOTION TO DISMISS [1] Complaint, FOR FAILURE TO STATE A CLAIM filed by KINGMAZI (ls)(See Image at DE #79)

Clerk's Notice to Filer re [79] Notice (Other). Wrong Event Selected; ERROR - The Filer selected the wrong event. The document was re-docketed by the Clerk, see [de#80]. It is not necessary to refile this document.

Order Approving [78] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants Verona Morris and theparts-garage. Signed by Judge William P. Dimitrouleas on 7/11/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 121 (KamsssStore), 196 (Caiboxing), and 245 (Triani) by Purple Innovation, LLC

Text of Proposed Order

Order Approving [83] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants Triani, Caiboxing and KamsssStore. Signed by Judge William P. Dimitrouleas on 7/15/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 30 (HFDAMAI), 31 (Hongfan reputation shop), 45 (poyangxianzhenqinjiubaihuodian11), 122 (kangaroos_shipping), 141 (pesachye0), 145 (Pudding_Toys), 220 (KINGMAZI), and 228 (Nanjingkangchen Tech Co. Ltd) by Purple Innovation, LLC

Text of Proposed Order

Order Approving [85] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants KINGMAZI, Nanjingkangchen Tech Co. Ltd, Pudding_Toys, kangaroos_shipping, pesachye0, poyangxianzhenqinjiubaihuodian11, HFDAMAI and Hongfan reputation shop. Signed by Judge William P. Dimitrouleas on 7/18/2025. See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A by Purple Innovation, LLC.

Declaration of Leigh Salomon

PAPERLESS ORDER by Clerk of Entry of Default re [87] Motion for Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Signed by DEPUTY CLERK on 7/21/2025.

NOTICE of Settlement of Defendant No. 98 (Everyday Picks) by Purple Innovation, LLC

ORDER TO SHOW CAUSE as to why the [75] MOTION to Dismiss [1] Complaint, should not be Granted. Show Cause Response due by 7/29/2025. Signed by Judge William P. Dimitrouleas on 7/22/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 65 (agri_82), 101 (gbproducts_1719), 227 (Myzhe), and 231 (QmeDNh) by Purple Innovation, LLC

Text of Proposed Order

Order Approving [91] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants agri_82, gbproducts_1719, Myzhe and QmeDNh. Signed by Judge William P. Dimitrouleas on 7/23/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 124 (ldliao321_shop), 130 (mr.japan2021), 139 (Nuwinen), and 230 (ONFSLX) by Purple Innovation, LLC

Text of Proposed Order

Order Approving [94] Notice of Voluntary Dismissal: Dismissing Case without prejudice as to Defendants ldliao321_shop, mr.japan2021, Nuwinen and ONFSLX. Signed by Judge William P. Dimitrouleas on 7/25/2025. See attached document for full details.

RESPONSE TO ORDER TO SHOW CAUSE re [90] Order to Show Cause, by Purple Innovation, LLC.

ORDER TO SHOW CAUSE as to why Plaintiff has not moved for Default Judgment against remaining Defendants. Show Cause Response due by 8/8/2025. Signed by Judge William P. Dimitrouleas on 7/31/2025. See attached document for full details.

Order Approving [98] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants Hanyge, Needhep, QuLuJing, BDStore4U and Canelx. Signed by Judge William P. Dimitrouleas on 8/4/2025. See attached document for full details.

NOTICE of Settlement of Defendant No. 98 (Everyday Picks) by Purple Innovation, LLC

NOTICE of Withdrawal of Motion by Robert Nagovskyi re [75] MOTION to Dismiss [1] Complaint

Order Approving [103] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendants JIAOCHU and asgar6_46. Signed by Judge William P. Dimitrouleas on 8/8/2025. See attached document for full details.

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

Declaration of Leigh Salomon

Exhibit 1 (Part 1 of 18)

Exhibit 1 (Part 2 of 18)

Exhibit 1 (Part 3 of 18)

Exhibit 1 (Part 4 of 18)

Exhibit 1 (Part 5 of 18)

Exhibit 1 (Part 6 of 18)

Exhibit 1 (Part 7 of 18)

Exhibit 1 (Part 8 of 18)

Exhibit 1 (Part 9 of 18)

Exhibit 1 (Part 10 of 18)

Exhibit 1 (Part 11 of 18)

Exhibit 1 (Part 12 of 18)

Exhibit 1 (Part 13 of 18)

Exhibit 1 (Part 14 of 18)

Exhibit 1 (Part 15 of 18)

Exhibit 1 (Part 16 of 18)

Exhibit 1 (Part 17 of 18)

Exhibit 1 (Part 18 of 18)

Exhibit 2

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

Text of Proposed Final Default Judgment and Permanent Injunction

ORDER TO SHOW CAUSE re 105 Plaintiff's MOTION for Default Judgment filed by Purple Innovation, LLC. Show Cause Response due by 8/22/2025. Signed by Judge William P. Dimitrouleas on 8/11/2025. See attached document for full details.

NOTICE of Compliance by Purple Innovation, LLC re 106 Order to Show Cause

NOTICE of Voluntary Dismissal of Defendant No. 76 (AVECHJAPAN) by Purple Innovation, LLC

(Text of Proposed Order Approving Voluntary Dismissal)

Order Approving 108 Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendant AVECHJAPAN. Signed by Judge William P. Dimitrouleas on 8/18/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant No. 254 (yangxiaoqiang) by Purple Innovation, LLC

Text of Proposed Order

Order Approving 110 Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendant yangxiaoqiang. Signed by Judge William P. Dimitrouleas on 8/22/2025. See attached document for full details.

ORDER Requiring Proposed Order re 105 Plaintiff's Motion for Default Judgment, by 8/27/2025. Signed by Judge William P. Dimitrouleas on 8/25/2025. See attached document for full details.

ORDER granting 105 Motion for Final Default Judgment. Closing Case. Signed by Judge William P. Dimitrouleas on 8/28/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT and PERMANENT INJUNCTION in favor of Purple Innovation, LLC against Defendants, Individuals, Partnerships, or Unincorporated Associations identified on Schedule "A" hereto. Signed by Judge William P. Dimitrouleas on 8/28/2025. See attached document for full details.

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

(Supplement Final Default Judgment and Permanent Injunction) (ls)

NOTICE of Voluntary Dismissal of Defendant No. 182 (Art) by Purple Innovation, LLC

(Text of Proposed Order)

ORDER Disapproving 116 Notice of Voluntary Dismissal. Signed by Judge William P. Dimitrouleas on 9/2/2025. See attached document for full details.

Plaintiff's MOTION for clarification 117 Order, 116 Notice of Voluntary Dismissal by Purple Innovation, LLC. Responses due by 9/16/2025.

(Text of Proposed Order)

ORDER granting 118 Motion for Clarification; Approving 116 Notice of Voluntary Dismissal; Dismissing Case without prejudice as to Defendant DOE No. 182, Art. Signed by Judge William P. Dimitrouleas on 9/3/2025. See attached document for full details.

Plaintiff's MOTION for Disbursement of Funds - Return of Bond by Purple Innovation, LLC.

(Text of Proposed Order)

DISBURSEMENT ORDER of Funds to Boies Schiller Flexner LLP in the amount of $100,000.00. Signed by Judge William P. Dimitrouleas on 9/4/2025. See attached document for full details.

SATISFACTION OF JUDGMENT re 114 Default Judgment, Permanent Injunction, as to Defendant 241 (StrataSph) by Purple Innovation, LLC

SATISFACTION OF JUDGMENT re 114 Default Judgment, Permanent Injunction, as to Defendant No. 111 (IEB's Store) by Purple Innovation, LLC