2025-cv-20514

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18177200, filed by Difold Inc.

Exhibit 1

(Civil Cover Sheet)

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

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

Certificate of Other Affiliates/Corporate Disclosure Statement by Difold Inc. identifying Corporate Parent Hyperfold JSC for Difold Inc.

Plaintiff's MOTION to Seal Schedule A to Complaint per Local Rule 5.4 by Difold Inc.

(Text of Proposed Order)

Order

ORDER GRANTING 5 MOTION TO FILE UNDER SEAL. Signed by Judge Roy K. Altman on 2/5/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 7 [misc] restricted/sealed until further notice. (1857863)

ORDER IN CASES WITH MULTIPLE DEFENDANTS. Signed by Judge Roy K. Altman on 2/5/2025. See attached document for full details.

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 12] by Difold Inc.

Summon(s)

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

NOTICE of Attorney Appearance by Leigh Benjamin Salomon on behalf of Difold Inc. Attorney Leigh Benjamin Salomon added to party Difold Inc.(pty:pla).

BOND in the amount of $5,000.00 receipt # 298570 posted by Difold Inc. Approved by Judge Roy K. Altman at DE#12.

Plaintiff's MOTION for Extension of Time to Extend Briefing Deadlines by Difold Inc. Responses due by 3/6/2025.

Exhibit Declaration of Nicole Fundora ISO Motion to Extend Briefing Deadlines

Text of Proposed Order

PAPERLESS ORDER granting 17 Motion for Extension of Time. The deadline for the Defendants to oppose the Plaintiff's Motion for Preliminary Injunction shall be extended to March 7, 2025. The deadline for the Plaintiff to file its reply to any response in opposition is extended to March 10, 2025. Signed by Judge Roy K. Altman on 2/21/2025.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Difold Inc. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 3/5/2025, response/answer due 3/26/2025.

(Exhibit Schedule A to Complaint - list of defendants served)

Plaintiff's MOTION to Unseal Case by Difold Inc. Responses due by 3/19/2025.

(Text of Proposed Order)

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 Dibang Silicone Rubber Household Products Co., Ltd., Guizhou Zhirong Xinde Enterprise Management Co., Ltd., Ningbo Double G Trading Co., Ltd., Shenzhen Pin Ke Industrial Co., Ltd., Sichuan Mybottle Technology Co., Ltd., Suzhou Zejunhui Home Product Co., Ltd., Yiwu Chengrong Electronic Commerce Co.,ltd, Yiwu Juecai Trade Co., Ltd., Zhangjiagang Newcoast Construction Materials Co., Ltd., Shop 1103207972 Store, USLION Official Store, 70422, chenchenkundedianpu, Context Real.X, CXZWZ, DaoXiFu, DeLiBaiH, Divinity Seed, Finura Store, fishpride, GangLinSEN, guowangdexiny i, GWESFDGZ, hao bo mao yi, High-quality products collection, HuaiBaoMh, jiaxingshiyibomaoyiyouxiangongsi, Junwang123, Kakamono, Komost, kylinss, LANDENGWANG, lihaifeng123, LinErBHD, Liurongchaos, Liuys shop, ManFeiLiDuo, MIEDEON, Mo Caikun International Trade, MuXiaoB, Nini Corporation, QiangWeia, QIANGYUNDIANZI, qinggandianzishangwuyouxiangongsi, QiSheShu, SAMUKA, Sinicline Shop, Springen, Three Pigs, TinyTiger Lifestory, TOKOSIO, US-acxc LLC, WeIXIB, WEN LU HAO, WIGOEIANCN IN STORE, wuhanyajilidianzishangwuzhongxin, Xingye-Home, XuGW, YANmsh, YuanShaGui, yuhong shop, zhenjiangs, ZHUOLAIYAN, ZONGXING, aliexcllent, Beautifuljewelry2 (supfhsion), damoni-77, dancing-flames, digitalzstore, dri5-85, famfindsbazaar, flamenco0039, hans_muller, hfmh5525, high-qualityworldproducts132hqwp, jasons5486, kulwant_81, lamul6397, mipha22, noobster8, page_5600 (trang_5600), perfekto24, premiumitemseb, raslokuli-0, royalcart-az, rustuoont, shopello_99, Sjewelrystore (prtstore), tahirmustafakhan22, the_global_gallery, Underwear*Loungewear*Store (fullhousemart66), unixmoment, Versa Market (yosefsimri21), VirtualShopping World (husmoha-95), Yaoping_Wang (enpq3636), yindou, yunfeichi01 and za61926.

Notice of Entry of Parties Listed on 22 Notice of Entry of Parties Listed into CM/ECF, into CM/ECF. NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): zenith_shop, zgmh2584, A beautiful life, AbbyAiTt, BAGWORLD, barley, binbinbag, dcdsc, Dongyang on daily necessities, fengbacao, Gbxy Sport, Goobo, hongdei, HUA XIAO STORE, Hualiwen, huilan, jumm, Lao Mo Department Store Selection, LUHUANGJU, Mile MengChuang, New Flash Technology, Yammy, Yiwu Xinnuo Trading Co., Ltd., yiwuqiaoyu, YJjiadefu, ykwanxiantang, yuchengxing, Zhenyuan Pet Products, zhuoshi123, ZJ Daily, EBUYE, Global Bazaar shop, Haoyan Xi Electric Appliance Co LTD, JATEN SHOP, KAIJU TRADE, KKYUMY, Lift Business, LYuShan, Nar Household, new magic cup, THE LITTLE RB, Wansheng Space, Yan XiElectronic Technology, Better and Easy Life, CHANGXIAO, Chaoda fashion boutique, Chengduqiuhainian Co.,Ltd, chenyangtaiyang, Cloud Shoes Store, Cteifuer, Da Ma, Depato, fantasticshop, Fendali Trading, foshanshijuejunhenshangmao, foshanshilikejunshangmao, foshanshiyangdundeshangmao, Genruite, GMGQJDS, GODOIT, GoodGoods, goodssky, guang zhou yi yu mao yi you xian gong si, GuangZhouFengYanQi, guangzhouhaishangmaoyi, Hand Jet, haolunmaoyi, HGYW, Honest Healthcare, HongDongXianShuoHuaShangMao, HongDongXianTeSaDianZi, hunanyirenyingshiwenhuachuanmeiyouxiangongsi, HYYsecond, Iricdace, JD Trade CO.,LTD, jinanhengyuansiwangluokeji, jinanshannantiyuqicai, jinanyixuanshangmaoxiaoshouyouxiangongsi, JingXinHuJianKangGuanLi, kaibaomaoyi, KEYHHWE, KOFPA, laifuzhubao, LaMaz, LIAOBOWEN, liboshangmaa, lijingrongbaozhuangcailiao, lixiaoshangmao, longuan, LTS EMIRA, LXJYUYU, O2frepak Direct, Rain Tin, ruoiit37, ruoit37, sanshiguanggao, Shenzhenshininghuimaoyi Co. Ltd., SUQIN, TaiYuan, taiyuanyanhongshangmao, TBKOMH, VacYaYa, WangDan12, WeiAoShangMao, wenbirdword, WVacFre, xiangtanxinla, Xiao market, xiongdasujiaozhipin, xulizhixingkeji, XuYing12, Yaxueyuan network, YGKJYXGS, yiqukeji, yuanchenfeishangmao, yuesongkeji, zhaoliangfashangmao, ZHIGUAN and Zitingyi Trading Co., Ltd.

Plaintiff's NOTICE of Filing Proposed Order on Plaintiff's Motion for Preliminary Injunction by Difold Inc.

(Text of Proposed Order)

PAPERLESS NOTICE of Hearing: **TIME CHANGE ONLY** The Preliminary Injunction Hearing on March 11, 2025, has been reset to 11:30 AM in Miami Division before Judge Roy K. Altman.

CERTIFICATE OF SERVICE by Difold Inc. re [25] Notice re Hearing

Exhibit Schedule A to Complaint - list of defendants served

ORDER Granting 21 Motion to Unseal Case. The Clerk is directed to UNSEAL this case and return all docket entries to the public record. The Plaintiff shall amend the case caption to reflect the Plaintiff's true name by March 14, 2025. Signed by Judge Roy K. Altman on 3/10/2025. See attached document for full details.

NOTICE of Compliance re DE# 27. All documents in this case have been unsealed per DE#27.

PAPERLESS Minute Entry for proceedings held before Judge Roy K. Altman: Preliminary Injunction Hearing held on 3/11/2025. Total time in court: 8 minutes. Attorney Appearance(s): Leigh Benjamin Salomon. Court Reporter: Francine Salopek, 305-301-3276 / mjsfcs@aol.com. (es00)

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

ORDER GRANTING 9 MOTION FOR PRELIMINARY INJUNCTION. CLOSING CASE. Signed by Judge Roy K. Altman on 3/12/2025. See attached document for full details.

Civil Case Terminated per DE 31 ORDER. CLOSING CASE.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

PAPERLESS ORDER. On March 5, 2025, the Plaintiff filed "Proof of Service" [ECF No. 20 ], certifying that it served all of the Defendants that same day. Federal Rule of Civil Procedure 12 provides that a defendant must serve an answer within 21 days after being served with the summons and complaint. The Defendants' responses to the Amended Complaint, therefore, were due on March 26, 2025. That deadline has passed, and the Defendants haven't responded to the Complaint, requested an extension of time, or otherwise appeared in the case at all. See generally Docket. So, by April 3, 2025, the Plaintiff must do one of two things: either move for Clerk's Entry of Default to begin default final judgment procedures against all remaining Defendants or file a notice of voluntary dismissal. Signed by Judge Roy K. Altman on 3/27/2025.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

MOTION for Clerk's Entry of Default as to $$QIANRU$$, A beautiful life, AbbyAiTt, Beautifuljewelry2 (supfhsion), CHANGXIAO, CXZWZ, Chaoda fashion boutique, Chengduqiuhainian Co.,Ltd, Context Real.X, Cteifuer, Da Ma, DaoXiFu, DeLiBaiH, Divinity Seed, Dongguan Dibang Silicone Rubber Household Products Co., Ltd., EBUYE, Fendali Trading, Finura Store, GMGQJDS, GODOIT, GWESFDGZ, GangLinSEN, Genruite, GoodGoods, GuangZhouFengYanQi, Guizhou Zhirong Xinde Enterprise Management Co., Ltd., HGYW, HUA XIAO STORE, HYYsecond, Haoyan Xi Electric Appliance Co LTD, High-quality products collection, Honest Healthcare, HongDongXianShuoHuaShangMao, HongDongXianTeSaDianZi, HuaiBaoMh, Hualiwen, Iricdace, JATEN SHOP, JD Trade CO.,LTD, JingXinHuJianKangGuanLi, Junwang123, KEYHHWE, KKYUMY, KOFPA, LANDENGWANG, LIAOBOWEN, LUHUANGJU, LXJYUYU, LYuShan, LaMaz, Lao Mo Department Store Selection, Lift Business, LinErBHD, Liurongchaos, Liuys shop, MIEDEON, ManFeiLiDuo, Mo Caikun International Trade, MuXiaoB, Nar Household, New Flash Technology, Ningbo Double G Trading Co., Ltd., Nini Corporation, O2frepak Direct, QIANGYUNDIANZI, QiSheShu, QiangWeia, SAMUKA, SUQIN, Shenzhen Pin Ke Industrial Co., Ltd., Shop 1103207972 Store, Sichuan Mybottle Technology Co., Ltd., Sinicline Shop, Sjewelrystore (prtstore), Suzhou Zejunhui Home Product Co., Ltd., TOKOSIO, TaiYuan, Three Pigs, TinyTiger Lifestory, US-acxc LLC, USLION Official Store, UnderwearLoungewearStore (fullhousemart66), VacYaYa, Versa Market (yosefsimri21), VirtualShopping World (husmoha-95), WEN LU HAO, WIGOEIANCN IN STORE, WVacFre, WangDan12, Wansheng Space, WeIXIB, WeiAoShangMao, Xingye-Home, XuGW, XuYing12, YANmsh, YGKJYXGS, YJjiadefu, Yammy, Yan XiElectronic Technology, Yaoping_Wang (enpq3636), Yaxueyuan network, Yiwu Chengrong Electronic Commerce Co.,ltd, Yiwu Juecai Trade Co., Ltd., Yiwu Xinnuo Trading Co., Ltd., YuanShaGui, ZHIGUAN, ZHUOLAIYAN, ZJ Daily, ZONGXING, Zhangjiagang Newcoast Construction Materials Co., Ltd., Zhenyuan Pet Products, Zitingyi Trading Co., Ltd., aliexcllent, binbinbag, chenchenkundedianpu, chenyangtaiyang, damoni-77, dancing-flames, dcdsc, digitalzstore, dri5-85, famfindsbazaar, fantasticshop, flamenco0039, foshanshijuejunhenshangmao, foshanshilikejunshangmao, foshanshiyangdundeshangmao, goodssky, guang zhou yi yu mao yi you xian gong si, guangzhouhaishangmaoyi, guowangdexinyi, hans_muller, hao bo mao yi, haolunmaoyi, hfmh5525, high-qualityworldproducts132hqwp, huilan, hunanyirenyingshiwenhuachuanmeiyouxiangongsi, jasons5486, jiaxingshiyibomaoyiyouxiangongsi, jinanhengyuansiwangluokeji, jinanshannantiyuqicai, jinanyixuanshangmaoxiaoshouyouxiangongsi, kaibaomaoyi, kulwant_81, kylinss, laifuzhubao, lamul6397, liboshangmaa, lihaifeng123, lijingrongbaozhuangcailiao, lixiaoshangmao, longuan, mipha22, noobster8, page_5600 (trang_5600), premiumitemseb, qinggandianzishangwuyouxiangongsi, raslokuli-0, royalcart-az, ruoiit37, ruoit37, rustuoont, sanshiguanggao, shopello_99, tahirmustafakhan22, taiyuanyanhongshangmao, the_global_gallery, unixmoment, wenbirdword, wuhanyajilidianzishangwuzhongxin, xiangtanxinla, xiongdasujiaozhipin, xulizhixingkeji, yindou, yiwuqiaoyu, ykwanxiantang, yuanchenfeishangmao, yuchengxing, yuesongkeji, yuhong shop, yunfeichi01, za61926, zenith_shop, zgmh2584, zhaoliangfashangmao, zhenjiangs, zhuoshi123 by Difold Inc.

Affidavit Declaration of Nicole Fundora ISO Request for Entry of Clerk's De

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A - Motions Terminated: 47 Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 4/4/2025.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE. Signed by Judge Roy K. Altman on 4/4/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Difold Inc.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Difold Inc.

Exhibit Schedule A - list of Defaulting Defendants

Exhibit Table of Damages Calculation

Affidavit Declaration of Nicole Fundora ISO Motion for Default

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 1 of 6)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 2 of 6)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 3 of 6)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 4 of 6)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 5 of 6)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 6 of 6)

Text of Proposed Order

Text of Proposed Order

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Difold Inc.

ORDER granting [56] Motion For Entry Of Final Default Judgment. Signed by Judge Roy K. Altman on 5/5/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION. Signed by Judge Roy K. Altman on 5/5/2025. See attached document for full details.

Plaintiff's MOTION for Disbursement of Funds Return of Bond by Difold Inc.

Text of Proposed Order

DISBURSEMENT ORDER. The Plaintiff's Motion for Return of Bond [ECF No. 62 ] is GRANTED. Signed by Judge Roy K. Altman on 5/7/2025. See attached document for full details.

SATISFACTION OF JUDGMENT re 61 Default Judgment, Permanent Injunction as to Defendant No. 84 (perfekto24) by Difold Inc.

SATISFACTION OF JUDGMENT re 61 Default Judgment, Permanent Injunction as to Defendant No. 32 (LANDENGWANG) by Difold Inc.

SATISFACTION OF JUDGMENT re 61 Default Judgment, Permanent Injunction as to Defendant No. 36 (Liuys shop), 44 (qinggandianzishangwuyouxiangongsi), and 54 (WEN LU HAO) by Difold Inc.

SATISFACTION OF JUDGMENT re 61 Default Judgment, Permanent Injunction as to Defendant No. 181 (KEYHHWE) by Difold Inc.

SATISFACTION OF JUDGMENT re 61 Default Judgment, Permanent Injunction as to Defendant No. 124 (yiwuqiaoyu) by Difold Inc.

SATISFACTION OF JUDGMENT re [61] Default Judgment, Permanent Injunction as to Defendants No. 147 (Chengduqiuhainian Co.,Ltd) and 179 (JingXinHuJianKangGuanLi) by Difold Inc.