2025-cv-20637

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18197812, filed by Purple Innovation, LLC.

Exhibit 1

Exhibit 2

(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.

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

Order (Text entry; no document attached.)

(Complaint) (ksr)

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

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

SYSTEM ENTRY - Docket Entry 6 [motion] restricted/sealed until further notice. (2195053) (Text entry; no document attached.)

(Text of Proposed Order)

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

(Text of Proposed Order)

OMNIBUS ORDER granting [5] Motion for Leave to File Excess Pages; granting [7] Motion to Seal. Signed by Judge Roy K. Altman on 2/18/2025. See attached document for full details.

Order (Text entry; no document attached.)

NOTICE of Attorney Appearance by Jianyin Liu on behalf of BCDZSW, Evern USA, Hvllyan US, Inreaktek-US, LINW, Sydzsw-US, XSIUYU-US, ZengAnKeJi. Attorney Jianyin Liu added to party BCDZSW(pty:dft), Attorney Jianyin Liu added to party Evern USA(pty:dft), Attorney Jianyin Liu added to party Hvllyan US(pty:dft), Attorney Jianyin Liu added to party Inreaktek-US(pty:dft), Attorney Jianyin Liu added to party LINW(pty:dft), Attorney Jianyin Liu added to party Sydzsw-US(pty:dft), Attorney Jianyin Liu added to party XSIUYU-US(pty:dft), Attorney Jianyin Liu added to party ZengAnKeJi(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-18264705 by BCDZSW, Evern USA, Hvllyan US, Inreaktek-US, LINW, Sydzsw-US, XSIUYU-US, ZengAnKeJi. Responses due by 3/21/2025.

SYSTEM ENTRY - Docket Entry 14 [order] restricted/sealed until further notice. (Text entry; no document attached.)

Certification Att'y Certification

(Text of Proposed Order)

ORDER granting [13] 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 Roy K. Altman on 3/10/2025. See attached document for full details.

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

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

NOTICE of Voluntary Dismissal of Defendant Nos. 22 (BCDZSW), 28 (Evern USA), 36 (Hvllyan US), 37 (Inreaktek-US), 41 (LINW), 48 (Sydzsw-US), 54 (XSIUYU-US), and 57 (ZengAnKeJi) by Purple Innovation, LLC

Plaintiff's MOTION for Extension of Time to Extend Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines by Purple Innovation, LLC. Responses due by 4/2/2025.

Declaration of Leigh Salomon

Text of Proposed Order

PAPERLESS ORDER GRANTING [19] Motion for Extension of Temporary Restraining Order, of Time for Briefing, and to Reschedule Preliminary Injunction Hearing. We find good cause to extend the briefing schedule for the Motion for Preliminary Injunction, to extend the Temporary Restraining Order, and to reschedule the Preliminary Injunction hearing. A hearing is RESET before this Court on April 21, 2025, at 3:30 p.m., at which time the Defendants and/or any other affected persons may challenge the appropriateness of this Order and move to dissolve it, and at which the Court will hear argument on the Plaintiff's requested preliminary injunction. The hearing will be held in person in Courtroom 12-4 at the Wilkie D. Ferguson, Jr. U.S. Courthouse, 400 N. Miami Avenue, Miami, Florida 33128. Any response or opposition to the Plaintiff's Motion for Preliminary Injunction must be filed and served on Plaintiff's counsel by April 16, 2025. The Plaintiff shall file any Reply Memorandum by April 18, 2025. Signed by Judge Roy K. Altman on 3/20/2025. (rr01)

NOTICE of Voluntary Dismissal of Defendant No. 42 (LYuan) by Purple Innovation, LLC

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of JIAYANG Co.Ltd, JINGJING Co.Ltd, JIONGJING Co.Ltd, SHENGMAN Co.Ltd, XIONGDI Co.Ltd, YUANEN Co.Ltd, ZAIWEN Co.Ltd. Attorney Andrew Jonathan Palmer added to party JIAYANG Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party JINGJING Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party JIONGJING Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party SHENGMAN Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party XIONGDI Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party YUANEN Co.Ltd(pty:dft), Attorney Andrew Jonathan Palmer added to party ZAIWEN Co.Ltd(pty:dft).

BOND in the amount of $$5000.00 receipt # 300347 posted by Purple Innovation, LLC Approved by Judge Roy K. Altman

Clerks Receipt for bond for TRO per order of the court (DE#14) sealed received on 3/25/2025 in the amount of $ 5,000.00, receipt number FLS300347.

NOTICE of Attorney Appearance by Jianyin Liu on behalf of NewVision01. Attorney Jianyin Liu added to party NewVision01(pty:dft).

"STRICKEN" NOTICE of Attorney Appearance Pro Hac Vice for Additional Party Representation(s) for NewVision01. All information provided in support of the initial 13 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-18264705 remains current and correct, including the sponsoring co-counsel. Modified on 4/2/2025 (ls). (per DE #29)

Clerk's Notice to Filer re 26 Notice of Appearance Pro Hac Vice for Additional Party Representation. 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 (Missing Attorney Signature). 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.

CLERK'S NOTICE - PHV Attorney Qianwu Yang has been added to this case for parties NewVision01 re 26 Notice of Appearance Pro Hac Vice for Additional Party Representation

NOTICE of Striking 26 Notice of Appearance Pro Hac Vice for Additional Party Representation, filed by NewVision01 by NewVision01

NOTICE of Attorney Appearance Pro Hac Vice for Additional Party Representation(s) for NewVision01. All information provided in support of the initial 13 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-18264705 remains current and correct, including the sponsoring co-counsel.

NOTICE of Voluntary Dismissal of Defendant No. 45 (NewVision01) by Purple Innovation, LLC

NOTICE of Attorney Appearance by Jianyin Liu on behalf of Shouken, EVEME US, TONINT. Attorney Jianyin Liu added to party Shouken(pty:dft), Attorney Jianyin Liu added to party EVEME US(pty:dft), Attorney Jianyin Liu added to party TONINT(pty:dft).

Joint STIPULATION Modifying Asset Restraint re 20 Order on Motion for Extension of Time, by TushGuard Modified Text on 4/11/2025

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

(Summon(s))

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

RESPONSE in Opposition re [19] Plaintiff's MOTION for Extension of Time to Extend Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines filed by TushGuard. Replies due by 4/21/2025.

Exhibit A- Def's Accused Product

Exhibit B- Def's Patent

Exhibit C- `512 Utility Patent

Joint MOTION to Modify TRO Order [DE 14] re [20] Order on Motion for Extension of Time, by TushGuard.

Clerk's Notice to Filer re [37] Joint MOTION to Modify TRO Order [DE 14] re [20] Order on Motion for Extension of Time. Docket Text Does Not Match Document; ERROR - The Filer failed to enter a title in the docket text that matches the title of the document. The correction was made by the Clerk. It is not necessary to refile the document.

NOTICE of Striking [37] Joint MOTION of Modifying Funds Restrained filed by TushGuard by TushGuard

Joint MOTION to Modify TRO re [20] Order on Motion for Extension of Time, Regarding Asset Restraint by TushGuard.

Clerk's Notice to Filer re [40] Joint MOTION to Modify TRO re [20] Order on Motion for Extension of Time, Regarding Asset Restraint. Docket Text Does Not Match Document; ERROR - The Filer failed to enter a title in the docket text that matches the title of the document. The correction was made by the Clerk. It is not necessary to refile the document.

ORDER granting [37] Joint Motion to Modify Funds Restrained. Signed by Judge Roy K. Altman on 4/14/2025. See attached document for full details.

AFFIDAVIT in Support of Response to Motion for Preliminary Injunction signed by: Lin Yuwen re 36 Response in Opposition to Motion, by TushGuard

ORDER granting 40 Joint Motion for Entry of Order Modifying Asset Restraint. Signed by Judge Roy K. Altman on 4/14/2025. See attached document for full details.

RESPONSE in Opposition re 19 Plaintiff's MOTION for Extension of Time to Extend Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines filed by Shouken, EVEME US, TONINT. Replies due by 4/22/2025.

Exhibit A-Shouken Accused Products

Exhibit B- EVEME US Accused Product

Exhibit C- TONINT Accused Product

Exhibit D- `512 Utility Patent

(Exhibit E- `977 utility Patent)

RESPONSE in Opposition re 19 Plaintiff's MOTION for Extension of Time to Extend Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines filed by nasite. Replies due by 4/22/2025.

Exhibit A- Nasite Accused Product

Exhibit B- `512 Utility Patent

(Exhibit C- `977 Utility Patent)

PAPERLESS ORDER VACATING 42 Order granting 37 "Joint" Motion for Modifying Asset Restraint (the "Motion"). The Order was docketed in error. The Clerk of Court is hereby DIRECTED to VACATE the Order. We add that defense counsel for the Defendant TushGuard (Doe 51 on Schedule A) filed a 39 Notice of Striking the 37 Motion and says that the allegedly "Joint" Motion was actually "not approved by Plaintiff and listed the incorrect Notice Attorney of Record for Plaintiff." Notice of Striking at 1. That's despite defense counsel designating the Motion as "Joint" and including the Plaintiff's signature. See Mot. at 1-2. Defense counsel also admits that he didn't "properly confer[ ] with" the Plaintiff before filing it. See Notice of Striking at 1. That's sanctionable conduct. We warn defense counsel that we will sanction him for any future misrepresentations. Signed by Judge Roy K. Altman on 4/15/2025. (rr01)

MOTION for clarification 47 Order, by Jianyin Liu. Attorney Jianyin Liu added to party Jianyin Liu(pty:ip). Responses due by 4/29/2025.

PAPERLESS ORDER GRANTING [48] Motion for Clarification (the "Motion"). We accept defense counsel's explanation for the filing of the [37] first Motion for Asset Modification as a "clerical error." Mot. at 1. Signed by Judge Roy K. Altman on 4/16/2025. (rr01)

PAPERLESS Minute Entry for proceedings held before Judge Roy K. Altman: Status Conference held on 4/16/2025. Total time in court: 0 hour(s) : 8 minutes. Attorney Appearance(s): Jianyin Liu, Leigh Benjamin Salomon, Court Reporter: Francine Salopek, 305-301-3276 / mjsfcs@aol.com. (rr01)

PAPERLESS ORDER. "[A] preliminary injunction is an extraordinary and drastic remedy not to be granted unless the movant clearly established the burden of persuasion as to each of the four prerequisites." Four Seasons Hotels & Resorts, B.V. v. Consorcio Barr, S.A., 320 F.3d 1205, 1210 (11th Cir. 2003) (quoting McDonald's Corp. v. Robertson, 147 F.3d 1301, 1312 (11th Cir. 1998) (cleaned up)). And, as the parties are no doubt aware, "where [the] facts are bitterly contested and credibility determinations must be made to decide whether injunctive relief should issue, an evidentiary hearing must be held." Four Seasons, 320 F.3d at 1211 (quoting McDonald's Corp., 147 F.3d at 1312). The parties dispute a great many things in this trademark- and patent-infringement case, including whether, why, and to what extent consumers might confuse the Defendants' products for the Plaintiff's, whether the Defendants intended to infringe the Plaintiff's marks and products, whether the Plaintiff's products in fact have secondary meaning, whether each side has valid patents, and so on. These disputes pertain to each side's likelihood of success on the merits. And, at the April 16, 2025, hearing in this matter, it appeared as though the parties disputed the harm sustained or faced by the Plaintiff, including whether the Plaintiff is in fact losing business opportunities and goodwill in the market for its product, whether its control over its brand is in fact impaired, and the degree to which it's already incurred any damages. These disputes pertain to the likelihood of irreparable harm and the balance of hardships. We therefore direct the parties to be prepared to present fact and expert witnesses at the preliminary injunction hearing as necessary to establish their right to--or their right to be free from--injunctive relief. Although we're mindful that injunctions are "drastic" remedies, we keenly appreciate the public's interest in being protected from misleading and infringing products. Chanel, Inc. v. besumart.com, 240 F. Supp. 3d 1283, 1291 (S.D. Fla. 2016) ("The public interest supports issuance of a[n] [ ] injunction against Defendants to prevent consumers from being misled by Defendants' products."). Accordingly, we expect the parties to ensure that we're able to render an informed decision in this matter. Signed by Judge Roy K. Altman on 4/17/2025. (rr01)

Summons (Affidavit) Returned Executed

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): Changsha Haocheduo Automobile Sales Co., Ltd., Changzhou Daomeng Technology Co., Ltd., Huai'an Snobie Import and Export Co.,LTD, Nantong Lanhurong Textile Technology Co., Ltd., Ningbo Mr. Dream Trading Co., Ltd., Shenzhen Leadfar Industry Co., Ltd., Xiamen Kangkang Technology Co., Ltd., Yiwu Yinba Daily Necessities Firm, 5 Cn1086289450fxaae Store, AIWILL Official Store, Chifeiyang Artistic Life Store, Elegant Department Store, Enipate Warm Store, KAISEFU Store, Kid-Three Store, Miss Wendy Toy Box Store Store, Molly Home Department Store, NAN Factory Store, Shanhao Store, ZIShan Store, BBright US, BICMTE-US, bingyee, Cclub, Compatible models, EVEME US, Fheng USA, FJFHXHOME, FJSYHOME, Gulymm US, Hanchuan, Horizon_Goods_Co., Hrc qvzp, Jgroup, JunAO-US, Laniwyn Store, MANYO, nasite, NiuZhuoQiuQiCaiMaoYiYouXianGongSi, Shouken., The Hive Comfort Zone, TONINT, TushGuard, VIGASZEN Direct, XINLIFE US, Yichengmaoyi, Yimiyaa, xrxl, 508home, 99lowry.cart, Amazingstuff69, ammatas89, asaf00001 (gentleman-store), asna-5444, avital1995, brightfail1999 (brightfai99-0), calevy0, chioweonline, crazy-printing, eranrajap-0, factory*wholesalestore (big*seller), Fashion*Factory*Shop (origin_1274), gedalia_42, goodthings*sharing*shop (yang0yy), happystore808, hehede99, igabr79, kobe345-7, lemoautoparts2019, lemohomegarden2019, lowcostshops, manjokepro, manjokestore (manjoke), meilidongren2008, More Persi (rozigila), music-store-japan, nabe_4983, noakore, official_shop_bonusversus6, om-6369, outdoor*wholesalestore (toy*home), QualityFinds212, run_shop, santa-home, santahome99 (vickyhome), shmuel120, si-5811, sj_store321, stop-a-shop, toleyi_0, usa-best-deal, vo_8941, wody365, ygh_54, yoyohub.Korea (korean_one_stop), baobaocheng, Chuanghaojia, COLMO US, guangzhouyingguang, GUANPIN, Naciey-YY, NZM-ZZ, Real Tone, Tp-AA, AiDream, BeautyQueen JC, BIGPANDAS SHOP, CEMRAKINE Boutique, CYX ILIFE, DealShop, disuxdsshop, Eel outdoor, HUANGDANWU, Huiyuanyoupin, InnovativeSpot, JIATIANN, Jing Jing Beauty, jinxuan Competitive products, KUMORE TOOLS, Nc Bestseller, Neck friends, NOVEL HOMES, Ohlin, Qingyuyouchuang, RuntoXY, Smile happy home cosmetic shop, Strange clouds A, superWei, WCCTV, YIDACONG SHOP, znxiaodian, AutoGears Pro, BLIBLIUNIT, Cromar, Doctorsdeals, FortuneBloom, goodssky, GuangZhouPinBo, HUANGBAOKEJI, IRmm Co.ltd, JIAYANG Co.Ltd, JINGJING Co.Ltd, JIONGJING Co.Ltd, Juzhonghe, Kwality Dealz, LGJ, liupingyinshangmao, Qzuitopz, SCQCFW, SHENGMAN Co.Ltd, Tiptoop, Today topo, VIVIDCRAFT-L, xiangtancikeli, XIONGDI Co.Ltd, yangmingmaoying, YGKJYXGS, YUANEN Co.Ltd, Zacfeain, ZAIWEN Co.Ltd and zhongshanshidingjimo.

Plaintiff's MOTION to Unseal Document by Purple Innovation, LLC. Responses due by 5/2/2025.

Text of Proposed Order

NOTICE of Settlement with Defendant Nos. 27 (EVEME US), 44 (nasite), 47 (Shouken), 50 (TONINT), and 51 (TushGuard) by Purple Innovation, LLC

PAPERLESS ORDER. The preliminary injunction hearing in this case is RESET to April 24, 2025, at 11:00 a.m. Our temporary restraining order [ECF No. 14 ] shall remain in effect until April 24, 2025. (rr01) (Text entry; no document attached.)

PAPERLESS ORDER GRANTING 54 Motion to Unseal. The Clerk of Court is DIRECTED to unseal all documents that have been restricted/sealed. Signed by Judge Roy K. Altman on 4/20/2025. (rr01)

NOTICE of Withdrawing Response in Opposition by nasite re [46] Response in Opposition to Motion

NOTICE of Withdrawing Response in Opposition [DE 45] by Shouken, EVEME US, TONINT, Shouken. re [45] Response in Opposition to Motion. Attorney Jianyin Liu added to party, Attorney Jianyin Liu added to party, Attorney Jianyin Liu added to party.

NOTICE of Voluntary Dismissal of Defendant Nos. 27 (EVEME US), 44 (nasite), 47 (Shouken.), 50 (TONINT) by Purple Innovation, LLC

NOTICE of Withdrawing Response in Opposition [DE 36] and Affidavit [DE 43] by TushGuard re 43 Affidavit, 36 Response in Opposition to Motion

NOTICE of Voluntary Dismissal of Defendant No. 51 (TushGuard) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant Nos. 151 (JIAYANG Co.Ltd), 152 (JINGJING Co.Ltd), 153 (JIONGJING Co.Ltd), 160 (SHENGMAN Co.Ltd), 165 (XIONGDI Co.Ltd), 168 (YUANEN Co.Ltd), and 170 (ZAIWEN Co.Ltd) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant Nos. 11 (Chifeiyang Artistic Life Store) and 77 (igabr79) by Purple Innovation, LLC

CERTIFICATE OF SERVICE by Purple Innovation, LLC re Court's April 19, 2025, Paperless Order Resetting Plaintiff's Preliminary Injunction Hearing and Extending the Temporary Restraining Order to April 24, 2025

PAPERLESS Minute Entry for proceedings held before Judge Roy K. Altman. A Preliminary Injunction Hearing was held on 4/24/2025. Total time in court: 0 hour(s) : 3 minutes. Attorney Appearance(s): Leigh Benjamin Salomon, Court Reporter: Francine Salopek, 305-301-3276 / mjsfcs@aol.com. (rr01)

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 Injunction)

NOTICE of Voluntary Dismissal of Defendant No. 114 (Tp-AA) by Purple Innovation, LLC

Notice of Compliance (Text entry; no document attached.)

CLERK'S NOTICE of Compliance (All Docket Entries that have been Sealed in this Case have been Unsealed) re 56 Order on Motion to Unseal Document

ORDER GRANTING 10 MOTION FOR PRELIMINARY INJUNCTION. Signed by Judge Roy K. Altman on 4/28/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 39 (JunAO-US), 117 (BIGPANDAS SHOP), 125 (InnovativeSpot), and 134 (Qingyuyouchuang) by Purple Innovation, LLC

"STRICKEN" NOTICE of Attorney Appearance by Jianyin Liu on behalf of Fheng USA. Attorney Jianyin Liu added to party. Modified on 5/2/2025 (ls) (per DE #74)

ANSWER and Affirmative Defenses to Complaint with Jury Demand by Fheng USA.

Clerk's Notice to Filer re 71 Notice of Attorney Appearance. Document Not Related to Case; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - Filer must file a Notice of Striking, then refile the document in the appropriate case.

NOTICE of Striking 71 Notice of Attorney Appearance filed by Fheng USA by Fheng USA

NOTICE of Attorney Appearance by Jianyin Liu on behalf of Fheng USA

Status Conference set for 5/27/2025 03:00 PM in Miami Division before Judge Roy K. Altman. Absent good cause, counsel must attend in person at the Wilkie D. Ferguson Jr. U.S. Courthouse, 400 North Miami Avenue Courtroom 12-4, Miami, Florida 33128. Counsel may move to appear remotely by Zoom upon a showing of good cause. If granted permission to attend by Zoom, the Meeting ID is 160 7688 8099. The Passcode is 183310. The Court does not issue a Zoom link. Please access the Zoom meeting by going to Zoom.us (or opening a Zoom app), clicking "join a meeting," and entering the Meeting ID and Passcode. (rr01) (Text entry; no document attached.)

NOTICE of Withdrawing Answer [DE 72] by Fheng USA re 72 Answer to Complaint

NOTICE of Attorney Appearance by Jianyin Liu on behalf of AutoGears Pro, VIVIDCRAFT-L, yangmingmaoying. Attorney Jianyin Liu added to party, Attorney Jianyin Liu added to party, Attorney Jianyin Liu added to party.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, 52 Summons Returned Executed, by AutoGears Pro, VIVIDCRAFT-L, yangmingmaoying.

NOTICE of Voluntary Dismissal of Defendant Nos. 29 (Fheng USA), 63 (asaf00001), 79 (lemoautoparts2019), 80 (lemohomegarden2019), 85 (More Persi), 101 (usa-best-deal), 108 (COLMO US), 121 (disuxdsshop), 141 (znxiaodian), 155 (Kwality Dealz), 158 (Qzuitopz), 159 (SCQCFW), and 169 (Zacfeain) by Purple Innovation, LLC

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by Juzhonghe. Attorney Alan Mensa-Wilmot added to party.

(Text of Proposed Order)

NOTICE of Voluntary Dismissal of Defendant Nos. 26 (Compatible models), 33 (Hanchuan), 53 (XINLIFE US), 135 (RuntoXY), 142 (AutoGears Pro), 163 (VIVIDCRAFT-L), and 166 (yangmingmaoying) by Purple Innovation, LLC

NOTICE of Striking 81 Notice of Voluntary Dismissal filed by Purple Innovation, LLC by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant Nos. 24 (bingyee), 33 (Hanchuan), 53 (XINLIFE US), 135 (RuntoXY), 142 (AutoGears Pro), 163 (VIVIDCRAFT-L), and 166 (yangmingmaoying) by Purple Innovation, LLC

Status Conference/Hearing(s) terminated. (ls)(per DE #84) (Text entry; no document attached.)

PAPERLESS OMNIBUS ORDER. The Motion for Extension 78 is DENIED as moot due to the voluntary dismissal of the movant Defendants. See generally Voluntary Dismissal [ECF No. 83]. The Defendant Juzhonghe's Unopposed Motion for Extension 80 is GRANTED. The Defendant Juzhonghe shall respond to the Complaint by June 16, 2025. The May 27, 2025, status conference is hereby CANCELLED. Signed by Judge Roy K. Altman on 5/26/2025. (rr01)

NOTICE of Voluntary Dismissal of Defendant Nos. 26 (Compatible models), 46 (NiuZhuoQiuQiCaiMaoYiYouXianGongSi), 86 (music-store-japan), and 123 (HUANGDANWU) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant Nos. 73 (gedalia_42) and 109 (guangzhouyingguang) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant No. 138 (superWei) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendants Nos. 71 (factory*wholesalestore (big*seller)), 72 (Fashion*Factory*Shop (origin_1274)), 74 (goodthings*sharing*shop (yang0yy)), 84 (meilidongren2008), 91 (outdoor*wholesalestore (toy*home)), 138 (superWei), and 154 (Juzhonghe) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant No. 145 (Doctordeals) by Purple Innovation, LLC

NOTICE of Voluntary Dismissal of Defendant Nos. 65 (avital1995) and 100 (toleyi_0) by Purple Innovation, LLC

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 91 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 7/7/2025.

ORDER on Default Final Judgment Procedure: Plaintiff's Motion for Default Final Judgment or a Notice of Joint Liability due 7/24/2025; Case Remains Closed. Signed by Judge Roy K. Altman on 7/11/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Nos. 81 (lowcostshops) and 150 (IRmm Co.ltd) by Purple Innovation, LLC

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

Declaration of Leigh Salomon

Exhibit 1 (Part 1 of 4)

Exhibit 1 (Part 2 of 4)

Exhibit 1 (Part 3 of 4)

Exhibit 1 (Part 4 of 4)

Exhibit 2

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

(Text of Proposed Final Default Judgment and Permanent Injunction)

ORDER granting 95 Motion for Default Final Judgment. Closing Case. Signed by Judge Roy K. Altman on 9/2/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT and PERMANENT INJUNCTION in favor of Purple Innovation, LLC against the Defendants, Individuals, Partnerships, or Unincorporated Associations identified on Schedule "A" hereto. Case Remains Closed. Signed by Judge Roy K. Altman on 9/2/2025. See attached document for full details.

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

Text of Proposed Order

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

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

SATISFACTION OF JUDGMENT re 97 Default Judgment, Permanent Injunction, as to Defendant Nos. 113 (Real Tone) and 140 (YIDACONG SHOP) by Purple Innovation, LLC

DISBURSEMENT ORDER. Signed by Judge Roy K. Altman on 9/8/2025. See attached document for full details.