2025-cv-21632

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18354861, filed by DIFOLD INC.

Exhibit 1 to Complaint

(Civil Cover Sheet)

Clerks Notice of Judge Assignment to Judge Beth Bloom. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Marty Fulgueira Elfenbein 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 and Exhibit) (cwc)

Plaintiff's 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)

PAPERLESS ORDER granting 5 Motion to Seal. Signed by Judge Beth Bloom

SYSTEM ENTRY - Docket Entry 7 [misc] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 8 [motion] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 9 [motion] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 10 [order] restricted/sealed until further notice. (Text entry; no document attached.)

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

SYSTEM ENTRY - Docket Entry 12 [order] restricted/sealed until further notice. (Text entry; no document attached.)

NOTICE of Filing Proposed Summons(es) in Compliance with the Court's Sealed Amended 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).

Plaintiff's MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, and Extend the Briefing Deadlines (Responses due by 5/1/2025.), MOTION to Reschedule PI Hearing by DIFOLD INC.

Affidavit Declaration of Nicole Fundora ISO Motion to Extend TRO and Reschedule PI Hearing

(Text of Proposed Order)

Clerks Receipt for bond for TRO per order of the court (DE#12)sealed received on 4/18/2025 in the amount of $ 5,000.00, receipt number FLS301390 Difold, Inc.

ORDER on Motion to Extend Ex Parte Temporary Restraining Order And Continue Hearing. Plaintiff's Motion, ECF No. 16, is GRANTED. (Motion Hearing set for 5/6/2025 11:30 AM in Miami Division before Judge Beth Bloom.) Signed by Judge Beth Bloom on 4/18/2025. See attached document for full details.

Order to Unseal. The Clerk of Court is directed to UNSEAL all docket entries in this action and return those portions of the Court file to the public records. Signed by Judge Beth Bloom on 4/24/2025.

Clerk's Notice Regarding DE [19] Order. Order to Unseal Docketed at DE [19] by Clerk.

CLERK'S NOTICE of Compliance by Unsealing Documents pursuant to DE [19] Order.

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 5/1/2025, response/answer due 5/22/2025.

(Exhibit Schedule A- list of defendants served)

NOTICE of Filing Proposed Order on Plaintiff's Motion for Preliminary Injunction by DIFOLD INC.

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): 1st Heaven, Bufan life, Chairlish, Champion ma, ChaoJianCS, ChenyiLtd, Cloud sail Trading, CXirrben, DaiHuiH, DuYaNanSHOP, Emberland, feiluojiastore, fufengzhubao, FUYU, GuoChenG, HanDeWanChangShangMaoYouXianGongSi, histarstore5, Hkm000623, laishengagawei, LeiTeKaiS, Liuxiangzhen SHOP, LUXYANSTORE, Marutatsu Tokyo, Mooney department store, mubujiankeji, richabb, SANLUNS Shop, Shaanxi Guangnian Ruomeng Trading Co., Ltd., shidanshanmao, SPECIAL MADE, TongMall, TREEAV, VVLifeStyle, Waqas khalid, WET ONLINE STORE, WFHCPY, WZZus, XiAnLuoKeShangMaoYouXianGongSi, Xushiyijia, yixinzs, ZhaoxingLtd, ZhengYaoBH, ZhengZhouBenBenMiaoShangMaoYouXianGongSi, ZhuRao, zukaain, azabub33, fodje-3, gvge3483, hikonidasstore, homedecor2380, jiey41, lalehars_0, lifen-30, liuhualin, lo617651, master_made, maweera_53, min-fara, nguydu1740, pathusamarakoo0, pineagonstore, pst81hj60, qm1268, racccoonn, ranafatoni, saashop24, samersahouri27, sfbpp88, shaiq_7196, shopeko, trendy-edges, triergenix15, trndspshop, valov-21, vivart_4125, BAIJIAYUN, Benny Cup, Kezhuluo, Like camping, MENGJIN1, Radiant Fusion, SW, TextileNest, WEIJIESIHOME, World Cup, YanXi Marketplace, yi wu shen nuo mao yi you xian gong si, Yin yi1, YOCITY CS, yuunii, Jiming Cycling Supplies, Lovely Bunny, Sunkissed, HengJia, KQPOINW, miaoyou, shengsuosi industry, Shenzhen Yishan Co.,ltd, Trendy Mall, VIta Home&Decor, wangxiaozhe, ZAICHEN and ZIWEN Co.Ltd.

PAPERLESS Minute Order for proceedings held before Judge Beth Bloom: re ECF No. 8 Plaintiff's Motion for a Preliminary Injunction. For the reasons stated on the record, the Motion is granted. Written order to follow. Total time in court: 7 minutes. Attorney Appearances: Leigh Benjamin Salomon. Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov. (ap01)

ORDER ON PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION re 8 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Internet Stores, a Temporary Asset Restraint, and Expedited Discovery filed by DIFOLD INC. is GRANTED. Signed by Judge Beth Bloom on 5/6/2025. See attached document for full details.

ANSWER to Complaint by 1st Heaven. (Address Updated)

Plaintiff's MOTION to Strike [28] Answer to Complaint by DIFOLD INC. Responses due by 5/30/2025.

Text of Proposed Order

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 Defendants Only by DIFOLD INC.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by DIFOLD INC.

ANSWER to Complaint by TongMall.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by DIFOLD INC.

Plaintiff's MOTION to Strike [34] Answer to Complaint and Require Corporate Defendant to Retain Counsel by DIFOLD INC. Responses due by 6/10/2025.

Text of Proposed Order

ORDER OF DISMISSAL AS TO CERTAIN DEFENDANTS WITHOUT PREJUDICE. Like camping, SW, TextileNest, VIta Home&Decor, WEIJIESIHOME, 1st Heaven and Emberland Signed by Judge Beth Bloom on 5/27/2025. See attached document for full details.

ORDER ON PLAINTIFF'S MOTION TO STRIKE re 29 Motion to Strike. Defendant 1st Heaven's Answer, DE 28, is STRICKEN. Deadline to obtain new counsel 6/11/2025. Signed by Judge Beth Bloom on 5/28/2025. See attached document for full details.

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.

ANSWER and Affirmative Defenses to Complaint by azabub33. (Address Updated)

Plaintiff's MOTION to Strike [44] Answer to Complaint by DIFOLD INC. Responses due by 6/25/2025.

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.

MOTION for Clerk's Entry of Default as to BAIJIAYUN, Benny Cup, Bufan life, CXirrben, Chairlish, ChaoJianCS, Cloud sail Trading, DaiHuiH, DuYaNanSHOP, FUYU, GuoChenG, HanDeWanChangShangMaoYouXianGongSi, HengJia, Hkm000623, Jiming Cycling Supplies, KQPOINW, Kezhuluo, LUXYANSTORE, LeiTeKaiS, Liuxiangzhen SHOP, Lovely Bunny, MENGJIN1, Mooney department store, Radiant Fusion, SPECIAL MADE, Shaanxi Guangnian Ruomeng Trading Co., Ltd., Sunkissed, TREEAV, VVLifeStyle, WET ONLINE STORE, WFHCPY, WZZus, Waqas khalid, World Cup, XiAnLuoKeShangMaoYouXianGongSi, Xushiyijia, YOCITY CS, YanXi Marketplace, Yin yi1, ZIWEN Co.Ltd, ZhaoxingLtd, ZhengYaoBH, ZhengZhouBenBenMiaoShangMaoYouXianGongSi, ZhuRao, feiluojiastore, fodje-3, fufengzhubao, gvge3483, hikonidasstore, histarstore5, homedecor2380, jiey41, laishengagawei, lalehars_0, lifen-30, liuhualin, lo617651, master_made, maweera_53, miaoyou, mubujiankeji, nguydu1740, pathusamarakoo0, pineagonstore, qm1268, racccoonn, richabb, saashop24, samersahouri27, sfbpp88, shaiq_7196, shengsuosi industry, shidanshanmao, shopeko, trendy-edges, triergenix15, trndspshop, valov-21, vivart_4125, wangxiaozhe, yi wu shen nuo mao yi you xian gong si, yixinzs, yuunii, zukaain by DIFOLD INC.

(Affidavit Declaration of Nicole Fundora ISO Request for Entry of Clerk's Default)

Clerk's Entry of Default as to BAIJIAYUN, Benny Cup, Bufan life, CXirrben, Chairlish, ChaoJianCS, Cloud sail Trading, DaiHuiH, DuYaNanSHOP, FUYU, GuoChenG, HanDeWanChangShangMaoYouXianGongSi, HengJia, Hkm000623, Jiming Cycling Supplies, KQPOINW, Kezhuluo, LUXYANSTORE, LeiTeKaiS, Liuxiangzhen SHOP, Lovely Bunny, MENGJIN1, Mooney department store, Radiant Fusion, SPECIAL MADE, Shaanxi Guangnian Ruomeng Trading Co., Ltd., Sunkissed, TREEAV, VVLifeStyle, WET ONLINE STORE, WFHCPY, WZZus, Waqas khalid, World Cup, XiAnLuoKeShangMaoYouXianGongSi, Xushiyijia, YanXi Marketplace, ZIWEN Co.Ltd, ZhaoxingLtd, ZhengYaoBH, ZhengZhouBenBenMiaoShangMaoYouXianGongSi, ZhuRao, feiluojiastore, fodje-3, fufengzhubao, gvge3483, hikonidasstore, histarstore5, homedecor2380, jiey41, laishengagawei, lalehars_0, lifen-30, liuhualin, lo617651, master_made, maweera_53, miaoyou, mubujiankeji, nguydu1740, pathusamarakoo0, pineagonstore, qm1268, racccoonn, richabb, saashop24, samersahouri27, sfbpp88, shaiq_7196, shengsuosi industry, shidanshanmao, shopeko, trendy-edges, triergenix15, trndspshop, valov-21, vivart_4125, wangxiaozhe, yi wu shen nuo mao yi you xian gong si, yixinzs, yuunii, zukaain - Motions Terminated: [48] Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 6/25/2025.

NOTICE of Voluntary Dismissal as to Certain Defendant 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 identifying the specific patents infringed and the calculated dama

Affidavit Declaration of Nicole Fundora ISO Motion for Default

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

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

Exhibit Exhibit 2 to Declaration of Nicole Fundora

Text of Proposed Order

Text of Proposed Order

ORDER ON DEFAULT JUDGMENT PROCEDURE. (Responses due by 7/25/2025.) Signed by Judge Beth Bloom on 6/25/2025. See attached document for full details.

Opposition re [45] Plaintiff's MOTION to Strike [44] Answer to Complaint filed by azabub33. Replies due by 7/7/2025.

MOTION for Leave to File Late Answer by pineagonstore.

Letter

ORDER ON DEFENDANT'S MOTION FOR LEAVE TO FILE LATE ANSWER. Plaintiff's Motion, DE [54], is DENIED. Signed by Judge Beth Bloom on 6/30/2025. See attached document for full details.

ORDER ON PLAINTIFF'S MOTION TO STRIKE. Plaintiff's Motion to Strike, DE[36], is GRANTED. Defendant TONGMALL's Answer, DE [34], is STRICKEN. Signed by Judge Beth Bloom on 6/30/2025. See attached document for full details.

ORDER ON PLAINTIFF'S MOTION TO STRIKE. Plaintiff's Motion, DE [45], is GRANTED.Defendant azubab33's Answer, DE [44], is STRICKEN. Signed by Judge Beth Bloom on 6/30/2025. See attached document for full details.

ANSWER and Affirmative Defenses to Complaint by CXirrben.

Plaintiff's MOTION to Strike [58] Answer to Complaint and Require Corporate Defendant to Retain Counsel by DIFOLD INC. Responses due by 7/15/2025.

Text of Proposed Order

NOTICE of Voluntary Dismissal as to Certain Defendants Only by DIFOLD INC.

Text of Proposed Order

Plaintiff's MOTION for Clerk's Entry of Default as to azabub33, pineagonstore by DIFOLD INC.

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

Clerk's Entry of Default as to azabub33, pineagonstore - Motions Terminated: [61] Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 7/9/2025.

ORDER ON MOTION FOR DEFAULT JUDGMENT. Plaintiff's Motion DE [51], is DENIED. Signed by Judge Beth Bloom on 7/12/2025. See attached document for full details.

ORDER ON PLAINTIFF'S MOTION TO STRIKE re DE [59], is GRANTED. Defendant CXirrben's Answer, DE [58], is STRICKEN. Signed by Judge Beth Bloom on 7/12/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Certain Defendant Only by DIFOLD INC.

Renewed MOTION for Default Judgment by DIFOLD INC.

Exhibit Schedule A - list of Defaulting Defendants

Exhibit Exhibit 1 to Renewed Motion for Default

Affidavit Declaration of Nicole Fundora ISO Renewed Motion for Default

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

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

Exhibit Exhibit 2 to Declaration of Nicole Fundora

Text of Proposed Order

Text of Proposed Order

MOTION to Set Aside Clerk's Entry of Default by pineagonstore.

MOTION to Vacate 57 Order on Motion to Strike by azabub33. Responses due by 7/31/2025.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by DIFOLD INC.

PAPERLESS ORDER denying as moot [67] Motion to Set Aside Default. See ECF No. [69]. Signed by Judge Beth Bloom

MOTION to Set Aside Clerk's Entry of Default and to Dismiss the Complaint [62] Clerk's Entry/Non-Entry of Default (Responses due by 8/11/2025.) by azabub33.

Plaintiff's MOTION to Strike [71] MOTION to Set Aside Default MOTION to Dismiss [62] Clerk's Entry/Non-Entry of Default by DIFOLD INC. Responses due by 8/14/2025.

Text of Proposed Order

ORDER TO SHOW CAUSE that on or before August 20, 2025, Plaintiff shall show cause as to why the Court should not grant Defendant's Motion, ECF No. [71], and deny Plaintiff's Motion to Strike, ECF No. [72]. Signed by Judge Beth Bloom on 8/13/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Certain Defendant Only by DIFOLD INC.

PAPERLESS ORDER denying as moot ECF No. [68] Defendant azabub33's ("Defendant") Motion to Vacate, ECF No. [71] Defendant's Motion to Set Aside Default and to Dismiss Complaint, and ECF No. [72] Plaintiff's Motion to Strike. Plaintiff voluntarily dismissed its claims against Defendant on August 15, 2025. See ECF No. [74]. Signed by Judge Beth Bloom (ap01)

Order of Dismissal as to Certain Defendants re [77] Notice of Voluntary Dismissal; Dismissing Case without prejudice as to the Defendants listed in the Notice. Signed by Judge Beth Bloom on 8/22/2025. See attached document for full details.

ORDER ON RENEWED MOTION FOR ENTRY OF FINAL DEFAULT JUDGMENT re [66] Motion. Plaintiff's Motion is GRANTED against the Defaulting Defendants listed in the attached Schedule A. Signed by Judge Beth Bloom on 9/8/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A against BAIJIAYUN, Chairlish, ChaoJianCS, Cloud sail Trading, DaiHuiH, DuYaNanSHOP, FUYU, GuoChenG, HengJia, Hkm000623, Jiming Cycling Supplies, KQPOINW, LUXYANSTORE, LeiTeKaiS, Liuxiangzhen SHOP, Lovely Bunny, MENGJIN1, Mooney department store, Radiant Fusion, Shaanxi Guangnian Ruomeng Trading Co., Ltd., Sunkissed, VVLifeStyle, WET ONLINE STORE, WFHCPY, WZZus, Waqas khalid, XiAnLuoKeShangMaoYouXianGongSi, Xushiyijia, YOCITY CS, YanXi Marketplace, Yin yi1, ZIWEN Co.Ltd, ZhaoxingLtd, ZhengYaoBH, ZhengZhouBenBenMiaoShangMaoYouXianGongSi, ZhuRao, feiluojiastore, fodje-3, fufengzhubao, gvge3483, hikonidasstore, homedecor2380, jiey41, laishengagawei, lalehars_0, lifen-30, liuhualin, master_made, maweera_53, miaoyou, mubujiankeji, nguydu1740, pathusamarakoo0, qm1268, racccoonn, richabb, saashop24, samersahouri27, sfbpp88, shaiq_7196, shengsuosi industry, shidanshanmao, shopeko, trendy-edges, triergenix15, trndspshop, valov-21, vivart_4125, wangxiaozhe, yixinzs, yuunii, zukaain; in favor of The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A against SPECIAL MADE; in favor of The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A against Kezhuluo; in favor of The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A against World Cup; in favor of The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A against yi wu shen nuo mao yi you xian gong si. The Clerk shall CLOSE the case. Signed by Judge Beth Bloom on 9/8/2025. See attached document for full details.

Plaintiff's MOTION for Disbursement of Funds Return of Bond by DIFOLD INC.

Text of Proposed Order