2025-cv-21710

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18366417, filed by The Kyjen Company, LLC.

Exhibit 1 - Trademarks

Exhibit 2 - Patents

Exhibit 3 - Copyright

(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

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by The Kyjen Company, LLC

Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support by The Kyjen Company, LLC.

Declaration of Valeria Munoz

Exhibit 1

(Text of Proposed Order) Modified to Unseal per DE 34 on 5/28/2025 (amb)

Plaintiff's MOTION for Leave to File Excess Pages by The Kyjen Company, LLC.

(Text of Proposed Order)

Plaintiff's MOTION to Seal per Local Rule 5.4 by The Kyjen Company, LLC.

(Text of Proposed Order)

PAPERLESS ORDER GRANTING the Plaintiff's 6 Ex Parte Motion to Exceed Page Limitation. The Plaintiff may file its twenty-four-page Ex Parte Motion for Entry of a Temporary Restraining Order. Signed by Judge Roy K. Altman on 4/17/2025. (es00)

Order in Cases with Multiple Defendants Signed by Judge Roy K. Altman on 4/23/2025. See attached document for full details.

ORDER granting 7 Motion to Seal. Signed by Judge Roy K. Altman on 4/23/2025. See attached document for full details.

ORDER granting 5 Ex Parte Motion. Signed by Judge Roy K. Altman on 4/23/2025. See attached document for full details. (amb) Modified to Unseal per DE 34 on 5/28/2025

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, A Temporary Asset Restraint, and Expedited Discovery by The Kyjen Company, LLC.

Declaration of Evanka Herbers

Exhibit 1 - Trademarks

Exhibit 2 - Patents

Exhibit 3 - Copyright

Exhibit 4 (Part 1 of 14)

Exhibit 4 (Part 2 of 14)

Exhibit 4 (Part 3 of 14)

Exhibit 4 (Part 4 of 14)

Exhibit 4 (Part 5 of 14)

Exhibit 4 (Part 6 of 14)

Exhibit 4 (Part 7 of 14)

Exhibit 4 (Part 8 of 14)

Exhibit 4 (Part 9 of 14)

Exhibit 4 (Part 10 of 14)

Exhibit 4 (Part 11 of 14)

Exhibit 4 (Part 12 of 14)

Exhibit 4 (Part 13 of 14)

Exhibit 4 (Part 14 of 14)

(Text of Proposed Temporary Restraining Order) Modified to Unseal per DE 34 on 5/28/2025 (amb)

Sealed Document - Notice of Filing Schedule A Under Seal re DE# 10 Order on Motion to Seal by The Kyjen Company, LLC.

(Schedule A to Complaint) Modified to Unseal per DE 34 on 5/28/2025 (amb)

SEALED ORDER granting 12 Ex Parte Motion. Preliminary Injunction Hearing set for 5/6/2025 01:45 PM in Miami Division before Judge Roy K. Altman. Responses due by 5/2/2025. Replies due by 5/5/2025. Signed by Judge Roy K. Altman on 4/30/2025. See attached document for full details. (amb) Modified to Unseal per DE 34 on 5/28/2025

NOTICE of Filing Proposed Summons(es) by The Kyjen Company, LLC

(Summon(s))

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 The Kyjen Company, LLC. Responses due by 5/15/2025.

Declaration of Valeria Munoz

(Text of Proposed Order)

PAPERLESS ORDER GRANTING the Plaintiff's 16 Motion for Extension of TRO and PI Hearing. The PI hearing in this matter is RESET for May 20, 2025, at 1:45 p.m. Any Defendant who wishes to oppose the Plaintiff's 12 Motion for a Preliminary Injunction must do so by May 14, 2025. The Plaintiff must file any reply in support of its Motion by May 19, 2025. Finally, the temporary restraining order we 14 entered in this matter is hereby extended through May 20, 2025. Signed by Judge Roy K. Altman on 5/2/2025. (es00)

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

PAPERLESS ORDER RESETTING HEARING. The PI hearing in this matter is RESET for May 27, 2025, at 3:00 p.m. Any Defendant who wishes to oppose the Plaintiff's 12 Motion for a Preliminary Injunction must do so by May 19, 2025. The Plaintiff must file any reply in support of its Motion by May 23, 2025. Finally, the temporary restraining order we 14 entered in this matter is hereby extended through May 27, 2025. Signed by Judge Roy K. Altman on 5/5/2025. (es00)

Notice of Posting Bond in the amount of $10,000.00 posted by The Kyjen Company, LLC Approved by Judge Roy K. Altman (pc) (Additional attachment(s) added on 5/6/2025: # 1 Receipt)

NOTICE of Attorney Appearance by Leslie Rafalli Gillis on behalf of dechong. Attorney Leslie Rafalli Gillis added to party dechong(pty:dft).

(STRICKEN) MOTION motion to dissolve tro by dechong.

(Affidavit in support of) Modified per de 25 on 5/21/2025 (pc)

AFFIDAVIT signed by: (revised) lily dechong re 22 MOTION motion to dissolve tro by dechong

NOTICE of Voluntary Dismissal of Defendant Nos. 55 (LuckyOK), 141 (Good products are here), and 142 (Good Products Are Worth Having) by The Kyjen Company, LLC

PAPERLESS ORDER STRIKING Defendant dechong's 22 Motion to Dissolve TRO. Local Rule 7.1(a)(2) requires every movant to certify that it conferred (or attempted to confer) with the other parties in this case "prior to filing any motion." There's an exception for motions that seek injunctive relief, but a motion to dissolve a TRO doesn't qualify. The Defendant may confer with the Plaintiff and refile its motion by May 21, 2025. Because the PI hearing in this matter is set for May 27, 2025, at 3:00 p.m., and because the Defendant's bases for dissolving the TRO overlap almost entirely with its opposition to the 12 PI Motion, the Plaintiff's combined response/reply to the Motion to Dissolve TRO is due by May 23, 2025. Signed by Judge Roy K. Altman on 5/20/2025. (es00)

RESPONSE in Opposition re 22 MOTION motion to dissolve tro (with required conference declaration) filed by dechong. Replies due by 5/28/2025.

MOTION to request leave to appear telephonically by dechong.

PAPERLESS ORDER GRANTING Defendant dechong's 27 Unopposed Motion to Appear Remotely. The Defendant may appear remotely by Zoom at the hearing we've set in this matter for May 27, 2025, at 3:00 p.m. ET. To appear remotely, the Defendant should go to Zoom.us (or open a Zoom app), click "join a meeting," and enter 160 7688 8099 as the Meeting ID and 183310 as the Passcode. Signed by Judge Roy K. Altman on 5/23/2025. (es00)

RESPONSE in Opposition re 22 MOTION motion to dissolve tro filed by The Kyjen Company, LLC. Replies due by 5/30/2025.

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by The Kyjen Company, LLC. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 5/16/2025, response/answer due 6/6/2025.

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): Jiangsu Zotia Houseware Co., Ltd., Aluckmao, Animire, Bala Information, dechong, Doversky, Freefa Manufacturer, Fur & Tech, Guiyunjian, HiNoKi, HollowBall, huaibeihuiyibaihuo, huangqiucen, JenililyDirect, kellyiii, lan ting mao yi, ledorr, Maintain77, Mooela, MY01, nahangkeji, panlinshandongguituwenhuachuan, PetHse, R-lian, Shaww Juu, taiyuanfanyishushangmaoyouxiangongsi, Tjsouler Pet Store, XIGOU, Yingying Official Store, ZFJ-FAFA, danuo, ddmyjun, dhpetcl (dh1102211293), dhpetey (dh1100391878), hui2hao, jiu10, liuyier, pet_toy1, petchains, zzhomefashion, dib-bid, home_oasiss, My Happy box 01 (myhappy_40), pempet_official, xiaxue (weni6_5), April Fashion Jewelry, ATDV, Chen Pingguo Beauty Collection, CJJ PET, Coffeemate, Dexter, DreTup, HAISSKY motorcycle parts, happiness in life, Moffey Shopping, Mr xiew, Ningbo jiamin Pets, Out of circle, Pet Supplies QingYu, Sengu pet supplies, Soul Pet, SWEET pep, TDC PET, The Kings pet world, The Silk Road, WINGPET, XinFu Yuan, Zezili, zhenjiuyouxuan, ADHYRO, AirBelle, ashcjgtfONQ, Baishenghong, Ball King Girl Store, beiweidianzi, Brother Teddy, Caizhitong Trading Co., Ltd., chenyanmaoyi, denggudianzi, dfgdfghdfgdfgd, FANGQU Co.Ltd, FENGYAN Co.Ltd, fengyuewenhua, foshanshidiaofudaoshangmao, foshanshijiaojingfengmaoyi, foshanshiqitongqishangmao, foshanshiwanxinxiaoshangmao, guangzhouyuchengshiyemaoyiyouxiangongsi, GZLY Co.,Ltd, GZSL Co.,LTD, GZYNH Co.,LTD, haibingchuangkeji, Hesheng2023, HESHU Co.Ltd, hongchuangyiqi, huanrushangmao, ixinjidianshe, jiejiehongyunshangmao, JIJI Co.Ltd, jinkunpengruijianshe, Kerr Good Store, liboshangmaa, LittlethingSTR, LYMZ Co.Ltd, mengguawangluo, mizhejiaoshangmao, NewSoul, Our Story, pobucishangmao, SCQCFW, shen zhen chao fan jie mao yi you xian gong si, shenglixiaopu, Shuzhi Small Shop, Siateml, Sokhug, sparkling001, VORCOY, weikewulianjishugongsi, weizhuqianshangmao, wu han xin yi tong wang luo ke ji you xian gong si, Xiao market, xiaxiaotingshangmao, XIJIA, xingmengyuanmaoyi, XTCXJC, XW BALD EAGLE, Yanna, yehaoshangmaoyouxiangongsi, YGKJYXGS, yichangshihengyaan, Yicmeid, yilanxianxianghu Co. Ltd, Youpinhuijiajuyongpinltd, Zabbiam, ZenithDaily Decor, Zhensu trading co., ltd, ZhongXiangShi, ZYLYY and Jeffrey Big Shop.

Plaintiff's MOTION to Unseal Document by The Kyjen Company, LLC. Responses due by 6/6/2025.

(Text of Proposed Order)

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of FANGQU Co.Ltd. Attorney Andrew Jonathan Palmer added to party.

PAPERLESS ORDER GRANTING the Plaintiff's 32 Motion to Unseal. We DIRECT the Clerk of Court to unseal docket entries 5, 11, 12, 13, and 14. Signed by Judge Roy K. Altman on 5/27/2025. (es00)

Plaintiff's NOTICE of Filing Proposed Order Granting Plaintiff's Motion for Preliminary Injunction by The Kyjen Company, LLC

(Text of Proposed Order on Plaintiff's Motion for Preliminary Injunction)

NOTICE of Compliance re 34 Order on Motion to Unseal Document. (Docket entries 5, 11, 12, 13, and 14 Unsealed.)

PAPERLESS Minute Order for proceedings held before Judge Roy K. Altman: Motion Hearing held on 5/27/2025 re 12 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, A Temporary Asset Restraint, and Expedited Discovery filed by The Kyjen Company, LLC. Total time in court: 12 minutes. Attorney Appearance(s): Leslie Rafalli Gillis, Valeria Munoz, Andrew Jonathan Palmer. Court Reporter: Patricia Diaz, 305-523-5178 / Patricia_Diaz@flsd.uscourts.gov. (es00)

STIPULATION for Entry of Order Modifying Asset Restraint by The Kyjen Company, LLC

(Text of Proposed Order)

NOTICE of Attorney Appearance by Ni Xue on behalf of GZSL Co.,LTD. Attorney Ni Xue added to party.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by GZSL Co.,LTD.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by FANGQU Co.Ltd.

ORDER GRANTING MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Administratively Closing Case. Motions terminated: 41 Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, filed by FANGQU Co.Ltd, 40 Unopposed MOTION for Extension of Time to File Response/Reply/ Answer as to 1 Complaint, filed by GZSL Co.,LTD. Signed by Judge Roy K. Altman on 6/6/2025. See attached document for full details.

ORDER FOLLOWING HEARING re 37 Motion Hearing. To facilitate a settlement, the temporary restraining order we granted against Defendant FANGQU Co. Ltd. (Schedule A, No. 82) is extended until June 10, 2025. A hearing is SET before this Court on June 10, 2025, at 10:30 a.m. (Settlement Conference set for 6/10/2025 10:30 AM before Judge Roy K. Altman.) Signed by Judge Roy K. Altman on 6/6/2025. See attached document for full details.

First MOTION for Extension of Time to respond to complaint by dechong. Attorney Leslie Rafalli Gillis added to party dechong(pty:dft). Responses due by 6/20/2025.

MOTION for Extension of Time amended as to paragraph 8 only by dechong. Responses due by 6/20/2025.

PAPERLESS ORDER GRANTING Certain Plaintiffs' 40, 41, 44, 45 Motions for Extension of Time to Answer the 1 Complaint. Defendants GZSL Co., LTD, FANGQU Co. Ltd., and dechong must answer or respond to the Complaint by June 23, 2025. Signed by Judge Roy K. Altman on 6/6/2025. (es00)

NOTICE of Voluntary Dismissal of Defendant Nos. 14 (JenililyDirect), 17 (ledorr), 46 (April Fashion Jewelry), 62 (Soul Pet), 129 (Yanna), 133 (Yicmeid), and 136 (Zabbiam) by The Kyjen Company, 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 The Kyjen Company, LLC.

(Declaration of Valeria Munoz)

Clerk's Entry of Default as to ADHYRO, ATDV, AirBelle, Aluckmao, Animire, Baishenghong, Bala Information, Ball King Girl Store, Brother Teddy, CJJ PET, Caizhitong Trading Co., Ltd., Chen Pingguo Beauty Collection, Coffeemate, Dexter, Doversky, DreTup, FENGYAN Co.Ltd, Freefa Manufacturer, Fur & Tech, GZLY Co.,Ltd, GZYNH Co.,LTD, Guiyunjian, HAISSKY motorcycle parts, HESHU Co.Ltd, Hesheng2023, HiNoKi, HollowBall, JIJI Co.Ltd, Jeffrey Big Shop, Jiangsu Zotia Houseware Co., Ltd., Kerr Good Store, LYMZ Co.Ltd, LittlethingSTR, MY01, Maintain77, Moffey Shopping, Mooela, Mr xiew, My Happy box 01 (myhappy_40), NewSoul, Ningbo jiamin Pets, Our Story, Out of circle, Pet Supplies QingYu, PetHse, R-lian, SCQCFW, SWEET pep, Sengu pet supplies, Shaww Juu, Shuzhi Small Shop, Siateml, Sokhug, TDC PET, The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A, The Kings pet world, The Silk Road, Tjsouler Pet Store, VORCOY, WINGPET, XIGOU, XIJIA, XTCXJC, XW BALD EAGLE, Xiao market, XinFu Yuan, YGKJYXGS, Yingying Official Store, Youpinhuijiajuyongpinltd, ZFJ-FAFA, ZYLYY, ZenithDaily Decor, Zezili, Zhensu trading co., ltd, ZhongXiangShi, ashcjgtfONQ, beiweidianzi, chenyanmaoyi, danuo, ddmyjun, denggudianzi, dfgdfghdfgdfgd, dhpetcl (dh1102211293), dhpetey (dh1100391878), dib-bid, fengyuewenhua, foshanshidiaofudaoshangmao, foshanshijiaojingfengmaoyi, foshanshiqitongqishangmao, foshanshiwanxinxiaoshangmao, guangzhouyuchengshiyemaoyiyouxiangongsi, haibingchuangkeji, happiness in life, home_oasiss, hongchuangyiqi, huaibeihuiyibaihuo, huangqiucen, huanrushangmao, hui2hao, ixinjidianshe, jiejiehongyunshangmao, jinkunpengruijianshe, jiu10, kellyiii, lan ting mao yi, liboshangmaa, liuyier, mengguawangluo, mizhejiaoshangmao, nahangkeji, panlinshandongguituwenhuachuan, pempet_official, pet_toy1, petchains, pobucishangmao, shen zhen chao fan jie mao yi you xian gong si, shenglixiaopu, sparkling001, taiyuanfanyishushangmaoyouxiangongsi, weikewulianjishugongsi, weizhuqianshangmao, wu han xin yi tong wang luo ke ji you xian gong si, xiaxiaotingshangmao, xiaxue (weni6_5), xingmengyuanmaoyi, yehaoshangmaoyouxiangongsi, yichangshihengyaan, yilanxianxianghu Co. Ltd, zhenjiuyouxuan, zzhomefashion - Motions Terminated: 48 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 6/10/2025. (pc) (VACATED as to R-lian only per DE 58) Modified text on 6/18/2025

Plaintiff's NOTICE of Filing Second [Proposed] Order Granting Plaintiff's Motion for Preliminary Injunction by The Kyjen Company, LLC

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

PAPERLESS Minute Order for proceedings held before Judge Roy K. Altman: Preliminary injunction hearing held on 6/10/2025. Total time in court: 3 minutes. Attorney Appearance(s): Valeria Munoz. Court Reporter: Francine Salopek, 305-301-3276 / mjsfcs@aol.com. (es00)

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

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, 30 Summons Returned Executed, by Aluckmao, Animire.

Plaintiff's MOTION for Default Judgment by The Kyjen Company, LLC.

Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 1 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 2 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 3 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 4 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 5 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 6 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 7 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 8 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 9 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 10 of 11)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment (Part 11 of 11)

Exhibit 2 to the Declaration of Valeria Munoz in Support of Plaintiff's Motion for Entry of Final Default Judgment

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

(Proposed Order of Final Default Judgment and Permanent Injunction)

MOTION to Set Aside Default by R-lian. Attorney Alan Mensa-Wilmot added to party R-lian(pty:dft).

Affidavit

(Text of Proposed Order)

PAPERLESS ORDER GRANTING the 53 Unopposed Motion for Extension of Time to Answer or Respond to the 1 Complaint. Defendants Animire and Aluckmao must answer or respond to the Complaint by June 27, 2025. Signed by Judge Roy K. Altman on 6/17/2025. (es00)

MOTION TO DISMISS 1 Complaint, FOR FAILURE TO STATE A CLAIM, MOTION to Sever by Aluckmao, Animire. Responses due by 7/1/2025.

PAPERLESS ORDER GRANTING Defendant R-lian's 55 Motion to Vacate Clerk's Entry of Default. Because R-lian has appeared and plans to answer or respond to the Complaint, we VACATE the 49 Clerk's Entry of Default as to R-lian only. Under our 9 Multiple Defendants Order, all non-defaulting Defendants may separately answer the Complaint, but must jointly file any motions to dismiss. Defendants Animire and Aluckmao have already 57 moved to dismiss the Complaint. We therefore DENY without prejudice Animire and Aluckmao's 57 Motion to Dismiss the Complaint. R-lian, Animire, and Aluckmao may answer or jointly respond to the Complaint by July 1, 2025. Signed by Judge Roy K. Altman on 6/17/2025. (es00) Modified text on 6/18/2025 per Chambers

NOTICE of Voluntary Dismissal of Defendant Nos. 4 (Bala Information), 42 (home_oasiss), 78 (Caizhitong Trading Co., Ltd.), and 109 (NewSoul) by The Kyjen Company, LLC

ANSWER and Affirmative Defenses to Complaint by FANGQU Co.Ltd.

MOTION to Dissolve Preliminary Injunction [DE 42] re 42 Preliminary Injunction, Order Dismissing/Closing Case, by Aluckmao.

Exhibit A- Infringing Evidence

(Exhibit B- Def's Design Patent)

PAPERLESS ORDER. For the reasons set forth on the record at the [51] Second Preliminary Injunction Hearing, the [42] Preliminary Injunction Order we entered in this action now also extends to Defendant FANGQU Co. Ltd. (Schedule A, No. 82). Signed by Judge Roy K. Altman on 6/30/2025. (es00)

NOTICE of Withdrawal of Motion to Dismiss by Defendant Animire Only by Animire re 57 MOTION TO DISMISS 1 Complaint, FOR FAILURE TO STATE A CLAIM MOTION to Sever

NOTICE of Voluntary Dismissal of Defendant Nos. 3 (Animire) and 18 (Maintain77) by The Kyjen Company, LLC

Plaintiff's NOTICE of Filing Amended [Proposed] Order on Motion for Entry of Final Default Judgment and Amended [Proposed] Final Default Judgment and Permanent Injunction by The Kyjen Company, LLC re 54 Plaintiff's MOTION for Default Judgment

Text of Amended [Proposed] Order on Motion for Entry of Final Default Judgment

(Text of Amended [Proposed] Final Default Judgment and Permanent Injunction)

MOTION to Withdraw Document DE 26, 44, 45 by dechong. Responses due by 7/17/2025.

NOTICE of Voluntary Dismissal of Defendant No. 5 (dechong) by The Kyjen Company, LLC

RESPONSE in Opposition re [61] MOTION to Dissolve Preliminary Injunction [DE 42] re [42] Preliminary Injunction, Order Dismissing/Closing Case, filed by The Kyjen Company, LLC. Replies due by 7/14/2025.

Clerk's Notice to Filer re 66 MOTION to Withdraw Document DE 26, 44, 45. Wrong Event Selected; ERROR - The Filer selected the wrong event. The correction was made by the Clerk It is not necessary to refile this document.

NOTICE of Voluntary Dismissal of Defendant No. 24 (R-lian) by The Kyjen Company, LLC

NOTICE of Withdrawing Motion to Dismiss [DE 57] by Aluckmao re 57 MOTION TO DISMISS 1 Complaint, FOR FAILURE TO STATE A CLAIM MOTION to Sever

NOTICE of Withdrawing Motion to Dissolve Preliminary Injunction [DE 61] by Aluckmao re 61 MOTION to Dissolve Preliminary Injunction [DE 42] re 42 Preliminary Injunction, Order Dismissing/Closing Case

NOTICE of Voluntary Dismissal of Defendant No. 2 (Aluckmao) by The Kyjen Company, LLC

Unopposed MOTION to Withdraw as Attorney by Ni Xue for / by GZSL Co.,LTD. Responses due by 7/29/2025.

(Text of Proposed Order)

Plaintiff's MOTION for Clerk's Entry of Default as to GZSL Co.,LTD by The Kyjen Company, LLC.

(Declaration of Valeria Munoz)

PAPERLESS ORDER GRANTING Ni Xue's 74 Motion to Withdraw as Counsel. We DIRECT the Clerk of Court to terminate Ni Xue as counsel for Defendant GZSL Co., Ltd. Defendant GZSL Co., Ltd appears to be a business entity. "[C]orporate entities may not appear pro se"; they "must be represented by counsel in all dealings with the Court." Damian v. Int'l Metals Trading & Invs., Ltd., 243 F. Supp. 3d 1308, 1313 (S.D. Fla. 2017) (Middlebrooks, J.) (citing Palazzo v. Gulf Oil Corp., 764 F.2d 1381, 1385 (11th Cir. 1985)). Fortunately, Attorney Xue informs us that Defendant GZSL Co., Ltd. has already found replacement counsel. Mot. at 1. By July 21, 2025, then, GZSL Co., Ltd.'s new counsel must enter an appearance in this case. (es00)

Clerk's Entry of Default as to GZSL Co.,LTD - Motions Terminated: 75 Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 7/16/2025.

NOTICE of Striking 65 Notice (Other), filed by The Kyjen Company, LLC, 54 Plaintiff's MOTION for Default Judgment filed by The Kyjen Company, LLC by The Kyjen Company, LLC

Amended MOTION for Default Judgment by The Kyjen Company, LLC.

Amended Declaration of Valeria Munoz

Exhibit 1 (Part 1 of 11)

Exhibit 1 (Part 2 of 11)

Exhibit 1 (Part 3 of 11)

Exhibit 1 (Part 4 of 11)

Exhibit 1 (Part 5 of 11)

Exhibit 1 (Part 6 of 11)

Exhibit 1 (Part 7 of 11)

Exhibit 1 (Part 8 of 11)

Exhibit 1 (Part 9 of 11)

Exhibit 1 (Part 10 of 11)

Exhibit 1 (Part 11 of 11)

Exhibit 2

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

(Amended Text of Proposed Final Default Judgment and Permanent Injunction)

CERTIFICATE OF SERVICE by The Kyjen Company, LLC re 76 Order on Motion to Withdraw as Attorney, re Defendant No. 91 (GZSL Co.,LTD)

Joint MOTION for Extension of Time of All Currently Pending Dates, Including the Deadline to File the Joint Conference Report re Defendant No. 82 (FANGQU Co.Ltd) by The Kyjen Company, LLC. Responses due by 8/4/2025.

(Text of Proposed Order)

PAPERLESS ORDER GRANTING the 81 Joint Motion for Extension of Time. The Plaintiff and Defendant FANGQU Co. Ltd. inform us that they've engaged in "settlement negotiations" and "expect to reach an agreement soon." They've requested a brief extension of their deadline to file a Local Rule 16.1 Report. As to these parties only, then, we extend all deadlines to July 29, 2025. Signed by Judge Roy K. Altman on 7/25/2025. (es00)

NOTICE of Settlement re Defendant No. 82 (FANGQU Co.Ltd) by The Kyjen Company, LLC

ORDER GRANTING MOTION FOR DEFAULT FINAL JUDGMENT re 79 Motion for Default Judgment. Signed by Judge Roy K. Altman on 7/30/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of The Kyjen Company, LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Signed by Judge Roy K. Altman on 7/30/2025. See attached document for full details.

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

NOTICE of Voluntary Dismissal of Defendant No. 82 (FANGQU Co.Ltd) by The Kyjen Company, LLC

SATISFACTION OF JUDGMENT re 85 Default Judgment, Permanent Injunction, as to Defendant No. 28 (XIGOU) by The Kyjen Company, LLC

Plaintiff's MOTION for Disbursement of Funds - Return of Bond by The Kyjen Company, LLC.

(Text of Proposed Order)

SATISFACTION OF JUDGMENT re [85] Default Judgment, Permanent Injunction, as to Defendant No. 117 (Sokhug) by The Kyjen Company, LLC

PAPERLESS ORDER DENYING as moot the Plaintiff's 89 Motion for Return of Bond. Our 85 Default Judgment Order directed the Clerk of Court to "immediately release to the Plaintiff the $10,000.00 bond it posted, along with any accrued interest." Since we've already granted the relief sought in the Motion, and since the Motion doesn't clarify why another order is necessary, it's DENIED as moot. Signed by Judge Roy K. Altman on 8/5/2025. (es00)

PAPERLESS ORDER. In the Plaintiff's last 89 motion, it requested that we enter a separate order directing return of its bond. We 91 denied that motion as moot because our 85 Default Final Judgment in this case already directed the Clerk of Court to return the bond. But the Clerk of Court has informed us that, notwithstanding the literal text of the Plaintiff's Motion, the Plaintiff actually seeks return of its bond to its counsel rather than to itself. Because the Clerk of Court may not disburse money to a payee not specified by order, we hereby enter a separate order specifying that the bond should be returned to Plaintiff's counsel. We DIRECT the Clerk of Court to disburse the 20 $10,000.00 bond posted by the Plaintiff on May 6, 2025, plus any accrued interest. The Clerk of Court must disburse the bond to Plaintiff's counsel at Boies Schiller Flexner LLP, 2200 Corporate Boulevard, NW, Ste. 400, Boca Raton, FL 33431. We furthermore DIRECT the Plaintiff to provide a copy of this order, as well as all other necessary information, to the Court's Financial Section. Signed by Judge Roy K. Altman on 8/8/2025. (es00)

CLERK'S NOTICE re 92 Order Additional Notice of Electronic Filing (NEF) sent to Financial Clerk

SATISFACTION OF JUDGMENT re 85 Default Judgment, Permanent Injunction, as to Defendant Nos. 30 (ZFJ-FAFA) and 63 (SWEET pep) by The Kyjen Company, LLC

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SATISFACTION OF JUDGMENT re 85 Default Judgment, Permanent Injunction, as to Defendant Nos. 47 (ATDV) and 53 (HAISSKY motorcycle parts) by The Kyjen Company, LLC