2024-cv-02356

COMPLAINT filed by YSN Imports LLC dba Flame King; Filing fee $ 405, receipt number AILNDC-21778125.

Exhibit 1, Defendant List and Evidence (under seal)

Exhibit 2, TM Registration Certificates

Exhibit 3, Lab Testing

(Exhibit 4, Joint Manufacturer and Supplier Evidence)

SEALED DOCUMENT by Plaintiff YSN Imports LLC dba Flame King Defendant List and Evidence

Supplement Screenshot Evidence Part 1 of 3

Supplement Screenshot Evidence Part 2 of 3

(Supplement Screenshot Evidence Part 3 of 3)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff YSN Imports LLC dba Flame King by Rishi Nair

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (Text entry; no document attached.)

MOTION by Plaintiff YSN Imports LLC dba Flame King to seal Defendant List and Evidence (Dkt. 2)

MOTION by Plaintiff YSN Imports LLC dba Flame King to expedite discovery and for alternative email service of process under FRCP 4(f)(3)

Declaration by Israel Schochet

Exhibit 1 to Schochet Declaration (Marks and Official Listing)

Exhibit 2 to Schochet Declaration (Lab results)

Declaration by Rishi Nair

(Exhibit 1 to Nair Declaration (Unpublished Caselaw))

NOTICE of Motion by Rishi Nair for presentment of motion to expedite, 6, motion to seal 5 before Honorable Virginia M. Kendall on 4/2/2024 at 09:00 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 4/2/2024. Plaintiff's Motion for leave to file under seal 5 is granted. Plaintiff's Motion to expedite Discovery and for alternative email service of process 6 are granted. Order to follow. Mailed notice

SUMMONS Issued as to Defendant THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A (Text entry; no document attached.)

SUMMONS Returned Executed by YSN Imports LLC dba Flame King as to THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A on 4/17/2024, answer due 5/8/2024.

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to Def. 64 "bookmarkdeals" ONLY

ATTORNEY Appearance for Defendants Bravex, STEINBRUCKE, Elemake, Le swing, magicworx999, hc_performance445, oepartsmaster9, eight-plus2022, autoparteoy129, auto-zone19, topautoparts18 by Steven G Kalberg

(Appearance Continued)

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to Def. Nos. 26 Marketplace Pros and 179 usastorez/usa*stores ONLY

MOTION by Defendants Bravex, Elemake, Le swing, STEINBRUCKE, auto-zone19, autoparteoy129, eight-plus2022, hc_performance445, magicworx999, oepartsmaster9, topautoparts18 for extension of time to file answer regarding complaint, 1 or otherwise respond (unopposed)

NOTICE of Motion by Steven G Kalberg for presentment of motion for extension of time to file answer, 16 before Honorable Virginia M. Kendall on 5/16/2024 at 09:00 AM.

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to Def. Nos. 63 blyh99/blyh-99; 140 navinga0/navinga-0; 143 nirayehuda; 150 pincha13/pincha-13; 157 shaulelc46/shaulelc-46; AND, 172 tome6001/tome-6001 ONLY

MINUTE entry before the Honorable Virginia M. Kendall. Defendants' Unopposed Motion for extension of time to answer or otherwise plead 16 is granted. Responsive Brief shall be filed by 6/7/2024. Motion hearing set for 5/16/2024 is stricken. Mailed notice

MOTION by Plaintiff YSN Imports LLC dba Flame King for default judgment as to each defendant as listed in Exhibit 1 to Plaintiff's Memorandum in Support of Its Motion for Entry of Default and Default Judgment

MEMORANDUM by YSN Imports LLC dba Flame King in support of motion for default judgment 20 as to defendants as listed in Exhibit 1

Exhibit 1, Defaulting Defendant List

Declaration by Rishi Nair

Exhibit 1 to Nair Declaration (Unpublished Caselaw)

(Certificate of Service)

NOTICE of Motion by Rishi Nair for presentment of motion for default judgment 20 before Honorable Virginia M. Kendall on 5/28/2024 at 09:00 AM.

ATTORNEY Appearance for Defendants AUSAIL, QUANIE, GAGITER, JAYICHENG by Hua Chen

ATTORNEY Appearance for Defendants superplaza-07, mansencoltd, kg1coltd, pollypoc, Artudatech-06, reachmall-03, eforshop-14, excelsellerusa, USseller999, Darupsun by Timothy Tiewei Wang

(Exhibit A - List of Represented defendants)

MOTION by Defendants Artudatech-06, Darupsun, USseller999, eforshop-14, excelsellerusa, kg1coltd, mansencoltd, pollypoc, reachmall-03, superplaza-07 for extension of time to file answer regarding complaint, 1

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer 25 before Honorable Virginia M. Kendall on 5/29/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Defendants Artudatech-06, Darupsun, USseller999, eforshop-14, excelsellerusa, kg1coltd, mansencoltd, pollypoc, reachmall-03 and superplaza-07's Unopposed Motion for extension of time to answer or otherwise plead 25 is granted. Responsive brief shall be filed by 6/11/2024. Motion hearing set for 5/29/2024 is stricken. Mailed notice

ATTORNEY Appearance for Defendant NASH FUEL by Donald Patrick Eckler

MOTION by Defendant NASH FUEL for extension of time to file answer

NOTICE of Motion by Donald Patrick Eckler for presentment of motion for extension of time to file answer 29 before Honorable Virginia M. Kendall on 5/28/2024 at 09:00 AM.

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to Def. Nos. 77 create9rich; 100 flywisdomsales8; 111 hibis6cus; AND, 138 motorstarshine ONLY

MOTION by Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE for extension of time to file answer regarding complaint, 1 UNOPPOSED

NOTICE of Motion by Hua Chen for presentment of motion for extension of time to file answer 32 before Honorable Virginia M. Kendall on 6/3/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 5/28/2024. Plaintiff's Motion for entry of Default and Default Judgment as to Defendants as listed in Exhibit 1 20 is granted. Enter Order of Default as to Defendants as listed in Exhibit 1. Default Judgment Order to follow. Defendants' Motions for extension of time to Answer or otherwise plead 29 and 32 are granted. Responsive Pleadings shall be filed by 6/24/2024. Status hearing set for 6/25/2024 at 9:00 AM. Mailed notice

DEFAULT Judgment Order signed by the Honorable Virginia M. Kendall on 5/28/2024. Mailed notice

MOTION by Defendants Bravex, Elemake, Le swing, STEINBRUCKE, auto-zone19, autoparteoy129, eight-plus2022, hc_performance445, magicworx999, oepartsmaster9, topautoparts18 for extension of time to file answer regarding complaint, [1] or otherwise respond to Plaintiff's Complaint (second unopposed)

NOTICE of Motion by Steven G Kalberg for presentment of motion for extension of time to file answer, [36] before Honorable Virginia M. Kendall on 6/11/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Defendants Bravex, Elemake, Le swing, STEINBRUCKE, auto-zone19, autoparteoy129, eight-plus2022, hc_performance445, magicworx999, oepartsmaster9, and topautoparts18's Motion for extension of time to answer [36] is granted. Answer shall be filed by 7/8/2024. Status hearing is reset for 7/11/2024 at 9:00 AM. Motion hearing set for 6/11/2024 is stricken. Mailed notice

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to Def. Nos. 45 175070432ye/darupsun; 51 artudatech06/artudatech-06; 91 eforshop14/eforshop-14; 95 excelsellerusa; 125 kg1coltd; 132 mansencoltd; 151 pollypoc; 156 reachmall03/reachmall-03; 167 superplaza07/superplaza-07; AND, 180 usseller999 ONLY

ATTORNEY Appearance for Defendants aboutsla, bestdealshop5063, blueberrybay17/bluelake1940, buyeasy2013, buyeasyfr/buyeasy-fr, catchit2020/catch-it, cherish168, dancing-updoll, harrentown/harren-town, hhl888, isaac52010/kissyourlife52010, kaufttown/kauft-town, kaylie52013/happydeals77us, kkstrip, loveheart-store, littleshell, mylifeshoppingmall, npango/n.pango, princeplaza, qtx6/hmx666, shenmi75, shine2095/shine-2095, shopfunny/shop-funny, shoppingfunday, shsshop1/shh-shop1, subsublivehua/aboutsla, topjohn/flyme1818, vipstorede/vip-store-de, xinstore2020/xin-store-2020, xinusa/xin-usa by Erin Kathryn Russell

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to DEF NOs. 46 aboutsla; 60 bestdealshop5063; 62 blueberrybay17/bluelake1940; 67 buyeasy2013; 68 buyeasyfr/buyeasy-fr; 71 catchit2020/catch-it; 74 cherish168; 79 dancing-updoll; 108 harrentown/harren-town; 110 hhl888; 121 isaac52010/kissyourlife52010; 123 kaufttown/kauft-town; 124 kaylie52013/happydeals77us; 126 kkstrip; 128 loveheart-store; 129 lttleshell; 139 mylifeshoppingmall; 144 npango/n.pango; 152 princeplaza; 155 qtx6/hmx666; 158 shenmi75; 159 shine2095/shine-2095; 160 shopfunny/shop-funny; 161 shoppingfunday; 162 shsshop1/shs-shop1; 165 subsublivehua/aboutsla; 175 topjohn/flyme1818; 182 vipstorede/vip-store-de; 188 xinstore2020/xin-store2020; AND, 189 xinusa/xin-usa ONLY

FULL SATISFACTION of Judgment regarding order 35 in the amount of $174.91 as to Defendant No. 141 nethdien0/nethdien_0 ONLY

MOTION by Defendant NASH FUEL for extension of time to file answer (Unopposed Second Motion for an Extension of Time to Answer or Otherwise Plead to Plaintiff's Complaint)

NOTICE of Motion by Donald Patrick Eckler for presentment of motion for extension of time to file answer 43 before Honorable Virginia M. Kendall on 7/11/2024 at 09:00 AM.

FULL SATISFACTION of Judgment regarding order[35] in the amount of as listed per defendant as to DEF NOs. 3 atoship; 12 DASBETAUTO; 20 HMMAO; 27 MIMILA; 28 MYSPORT_6; 41 TTLUCK88; 47 accushshopping; 48 airbrushdy; 58 bbiestopstore; 72 cfhytyoyo/hcold5027; 76 comettgood; 80 ddouyg007; 86 ebyhzxrfsess/rfsess_oh; 107 happybuy686; 114 hmmaot/hmmao_t; 154 pugedcq56store; 166 summ4300/sunm43; 170 tdggyhh33; 177 tutuooo666; 181 videstar88; AND, 186 womeyouer77store/ womeyouer77 ONLY

MOTION by Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE for extension of time to file answer

NOTICE of Motion by Hua Chen for presentment of motion for extension of time to file answer[46] before Honorable Virginia M. Kendall on 7/11/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Defendants' Motions for extension of time to answer or otherwise plead [43] and [46] are granted. Answers shall be filed by 7/24/2024. Status hearing is reset for 8/14/2024 at 9:30 AM. Motion and Status hearings set for 7/11/2024 are stricken. Mailed notice

FULL SATISFACTION of Judgment regarding order 35 in the amount of $149.54 as to Def. No. 169 tbsierra/tbsierra2001 ONLY

MOTION by Defendants Bravex, Elemake, Le swing, STEINBRUCKE, auto-zone19, autoparteoy129, eight-plus2022, hc_performance445, magicworx999, oepartsmaster9, topautoparts18 for extension of time to file answer (third unopposed)

NOTICE of Motion by Steven G Kalberg for presentment of motion for extension of time to file answer, [50] before Honorable Virginia M. Kendall on 7/16/2024 at 09:00 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Defendants' Unopposed Motion for extension of time to answer or otherwise plead 50 is granted. Responsive Pleading shall be filed by 7/31/2024. Motion hearing set for 7/16/2024 is stricken. Mailed notice

FULL SATISFACTION of Judgment regarding order[35] in the amount of as listed per defendant as to Def. Nos. 66 btshub AND 82 destore203/udasell78 ONLY

ANSWER to Complaint by AUSAIL, GAGITER, JAYICHENG, QUANIE

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to DEF. NOs. 4 ATP Technic; 6 Bravex; 14 Elemake; 15 Freebird Trading; 25 Le swing; 35 STEINBR"CKE; 53 autoparteoy129; 54 autozone19/auto-zone19; 92 eightplus2022/eight-plus2022; 102 freebird2de22017/autotools-eu; 103 freetecautotools/autorepairtool-eu; 112 highfree/consing_4; 117 huanke20203/huanke2020-3; 127 kuntecus/kuntec-us; 131 magicworx999; 136 mlautotoolsc/mlautotools-c; 146 oepartsmaster9; 149 performancedeutschland/; hc_performance445; 164 sparkfireus/bangdagve; 173 topautoparts18; 187 wootone/freebird-top; 191 yaemart2020/yaemart*2020 ONLY

FULL SATISFACTION of Judgment regarding order[35] in the amount of $1,028.29 as to Def. No. 106 greatgiftsarrivereallyfast/ moneymakinmeeks2012 ONLY

FULL SATISFACTION of Judgment regarding order[35] in the amount of $1,354.92 as to Def. No. 184 weldingpartner ONLY

NOTICE of Voluntary Dismissal by YSN Imports LLC dba Flame King with prejudice as to Def. No. 153 propanekits/ propane-kits ONLY

NEW PARTIES: ATP Technic, Freebird Trading, freebird2de22017/autotools-eu, freetecautotools/autorepairtool-eu, highfree/consing_4, huanke20203/huanke2020-3, kuntecus/kuntec-us, mlautotoolsc/mlautotools-c, sparkfireus/bangdagve, wootone/freebird-top and yaemart2020/yaemart*2020 added to case caption. (Text entry; no document attached.)

NEW PARTIES: propanekits/ propane-kits added to case caption. (Text entry; no document attached.)

FULL SATISFACTION of Judgment regarding order[35] in the amount of as listed per defendant as to Def. Nos. 50 amazinghomegoodsforyou916; 57 baynami; 59 beachbummer777; 61 bistatebusiness; 75 co-rian; 85 dreamcatcher87/joey-87/J&A Sale's; AND, 93 electronicscoinsandcollectables/cwolff78 ONLY

NEW PARTIES: amazinghomegoodsforyou916, baynami, beachbummer777, bistatebusiness, co-rian, dreamcatcher87/ joey-87/J&A Sale's and electronicscoinsandcollectables/ cwolff78 added to case caption. (Text entry; no document attached.)

ATTORNEY Appearance for Defendant Stark Tools USA by Brian W. Coffman

MINUTE entry before the Honorable Mary M. Rowland: The court has considered an Ex Parte Application for Relief from Default, Default Judgment, and Orders Affecting Defendant Stark Group, LLC's Business Operations filed on an Emergency basis. [60]. This document was filed under seal without seeking permission and was filed ex parte for reasons that are not explained. First, Stark Group LLC is to immediately serve a copy of this motion on Plaintiff. There is no reason for it to be handled ex parte. Second, Stark LLC is to file a motion seeking leave to file under seal pursuant to the pertinent Local Rules. Finally, the Court will grant temporary relief on an emergency basis. The Court stays the Default Judgment Order of this Court (Dkt. No. 35) as to Stark's two eBay sites, Inspiredepot/durapowers (using email xtremediecast1@gmail.com) and xtremepowerinc/hd-tool (using email toolspro1@gmail.com). The injunctive relief required by the default judgment to those two sites is stayed until further order of the Court. Plaintiff's counsel is to effectuate this order. This matter will be heard by the Court (Judge Kendall) on Tuesday, 8/6/24 at 9:30 am. Mailed notice.

MOTION by Defendant Stark Tools USA APPLICATION FOR RELIEF FROM DEFAULT, DEFAULT JUDGMENT, AND ORDERS AFFECTING DEFENDANT STARK GROUP, LLC'S BUSINESS OPERATIONS (DKT. NO. 35)

Declaration of Brian Patrick

Declaration of Adam P Zaffos

(Text of Proposed Order)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-22323103.

ATTORNEY Appearance for Defendant THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A by Rabea J. Zayed

STIPULATION of Dismissal and vacatur of Default Judgment [Dkt. 35] as to Def Nos. 1 Skymall and 163 skymallstore/skymallus ONLY

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 8/6/2024. Oral argument heard regarding Defendant's Motion for Relief from Default Judgment 63. Defendant's Motion 63 is entered and continued to 9/4/2024 for Parties to potentially work on resolution. Status hearing set for 9/4/2024 at 9:30 AM. Default Judgment Order of this Court 35 remains stayed as to Stark's two eBay sites, Inspiredepot/durapowers (using email xtremediecast1@gmail.com) and xtremepowerinc/hd-tool (using email toolspro1@gmail.com). The injunctive relief required by the default judgment to those two sites is stayed until further order of the Court. Attorney Clay Wilkinson's Motion for leave to appear pro hac vice 64 is granted. Mailed notice

FULL SATISFACTION of Judgment regarding order[35] in the amount of as listed per defendant as to DEF. NOs.: 56 bay353757; 65 brilliantcooperations19; 81 dealcheaper/; deal_cheaper; 83 discountranilaptop/; discount_laptop; 88 ecomains/eco-mains; 89 ecomains2/eco-mains-2; 90 econliner; 98 firework999; 118 huntersgripthebest/; hunters_grip; 130 lusedclothing; 147 pefectech4u; 148 perfectday-569; 174 topfuture2018; 176 trading2022/trading-2022; 183 wandede/wande8081; 185 wjoliva123/wj_oliva123; AND, 193 zaeem458 ONLY

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 8/14/2024 is stricken. Mailed notice

STIPULATION and Order signed by the Honorable Virginia M. Kendall on 8/15/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order 35 in the amount of as listed per defendant as to DEF. NOs. 22 Howhite-US; 39 tiger up cut International; trading Co.,Ltd.; 69 casedazzle; 87 ecclegends/ec_legend; 101 franklinstreetsales/cityb12; 122 justintimegifts; AND, 137 mosupermall ONLY

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 9/4/2024. Attorney Clay Wilkinson representing Stark Tools USA appeared via Webex. Plaintiff and Defense Counsel Wilkinson reported they have settled and are waiting on execution of the settlement agreement. Once execution of the settlement agreement between Plaintiff and Stark Tools USA has been completed, Plaintiff will file a satisfaction of Judgment that will terminate the Motions for relief from Default Judgment 60 and 63 as moot. Default Judgment Order of this Court 35 remains stayed as to Stark's two eBay sites, Inspiredepot/durapowers (using email xtremediecast1@gmail.com) and xtremepowerinc/hd-tool (using email toolspro1@gmail.com). Plaintiff's Counsel further reported that four remaining Defendants AUSAIL, GAGITER, JAYICHENG, and QUANI have filed Answers, but there has been limited communication with them. Status hearing set for 10/3/2024 at 9:30 AM. Defendants AUSAIL, GAGITER, JAYICHEN and QUANI are Ordered to either appear at Status hearing set for 10/3/2024 at 9:30 AM, or Respond to Plaintiff's Counsel regarding Discovery or resolution before 10/2/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order 35 in the amount of as listed per defendant as to Def. Nos. 120 inspiredepot/durapowers AND 190 xtremepowerinc/hd-tool ONLY (Stark Group LLC)

MINUTE entry before the Honorable Virginia M. Kendall. Motions for relief from Default Judgment [60] and [63] are dismissed as moot pursuant to Satisfaction of Judgment [73]. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 10/3/2024. Defense Counsel appeared on behalf of Defendants AUSAIL, GAGITER, JAYICHENG, and QUAN. End of Fact Discovery Ordered closed by 3/7/2025. End of Fact Discovery Status hearing set for 3/10/2025 at 9:30 AM. The Parties shall be prepared to report to the Court whether a dispositive motion will be filed and whether expert Discovery is necessary. Mailed notice

MOTION by Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE for extension of time to complete discovery JOINT MOTION FOR EXTENSION OF TIME TO COMPLETE FACT DISCOVERY

MINUTE entry before the Honorable Virginia M. Kendall. Parties Joint Motion for extension of time to complete Discovery 76 is granted. End of Fact Discovery is extended and Ordered closed by 4/30/2025. End of Fact Discovery Status hearing is reset for 5/1/2025 at 9:30 AM. Mailed notice

MOTION by Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE for extension of time to complete discovery JOINT MOTION FOR EXTENSION OF TIME TO COMPLETE FACT DISCOVERY

MOTION by Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE TO WITHDRAW DEEMED ADMISSIONS

Declaration of Aggarwal

(Exhibit 1)

NOTICE of Motion by Daniel I. Konieczny for presentment of motion for miscellaneous relief 79 before Honorable Virginia M. Kendall on 5/6/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Parties Joint Motion for extension of time to complete Discovery 78 is granted. End of Fact Discovery is extended and Ordered closed by 6/30/2025. End of Fact Discovery Status hearing is reset for 7/1/2025 at 9:30 AM. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 5/6/2025 is reset for 5/8/2025 at 9:30 AM. Mailed notice.

ATTORNEY Appearance for Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE by Daniel I. Konieczny

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 5/8/2025. Oral argument heard regarding Motion to Withdraw Deemed Admissions 79. Plaintiff requested to file a Response to Motion 79 and will do so today. The Court takes Motion 79 under advisement indicating a written Order is forthcoming. Mailed notice

RESPONSE by YSN Imports LLC dba Flame Kingin Opposition to MOTION by Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE TO WITHDRAW DEEMED ADMISSIONS 79

(Exhibit 1, Unpublished Caselaw)

ORDER signed by the Honorable Virginia M. Kendall on 6/3/2025. The Court grants Defendants' Motion to Withdraw Deemed Admissions 79. Defendants' late responses are deemed timely, and the parties are directed to proceed with Discovery. See Order for further details. Mailed notice

MOTION by Plaintiff YSN Imports LLC dba Flame King to compel

Statement LR 37.2

Declaration by Rishi Nair

Exhibit A

Exhibit B

Exhibit C

NOTICE of Motion by Rishi Nair for presentment of motion to compel[87] before Honorable Virginia M. Kendall on 6/24/2025 at 09:30 AM.

MOTION by Attorney Daniel Konieczny and Hua Chen to withdraw as attorney for AUSAIL, GAGITER, JAYICHENG, QUANIE. New address information: (multiple parties, see Exs. 1-4)

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

NOTICE of Motion by Daniel I. Konieczny for presentment of motion to withdraw as attorney, [89] before Honorable Virginia M. Kendall on 6/24/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Attorneys Hua Chen and Daniel Konieczny's Motion to withdraw as attorneys 89 is granted. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 6/24/2025. Defendant failed to appear. Plaintiff's oral Motion for extension of Discovery is granted. End of Fact Discovery is extended and Ordered closed by 8/1/2025. End of Fact Discovery Status hearing is set for 8/12/2025 at 9:30 AM. Motion to Compel 87 is entered and continued. Status hearing set for 7/1/2025 is stricken. Mailed notice

FULL SATISFACTION of Judgment regarding order 35 in the amount of as listed per defendant as to Def. Nos. 13 Dutywand; 18 GASPOWOR-US; 21 Hotdevil; 29 Pavemade; 31 R1998-Tools; 32 SARDVISA; 34 secure4u; AND, 42 william' sky ONLY

ATTORNEY Appearance for Defendant AUSAIL by Xiaoyi Yao

ATTORNEY Appearance for Defendant GAGITER by Xiaoyi Yao

ATTORNEY Appearance for Defendant JAYICHENG by Xiaoyi Yao

ATTORNEY Appearance for Defendant QUANIE by Xiaoyi Yao

ATTORNEY Appearance for Defendants CaminoTek, Crescendo International LLC by Shaoyi Che

MOTION by Defendants Crescendo International LLC, CaminoTek to vacate order 35 Default Judgment, MOTION by Defendants Crescendo International LLC, CaminoTek to dismiss for lack of jurisdiction

Declaration of Tian Qiu in support of Motion to Vacate & Dismiss

(Declaration of ZiQi Jiang in support of Motion to Vacate & Dismiss)

NOTICE of Motion by Shaoyi Che for presentment of motion to vacate, motion to dismiss/lack of jurisdiction, 99 before Honorable Virginia M. Kendall on 7/23/2025 at 09:30 AM.

Amended NOTICE of Motion by Shaoyi Che for presentment of motion to vacate, motion to dismiss/lack of jurisdiction, [99] before Honorable Virginia M. Kendall on 7/24/2025 at 09:30 AM.

MOTION by Plaintiff YSN Imports LLC dba Flame King to compel Defs. Ausail, Gagiter, Jayicheng, and Quanie

Supplement LR 37.2 Statement

Declaration by Rishi Nair

Exhibit A

Exhibit B

Exhibit C

Exhibit D

NOTICE of Motion by Rishi Nair for presentment of motion to compel, [102] before Honorable Virginia M. Kendall on 7/22/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. By request of Defense Counsel due to being out of state, Motion hearing set for 7/22/2025 will now proceed via Webex. Prior to the hearing, you are directed to cut and paste this hyper link into a browser: https://us-courts.webex.com/join/virginia_kendallilnd.uscourts.gov You can use the dial in option ONLY if you do not have access to a device with video capability: (650)-479-3207, the access code is: 180 698 4009. Mailed notice

MOTION by Attorney Xiaoyi Yao to withdraw as attorney for AUSAIL, GAGITER, JAYICHENG, QUANIE. New address information: (multiple parties, see Exs. 1-4)

Exhibit

Exhibit

Exhibit

Exhibit

NOTICE of Motion by Xiaoyi Yao for presentment of motion to withdraw as attorney[105] before Honorable Virginia M. Kendall on 7/24/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Attorney Xiaoyi Yao's Motion to withdraw as attorney [105] is granted. Mailed notice

MOTION by Plaintiff YSN Imports LLC dba Flame King for default judgment as to Defs. Ausail, Gagiter, Jayicheng, and Quanie

MEMORANDUM by YSN Imports LLC dba Flame King in support of motion for default judgment[108] as to AUSAIL (No. 5), Gagiter (No. 17), JAYICHENG (No. 24), and QUANIE (No. 30)

Declaration by Rishi Nair

Exhibit 1 to Nair Declaration (Unpublished Caselaw)

Certificate of Service

NOTICE of Motion by Rishi Nair for presentment of motion for default judgment[108] before Honorable Virginia M. Kendall on 7/24/2025 at 09:30 AM.

STATUS Report Notice of Settlement and Withdrawal of Motion by CaminoTek, Crescendo International LLC

FULL SATISFACTION of Judgment regarding order[35] in the amount of $123,465.90 as to Def. No. 7 CaminoTek ONLY

SEALED DOCUMENT by Plaintiff YSN Imports LLC dba Flame King Defendant financial documents designated as Confidential

MOTION by Plaintiff YSN Imports LLC dba Flame King to seal document sealed document[113]

MINUTE entry before the Honorable Virginia M. Kendall. Pursuant to Notice of Withdrawal 111, Defendants' Motion to Dismiss and Motion to Vacate Default Judgment 99 is hereby withdrawn. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 7/22/2025. Plaintiff's Motion to Compel Defendants Ausail, Gagiter, Jayicheng, and Quanie 102 is granted. Defendants are Ordered to Respond to Interrogatories on or before 7/30/2025. Motion for Default and Default Judgment 108 is entered and continued. Motion hearing set for 8/12/2025 at 9:30 AM. Status hearing set for 8/12/2025 stands. Plaintiff's Motion for leave to file under seal 114 is granted. Mailed notice

ATTORNEY Appearance for Defendants AUSAIL, GAGITER, JAYICHENG, QUANIE by Jianyin Liu

RESPONSE by AUSAIL, GAGITER, JAYICHENG, QUANIEin Opposition to MOTION by Plaintiff YSN Imports LLC dba Flame King for default judgment as to Defs. Ausail, Gagiter, Jayicheng, and Quanie 108

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 8/12/2025. Defense Counsel Liu appeared via Webex. Motion for default judgment 108 is entered and continued for 9/9/2025 at 9:30 AM. Mailed notice

FULL SATISFACTION of Judgment regarding order 35 in the amount of $1,329.62 as to Def. No. 55 b2brenew ONLY

MOTION by Attorney Jianyin Liu to withdraw as attorney for AUSAIL, GAGITER, JAYICHENG, QUANIE. New address information: 18133000376@163.com

(Exhibit A- Contact Form)

NOTICE of Motion by Jianyin Liu for presentment of motion to withdraw as attorney 121 before Honorable Virginia M. Kendall on 8/26/2025 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Attorney Jianyin Liu's Motion to withdraw as attorney 121 is granted. Motion hearing set for 8/26/2025 is stricken. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Status hearing set for 9/9/2025 is reset for 9:00 AM (NOTE TIME CHANGE ONLY) due to a Jury Trial proceeding. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 9/9/2025. Plaintiff's Motion for Default Judgment 108 is granted. Default Judgment Order to follow. Mailed notice

DEFAULT Judgment Order signed by the Honorable Virginia M. Kendall on 9/9/2025. Civil case terminated. Mailed notice