2024-cv-04085

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 405, receipt number AILNDC-21981010.

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Schedule A regarding complaint 1

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 1 - Parts 1-4 regarding complaint 1

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

(Exhibit 1-4)

MOTION by Plaintiff Dyson Technology Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dyson Technology Limited

Notice of Claims Involving Patents by Dyson Technology Limited

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Lawrence J. Crain

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Andrew Daniel Burnham

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 1). (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 Dyson Technology Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Dyson Technology Limited in support of motion for temporary restraining order 12

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 13

Exhibit 1

(Exhibit 2)

DECLARATION of Giles Samuel Lane regarding memorandum in support of motion 13

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 2 - Parts 1-4 regarding declaration 15

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

(Exhibit 2-4)

MOTION by Plaintiff Dyson Technology Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Dyson Technology Limited in support of motion for miscellaneous relief 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 4, motion for miscellaneous relief 17, motion for temporary restraining order 12 before Honorable Manish S. Shah on 5/30/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 3 12 17 are granted, and no appearance on the motions is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 5/30/2024. Notices Mailed.

Registry Deposit Information Form by Dyson Technology Limited

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

INJUNCTION BOND in the amount of $ 50,000 posted by Dyson Technology Limited (Document not scanned)

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction[25]

Declaration of Justin T. Joseph

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction[25] before Honorable Manish S. Shah on 6/13/2024 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/10/2024, answer due 7/1/2024.

Declaration of Andrew D. Burnham

Exhibit A

TRANSCRIPT OF PROCEEDINGS held on 06/13/2024 before the Honorable Manish S. Shah. Motion Hearing. Order Number: 49044. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 7/4/2024. Redacted Transcript Deadline set for 7/15/2024. Release of Transcript Restriction set for 9/11/2024.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [25] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 6/13/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendants

NEW PARTIES: Beijing Cypselurus Technology Co., Ltd., Chongqing Niannianfa Technology Co., Ltd., Dongguan Nigo Smart Electric Co., Ltd., Foshan Huichuang Boyao Import And Export Co., Ltd., Guangzhou Tengyun Electric Appliance Co., LTD., Guangzhou Youxin Import And Export Co., Ltd., Huaibei Yueershi Technology Co., Ltd., Huizhou Jinyuanduo Technology Co., Ltd., Immortal (kunming) Technology Co., Ltd., Longyan Dousen Trading Co., Ltd., Luweisi (shenzhen) Technology Co., Ltd., Ningbo Eyoja Technology Development Co., Ltd., Ningbo Fix Dollar Import & Export Co., Ltd., Ningbo Young Shine Import And Export Trading Co., Ltd, Pingyang County Muyi Craft Gift Factory, Shanghai Purameta Technology Co., Ltd., Shaoxing Baiyou E-Commerce Co., Ltd., Shenzhen Baoyunjia Technology Co., Ltd., Shenzhen Bojielunsen Technology Co., Ltd., Shenzhen CPYP Technology Co., Ltd., Shenzhen Feifan Lingyue Development Technology Co., Ltd., Shenzhen Good Time Technology Co., Ltd., Shenzhen Haishan Technology Co., Ltd., Shenzhen Kelemi Model Technology Co., Ltd., Shenzhen Meisiyu Electronic Technology Co., Ltd., Shenzhen Nise Techology Co., Ltd., Shenzhen Onecloud Technology Co., Ltd., Shenzhen Perfect Idea Tech. Co., Ltd., Shenzhen Puzhen Industrial Co., Ltd., Shenzhen ScPanda Technology Co., Limited, Shenzhen Youngeast Technology Co., Ltd., Shenzhen Zhihui Trading Co., Ltd., Suzhou Winours Technology Co., Ltd., Wenzhou Boyo Electric Appliance Co., Limited, Wenzhou Langtu Electronics Co., Ltd., Wenzhou Pengli Electric Appliance Co., Ltd., Wuhan Jiuchuteng Technology Co., Ltd., Xiamen Homejoy Technology Co., Ltd., Xingtai Tongbu Trade Co., Ltd., Yiwu Haoyue Supply Chain Management Co., Ltd., Yiwu Hengli Network Technology Co., Ltd., Yiwu Queyu E-Commerce Firm, Yiwu Xichou Trading Co., Ltd., Yiwu Xiyu Trading Company Ltd., Yiwu Yifeng Import And Export Co., Ltd., Yuyao CZMS Trade Co., Ltd., Yuyao Joys Electrical Appliance Co., Ltd., Zhejiang Guanghui Electronic Co., Ltd., ChenhaoHu, DiShengZhouUS, limengtingfafa, shidanshanmao, TOP Shop, yiyangkuajing, fadacai10, jiekk Store, csyb168, delbeauty, delbigstore, delgoodlife, duoerlan95, JZCX Deal Smart, jzcxfreego, jzcxkingtu, saywe1, sdenjoysport, ybbigmall, ybenjoyshopping, ybsupers23, bizzareplant, Cozy time, Daiyishop, Goodme, Honest Healthcare, INSMART, Jinyon, Qtultex, ShenZhenShi JiuZhiShuo Network Technology Co., Ltd and YasiLing Trade Co., Ltd added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction 33

Declaration of Justin T. Joseph

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 33 before Honorable Manish S. Shah on 6/26/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/21/2024, answer due 7/12/2024.

NEW PARTIES: Beijing Cypselurus Technology Co., Ltd., Chongqing Niannianfa Technology Co., Ltd., Dongguan Nigo Smart Electric Co., Ltd., Foshan Huichuang Boyao Import And Export Co., Ltd., Guangzhou Tengyun Electric Appliance Co., LTD., Guangzhou Youxin Import And Export Co., Ltd., Huaibei Yueershi Technology Co., Ltd., Huizhou Jinyuanduo Technology Co., Ltd., Immortal (kunming) Technology Co., Ltd., Longyan Dousen Trading Co., Ltd., Luweisi (shenzhen) Technology Co., Ltd., Ningbo Eyoja Technology Development Co., Ltd., Ningbo Fix Dollar Import & Export Co., Ltd., Ningbo Young Shine Import And Export Trading Co., Ltd, Pingyang County Muyi Craft Gift Factory, Shanghai Purameta Technology Co., Ltd., Shaoxing Baiyou E-Commerce Co., Ltd., Shenzhen Baoyunjia Technology Co., Ltd., Shenzhen Bojielunsen Technology Co., Ltd., Shenzhen CPYP Technology Co., Ltd., Shenzhen Feifan Lingyue Development Technology Co., Ltd., Shenzhen Good Time Technology Co., Ltd., Shenzhen Haishan Technology Co., Ltd., Shenzhen Kelemi Model Technology Co., Ltd., Shenzhen Meisiyu Electronic Technology Co., Ltd., Shenzhen Nise Techology Co., Ltd., Shenzhen Onecloud Technology Co., Ltd., Shenzhen Perfect Idea Tech. Co., Ltd., Shenzhen Puzhen Industrial Co., Ltd., Shenzhen ScPanda Technology Co., Limited, Shenzhen Youngeast Technology Co., Ltd., Shenzhen Zhihui Trading Co., Ltd., Suzhou Winours Technology Co., Ltd., Wenzhou Boyo Electric Appliance Co., Limited, Wenzhou Langtu Electronics Co., Ltd., Wenzhou Pengli Electric Appliance Co., Ltd., Wuhan Jiuchuteng Technology Co., Ltd., Xiamen Homejoy Technology Co., Ltd., Xingtai Tongbu Trade Co., Ltd., Yiwu Haoyue Supply Chain Management Co., Ltd., Yiwu Hengli Network Technology Co., Ltd., Yiwu Queyu E-Commerce Firm, Yiwu Xichou Trading Co., Ltd., Yiwu Xiyu Trading Company Ltd., Yiwu Yifeng Import And Export Co., Ltd., Yuyao CZMS Trade Co., Ltd., Yuyao Joys Electrical Appliance Co., Ltd., Zhejiang Guanghui Electronic Co., Ltd., ChenhaoHu, DiShengZhouUS, limengtingfafa, shidanshanmao, TOP Shop, yiyangkuajing, fadacai10, jiekk Store, csyb168, delbeauty, delbigstore, delgoodlife, duoerlan95, JZCX Deal Smart, jzcxfreego, jzcxkingtu, saywe1, sdenjoysport, ybbigmall, ybenjoyshopping, ybsupers23, bizzareplant, Cozy time, Daiyishop, Goodme, Honest Healthcare, INSMART, Jinyon, Qtultex, ShenZhenShi JiuZhiShuo Network Technology Co., Ltd and YasiLing Trade Co., Ltd added to case caption. (Text entry; no document attached.)

Declaration of Andrew D. Burnham

(Exhibit A)

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Kahlia Roe Halpern

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 32 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 6/26/2024. Notices Mailed.

ATTORNEY Appearance for Defendant Shanghai Purameta Technology Co., Ltd. by Christopher Paul Keleher

ATTORNEY Appearance for Defendant bizzareplant by Haipeng Xiao

ANSWER to Complaint with Jury Demand by bizzareplant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendants

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

MOTION by Plaintiff Dyson Technology Limited to compel Defendant Shanghai Purameta Technology Co., Ltd.

(Exhibit A)

DECLARATION of Andrew D. Burnham regarding motion to compel 46

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion to compel 46 before Honorable Manish S. Shah on 8/6/2024 at 09:45 AM.

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open Court, plaintiff's motion to compel [46] is denied. Mailed notice

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

MOTION by Attorney Christopher Keleher to withdraw as attorney for Shanghai Purameta Technology Co., Ltd. New address information: Haiyong Ye, email address at shfacecare@aliyun.com, physical address is Floor 2, Building 3, No.1036 Xizha Road, Fengxian District, Shanghai, China

(UNOPPOSED) NOTICE of Motion by Christopher Paul Keleher for presentment of motion to withdraw as attorney, [52] before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion to withdraw as attorney 52 is granted. Attorney Christopher Paul Keleher is terminated as counsel for defendant. Business organizations cannot appear in federal court without counsel. If new counsel does not appear by 9/10/24, Shanghai Purameta Technology will be in default. Mailed notice

STIPULATION of Dismissal as to a certain Defendant (Joint)

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Trevor Christian Talhami

ATTORNEY Appearance for Defendant Shanghai Purameta Technology Co., Ltd. by Pete Scott Wolfgram

MAILED patent report to Patent Trademark Office, Alexandria VA. (jn,)

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

MINUTE entry before the Honorable Manish S. Shah: Plaintiff shall file a status report by 11/26/24 with a proposed schedule for litigating the case with any remaining parties. Plaintiff's notices of voluntary dismissal that allow for reinstatement of claims are not endorsed by the court and do not comply with Fed. R. Civ. P. 41(a)(2). Notices Mailed.

MOTION by Plaintiff Dyson Technology Limited to approve consent judgment as to a certain Defendant (Agreed)

(Exhibit A)

MOTION by Plaintiff Dyson Technology Limited for entry of default, MOTION by Plaintiff Dyson Technology Limited for default judgment as to certain Defendants

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for entry of default, motion for default judgment 63

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 64

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment 63, motion to approve consent judgment 62 before Honorable Manish S. Shah on 12/10/2024 at 09:45 AM.

(Exhibit A)

STATUS Report pursuant to 61 by Dyson Technology Limited

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motions to approve consent judgment 62 and for entry of default judgment 63 are granted. Enter Consent Judgment. Enter Default Judgment Order. Terminate civil case. Notices Mailed.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 12/10/2024. Notices Mailed.

FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/10/2024. Notices Mailed.

MAILED patent report to Patent Trademark Office, Alexandria VA. (jn,)

MAILED patent report with certified copy of minute order dated 12/10/2024 to Patent Trademark Office, Alexandria VA. (jn,)

FULL SATISFACTION of Judgment regarding order 70 in the amount of the Judgment Amount as to certain defendant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

NOTICE of Removal of material from the custody of the Clerk's Office by Dyson Technology Limited. Document # 24. (jn,)