2025-cv-00851

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 405, receipt number BILNDC-22997731.

Exhibit 2

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

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

(Exhibit 1-1)

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

CIVIL Cover Sheet

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 1).

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.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

NEW PARTIES: Dongguan Guitong Electronic Technology Co., Ltd., Dongguan Ren Woxing Energy Technology Co., Ltd., aidihua, anhongmaoyi zhongxin, bagen, Benoone, Dioedoecing, Hsealosaoy, JGTM Battery, JoyKey-US, liangyubest, Mccepar Direct-US, Mento-US, MYY DIRECT, PASHITA US, Tiawnger, TopServeStore, Wensususy-US, YAGU Direct-US, YANGLIJUAN, ZJEOSO-US, Battery&Jun, BatteryArsenal, BatteryEssentials, bossakku, courageous, DynamoWorks2020, EnergyFlare, EnergyMax2024, PowerBlaze2018, PowerEdge2024, RapidBattery, SwiftBattery, ToolsGal, VoltCharge, ZUOLV Auto Parts, BBAUIW, DongTaowo, foshanshijiahouyushangmao, foshanshishaalanshangmao, foshanxinguangmaoyi, Honiture Official Store, houepaixun1967511l, huileishangmaoyouxiangongsi, jiahefukeji, jianlaorenyuan2t, luzhuang19770212, PowerWings, xingmengyuanmaoyi, yahanmoshangmao, yinchuanshizhiyushangmao and YTHYTHYTH added to case caption.

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

MAILED Patent report to Patent Trademark Office, Alexandria VA.

((List of Patents))

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 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

DECLARATION of Giles Samuel Lane regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 2 - Part 1 regarding declaration 16

(Exhibit 2-1)

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 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 4, motion for miscellaneous relief 18, motion for temporary restraining order 13 before Honorable Manish S. Shah on 2/4/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 2/4/25 is necessary. Plaintiff's ex parte motions are under advisement and the court will rule by cm/ecf.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 4 13 18 are granted. The court has doubts that any value attributed to the accused products is a derived from the ornamental design (as opposed to the product's functional compatibility with plaintiff's products). Enter Sealed TRO. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 2/4/2025. Notices mailed.

Registry Deposit Information Form by Dyson Technology Limited

SURETY BOND in the amount of $ 50,000.00 posted by Dyson Technology Limited

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction 26

DECLARATION of Justin T. Joseph regarding memorandum in support of motion 27

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 26 before Honorable Manish S. Shah on 2/18/2025 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 2/12/2025, answer due 3/5/2025.

Declaration of Andrew D. Burnham

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 26 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 2/18/2025. Notices mailed.

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

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

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

ATTORNEY Appearance for Defendant PASHITA US by Christopher Paul Keleher

MOTION by Defendant PASHITA US for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[38] before Honorable Manish S. Shah on 4/2/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 38 is granted, and no appearance is necessary. Defendant 15 PASHITA US (A3N0L03TW11VGB) has until 4/16/25 to respond to the complaint. Notices Mailed.

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

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to a certain Defendant

MOTION by Plaintiff Dyson Technology Limited for entry of default, MOTION by Plaintiff Dyson Technology Limited for default judgment as to all Defendants with the exception of a certain Defendant

Exhibit A

MEMORANDUM by Dyson Technology Limited in support of motion for entry of default, motion for default judgment, [43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment, [43] before Honorable Manish S. Shah on 4/10/2025 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Luana Faria De Souza (Faria De Souza, Luana)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 43 is granted. Enter Default Judgment Order. Defendant 15 has until 4/16/25 to respond to the complaint. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 4/10/2025. Notices Mailed.

MOTION by Defendant PASHITA US for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[50] before Honorable Manish S. Shah on 4/30/2025 at 09:45 AM.

FULL SATISFACTION of Judgment regarding order[49] in the amount of The Judgment Amounts as to certain defendant

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer [50] is granted, and no appearance is necessary. Defendant No. 15, PASHITA US, has until 5/14/25 to respond to the complaint. The parties shall file a joint status report proposing a case schedule by 5/14/25. Notices Mailed.

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to Defendant PASHITA US

STATUS Report per [48] by Dyson Technology Limited

MINUTE entry before the Honorable Manish S. Shah: All of plaintiff's claims having been resolved, this case is dismissed. Civil case terminated. Notices Mailed.

FULL SATISFACTION of Judgment regarding order[49] as to a certain Defendant