2025-cv-26096

COMPLAINT against The Partnerships, Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-19071892, filed by ZHAOZHE WU.

Exhibit Ex. 1 - Copyright Registration Information

Exhibit Ex. 2 - US CBP Report

Exhibit Ex. 3 - Law Journal Article

Exhibit Ex. 4 - US DHS Report

Civil Cover Sheet 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 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE

Complaint with Exhibits

Amended Complaint/Amended Notice of Removal

Order Requiring Joint Scheduling Report

- Order (PAPERLESS or pdf attached)

Plaintiff's MOTION for Temporary Restraining Order by Zhaozhe Wu. Responses due by 1/16/2026.

Exhibit Ex. 1 - Copyright Registration Information

Exhibit Ex. 2 - Declaration of Andrew Palmer in support of Motion

Exhibit Ex. 3 - Declaration of Zhaozhe Wu in support of Motion

Exhibit Ex. 4 - Infringing Evidence Part 1

Exhibit Ex. 5 - Infringing Evidence Part 2

Exhibit Ex. 6 - Infringing Evidence Part 3

Exhibit Ex. 7 - Infringing Evidence Part 4

Plaintiff's MOTION for Service by Publication and email pursuant to Rule 4(f)(3) by Zhaozhe Wu.

Exhibit Ex. 1 - Declaration of Palmer in support of Motion

CERTIFICATE of Counsel re [6] Order Certification Regarding Prior Suits by Andrew Jonathan Palmer on behalf of Zhaozhe Wu

Order on Motion for Temporary Restraining Order

Order on Motion for Service by Publication

Clerks Receipt for Bond per Order at DE #10 received on 1/6/2026 in the amount of $ 10,000.00, receipt number 21313

NOTICE of Filing Proposed Summons(es) by Zhaozhe Wu re 11 Order on Motion for Service by Publication

(Exhibit proposed summons)

Summons Issued as to The Partnerships, Unincorporated Associations Identified on Schedule A.

MOTION for Extension of Time to File Motion for Preliminary Injunction re 10 Order on Motion for Temporary Restraining Order, by Zhaozhe Wu.

Order on Motion for Miscellaneous Relief

PAPERLESS ORDER granting ECF No. 15, Motion for Extension of Time to File Motion for Preliminary Inunction. Plaintiff shall file its motion for a preliminary injunction no later than January 16, 2026. Signed by Judge Beth Bloom

SUMMONS (Affidavit) Returned Executed on 4 Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Zhaozhe Wu. 888AngelCitn served on 1/14/2026, response/answer due 2/4/2026; alonghalf served on 1/14/2026, response/answer due 2/4/2026; Ausyst served on 1/14/2026, response/answer due 2/4/2026; Ayolanni served on 1/14/2026, response/answer due 2/4/2026; Biexsdw served on 1/14/2026, response/answer due 2/4/2026; Big off Fall&Winter Trendy Clothes 2025 served on 1/14/2026, response/answer due 2/4/2026; Biyxaw served on 1/14/2026, response/answer due 2/4/2026; Brand flagship store ->Gaexia served on 1/14/2026, response/answer due 2/4/2026; BSJLM served on 1/14/2026, response/answer due 2/4/2026; CaiShen- served on 1/14/2026, response/answer due 2/4/2026; Cerzetdf served on 1/14/2026, response/answer due 2/4/2026; chaiee served on 1/14/2026, response/answer due 2/4/2026; chao304zaifen served on 1/14/2026, response/answer due 2/4/2026; cheerBent served on 1/14/2026, response/answer due 2/4/2026; Chenxm served on 1/14/2026, response/answer due 2/4/2026; ChongHas served on 1/14/2026, response/answer due 2/4/2026; Cxquxse served on 1/14/2026, response/answer due 2/4/2026; DappyLINE served on 1/14/2026, response/answer due 2/4/2026; Derloar served on 1/14/2026, response/answer due 2/4/2026; dongguanshifeizhaoshangmaoyouxiangongsi served on 1/14/2026, response/answer due 2/4/2026; eipogp served on 1/14/2026, response/answer due 2/4/2026; Esn nazpy served on 1/14/2026, response/answer due 2/4/2026; Factory Sales Store served on 1/14/2026, response/answer due 2/4/2026; FAEXUM--Official Stores served on 1/14/2026, response/answer due 2/4/2026; fanwenen served on 1/14/2026, response/answer due 2/4/2026; Farmee--US served on 1/14/2026, response/answer due 2/4/2026; Fashion Customization Studio served on 1/14/2026, response/answer due 2/4/2026; fengkunhao served on 1/14/2026, response/answer due 2/4/2026; FFFish served on 1/14/2026, response/answer due 2/4/2026; Fitolos Direct served on 1/14/2026, response/answer due 2/4/2026; FPMLUXLL served on 1/14/2026, response/answer due 2/4/2026; FRODQYX Swimwear served on 1/14/2026, response/answer due 2/4/2026; Ftbreatwe served on 1/14/2026, response/answer due 2/4/2026; FuXiaEi Fashion Online served on 1/14/2026, response/answer due 2/4/2026; GAANBODI served on 1/14/2026, response/answer due 2/4/2026; Gdge served on 1/14/2026, response/answer due 2/4/2026; GMBIO served on 1/14/2026, response/answer due 2/4/2026; Goddess Sunflower served on 1/14/2026, response/answer due 2/4/2026; gogooday served on 1/14/2026, response/answer due 2/4/2026; GOOD93wyt5 served on 1/14/2026, response/answer due 2/4/2026; GoodVIS served on 1/14/2026, response/answer due 2/4/2026; Happy BN served on 1/14/2026, response/answer due 2/4/2026; Heevina served on 1/14/2026, response/answer due 2/4/2026; hgdgsygdnsh served on 1/14/2026, response/answer due 2/4/2026; huang jing qing served on 1/14/2026, response/answer due 2/4/2026; IceXue served on 1/14/2026, response/answer due 2/4/2026; ilovepajamas served on 1/14/2026, response/answer due 2/4/2026; Jiaochang served on 1/14/2026, response/answer due 2/4/2026; JiPan served on 1/14/2026, response/answer due 2/4/2026; Kai Nan Clothing served on 1/14/2026, response/answer due 2/4/2026; kangma served on 1/14/2026, response/answer due 2/4/2026; Kdemeng served on 1/14/2026, response/answer due 2/4/2026; Kids & Chic Womens Shop served on 1/14/2026, response/answer due 2/4/2026; Laueyweo served on 1/14/2026, response/answer due 2/4/2026; leileifushi served on 1/14/2026, response/answer due 2/4/2026; LiangjiaET served on 1/14/2026, response/answer due 2/4/2026; liaozhiyuan888 served on 1/14/2026, response/answer due 2/4/2026; lightning deals of today prime_ sdascdf served on 1/14/2026, response/answer due 2/4/2026; ligte023U served on 1/14/2026, response/answer due 2/4/2026; Lionmki served on 1/14/2026, response/answer due 2/4/2026; LIONVI served on 1/14/2026, response/answer due 2/4/2026; liujiaostore served on 1/14/2026, response/answer due 2/4/2026; LIXIAO served on 1/14/2026, response/answer due 2/4/2026; lLeahss served on 1/14/2026, response/answer due 2/4/2026; Lmcsosy served on 1/14/2026, response/answer due 2/4/2026; lvpengqin456 served on 1/14/2026, response/answer due 2/4/2026; LYSTAO ONLINE served on 1/14/2026, response/answer due 2/4/2026; MCHAOJIE served on 1/14/2026, response/answer due 2/4/2026; Mihxue served on 1/14/2026, response/answer due 2/4/2026; Moszsw served on 1/14/2026, response/answer due 2/4/2026; Mueiade served on 1/14/2026, response/answer due 2/4/2026; Nagub served on 1/14/2026, response/answer due 2/4/2026; OIFGH Direct served on 1/14/2026, response/answer due 2/4/2026; OUgifi served on 1/14/2026, response/answer due 2/4/2026; Ozzyunor served on 1/14/2026, response/answer due 2/4/2026; Pieux served on 1/14/2026, response/answer due 2/4/2026; Plufnvea served on 1/14/2026, response/answer due 2/4/2026; PmiYniV served on 1/14/2026, response/answer due 2/4/2026; Poogoi served on 1/14/2026, response/answer due 2/4/2026; Qbily Co., Ltd served on 1/14/2026, response/answer due 2/4/2026; qingzhuangFS served on 1/14/2026, response/answer due 2/4/2026; RenuppQ served on 1/14/2026, response/answer due 2/4/2026; SUNNNY Changsha Zhouhui Trading served on 1/14/2026, response/answer due 2/4/2026; supcoo served on 1/14/2026, response/answer due 2/4/2026; Tobhousehouse served on 1/14/2026, response/answer due 2/4/2026; tongli served on 1/14/2026, response/answer due 2/4/2026; TrendySSS served on 1/14/2026, response/answer due 2/4/2026; TYISZIL womens fashion served on 1/14/2026, response/answer due 2/4/2026; US Home Good served on 1/14/2026, response/answer due 2/4/2026; vuylizhen served on 1/14/2026, response/answer due 2/4/2026; Wenihue served on 1/14/2026, response/answer due 2/4/2026; White Christmas served on 1/14/2026, response/answer due 2/4/2026; Wlucking served on 1/14/2026, response/answer due 2/4/2026; Wonstyle served on 1/14/2026, response/answer due 2/4/2026; Wtnyiixh served on 1/14/2026, response/answer due 2/4/2026; WUCYAOTY served on 1/14/2026, response/answer due 2/4/2026; Xilung-US served on 1/14/2026, response/answer due 2/4/2026; XTaoTT served on 1/14/2026, response/answer due 2/4/2026; Xuesfans served on 1/14/2026, response/answer due 2/4/2026; YDNGF served on 1/14/2026, response/answer due 2/4/2026; yesai Fashion Clothes served on 1/14/2026, response/answer due 2/4/2026; yibgph served on 1/14/2026, response/answer due 2/4/2026; yidekuth served on 1/14/2026, response/answer due 2/4/2026; YMdhty served on 1/14/2026, response/answer due 2/4/2026; YNGHE served on 1/14/2026, response/answer due 2/4/2026; YOPUGEE-US served on 1/14/2026, response/answer due 2/4/2026; Yowein served on 1/14/2026, response/answer due 2/4/2026; Zhanussssssw Alano served on 1/14/2026, response/answer due 2/4/2026; ZhaoXinYouMao served on 1/14/2026, response/answer due 2/4/2026; ZiH served on 1/14/2026, response/answer due 2/4/2026; ZZX-lieksmie served on 1/14/2026, response/answer due 2/4/2026.

Plaintiff's MOTION for Preliminary Injunction by Zhaozhe Wu.

CERTIFICATE OF SERVICE by Zhaozhe Wu re 18 Plaintiff's MOTION for Preliminary Injunction

ORDER SETTING HEARING ON 18 MOTION FOR ENTRY OF PRELIMINARY INJUNCTION: A hearing is set before this Court at the Wilkie D. Ferguson, Jr. Courthouse, 400 N. Miami Ave., in Miami, FL 33128, in Courtroom 10-2 via Zoom video conference on January 22, 2026, at 11:30 a.m. Signed by Judge Beth Bloom on 1/15/2026. See attached document for full details.

CERTIFICATE OF SERVICE by Zhaozhe Wu re 20 Order Setting Hearing on Motion

RESPONSE in Opposition re 18 Plaintiff's MOTION for Preliminary Injunction filed by Ayolanni, Esn nazpy, FPMLUXLL, Farmee--US, FuXiaEi Fashion Online, GMBIO, IceXue, OIFGH Direct, PmiYniV, TYISZIL womens fashion, Wtnyiixh, XTaoTT, Xilung-US, ZhaoXinYouMao, yesai Fashion Clothes. Attorney Alan Mensa-Wilmot added to party Ayolanni(pty:dft), Attorney Alan Mensa-Wilmot added to party Esn nazpy(pty:dft), Attorney Alan Mensa-Wilmot added to party FPMLUXLL(pty:dft), Attorney Alan Mensa-Wilmot added to party Farmee--US(pty:dft), Attorney Alan Mensa-Wilmot added to party FuXiaEi Fashion Online(pty:dft), Attorney Alan Mensa-Wilmot added to party GMBIO(pty:dft), Attorney Alan Mensa-Wilmot added to party IceXue(pty:dft), Attorney Alan Mensa-Wilmot added to party OIFGH Direct(pty:dft), Attorney Alan Mensa-Wilmot added to party PmiYniV(pty:dft), Attorney Alan Mensa-Wilmot added to party TYISZIL womens fashion(pty:dft), Attorney Alan Mensa-Wilmot added to party Wtnyiixh(pty:dft), Attorney Alan Mensa-Wilmot added to party XTaoTT(pty:dft), Attorney Alan Mensa-Wilmot added to party Xilung-US(pty:dft), Attorney Alan Mensa-Wilmot added to party ZhaoXinYouMao(pty:dft), Attorney Alan Mensa-Wilmot added to party yesai Fashion Clothes(pty:dft). Replies due by 1/27/2026.

(Affidavit)

RESPONSE in Opposition re 18 Plaintiff's MOTION for Preliminary Injunction filed by 888AngelCitn, BSJLM, Biexsdw, Biyxaw, Brand flagship store ->Gaexia, CaiShen-, ChongHas, Cxquxse, DappyLINE, FAEXUM--Official Stores, Factory Sales Store, GOOD93wyt5, GoodVIS, Happy BN, JiPan, Kids & Chic Womens Shop, LIXIAO, LiangjiaET, Mihxue, Moszsw, Mueiade, OUgifi, Ozzyunor, Poogoi, RenuppQ, SUNNNY Changsha Zhouhui Trading, Tobhousehouse, US Home Good, WUCYAOTY, White Christmas, Xuesfans, YMdhty, YNGHE, Yowein, ZZX-lieksmie, Zhanussssssw Alano, alonghalf, chaiee, chao304zaifen, cheerBent, eipogp, gogooday, hgdgsygdnsh, kangma, lLeahss, liaozhiyuan888, lightning deals of today prime_ sdascdf, ligte023U, lvpengqin456, qingzhuangFS, tongli, vuylizhen, yibgph, yidekuth. Attorney Alan Mensa-Wilmot added to party 888AngelCitn(pty:dft), Attorney Alan Mensa-Wilmot added to party BSJLM(pty:dft), Attorney Alan Mensa-Wilmot added to party Biexsdw(pty:dft), Attorney Alan Mensa-Wilmot added to party Biyxaw(pty:dft), Attorney Alan Mensa-Wilmot added to party Brand flagship store ->Gaexia(pty:dft), Attorney Alan Mensa-Wilmot added to party CaiShen-(pty:dft), Attorney Alan Mensa-Wilmot added to party ChongHas(pty:dft), Attorney Alan Mensa-Wilmot added to party Cxquxse(pty:dft), Attorney Alan Mensa-Wilmot added to party DappyLINE(pty:dft), Attorney Alan Mensa-Wilmot added to party FAEXUM--Official Stores(pty:dft), Attorney Alan Mensa-Wilmot added to party Factory Sales Store(pty:dft), Attorney Alan Mensa-Wilmot added to party GOOD93wyt5(pty:dft), Attorney Alan Mensa-Wilmot added to party GoodVIS(pty:dft), Attorney Alan Mensa-Wilmot added to party Happy BN(pty:dft), Attorney Alan Mensa-Wilmot added to party JiPan(pty:dft), Attorney Alan Mensa-Wilmot added to party Kids & Chic Womens Shop(pty:dft), Attorney Alan Mensa-Wilmot added to party LIXIAO(pty:dft), Attorney Alan Mensa-Wilmot added to party LiangjiaET(pty:dft), Attorney Alan Mensa-Wilmot added to party Mihxue(pty:dft), Attorney Alan Mensa-Wilmot added to party Moszsw(pty:dft), Attorney Alan Mensa-Wilmot added to party Mueiade(pty:dft), Attorney Alan Mensa-Wilmot added to party OUgifi(pty:dft), Attorney Alan Mensa-Wilmot added to party Ozzyunor(pty:dft), Attorney Alan Mensa-Wilmot added to party Poogoi(pty:dft), Attorney Alan Mensa-Wilmot added to party RenuppQ(pty:dft), Attorney Alan Mensa-Wilmot added to party SUNNNY Changsha Zhouhui Trading(pty:dft), Attorney Alan Mensa-Wilmot added to party Tobhousehouse(pty:dft), Attorney Alan Mensa-Wilmot added to party US Home Good(pty:dft), Attorney Alan Mensa-Wilmot added to party WUCYAOTY(pty:dft), Attorney Alan Mensa-Wilmot added to party White Christmas(pty:dft), Attorney Alan Mensa-Wilmot added to party Xuesfans(pty:dft), Attorney Alan Mensa-Wilmot added to party YMdhty(pty:dft), Attorney Alan Mensa-Wilmot added to party YNGHE(pty:dft), Attorney Alan Mensa-Wilmot added to party Yowein(pty:dft), Attorney Alan Mensa-Wilmot added to party ZZX-lieksmie(pty:dft), Attorney Alan Mensa-Wilmot added to party Zhanussssssw Alano(pty:dft), Attorney Alan Mensa-Wilmot added to party alonghalf(pty:dft), Attorney Alan Mensa-Wilmot added to party chaiee(pty:dft), Attorney Alan Mensa-Wilmot added to party chao304zaifen(pty:dft), Attorney Alan Mensa-Wilmot added to party cheerBent(pty:dft), Attorney Alan Mensa-Wilmot added to party eipogp(pty:dft), Attorney Alan Mensa-Wilmot added to party gogooday(pty:dft), Attorney Alan Mensa-Wilmot added to party hgdgsygdnsh(pty:dft), Attorney Alan Mensa-Wilmot added to party kangma(pty:dft), Attorney Alan Mensa-Wilmot added to party lLeahss(pty:dft), Attorney Alan Mensa-Wilmot added to party liaozhiyuan888(pty:dft), Attorney Alan Mensa-Wilmot added to party lightning deals of today prime_ sdascdf(pty:dft), Attorney Alan Mensa-Wilmot added to party ligte023U(pty:dft), Attorney Alan Mensa-Wilmot added to party lvpengqin456(pty:dft), Attorney Alan Mensa-Wilmot added to party qingzhuangFS(pty:dft), Attorney Alan Mensa-Wilmot added to party tongli(pty:dft), Attorney Alan Mensa-Wilmot added to party vuylizhen(pty:dft), Attorney Alan Mensa-Wilmot added to party yibgph(pty:dft), Attorney Alan Mensa-Wilmot added to party yidekuth(pty:dft). Replies due by 1/27/2026.

Affidavit

(Affidavit)

RESPONSE in Opposition re 18 Plaintiff's MOTION for Preliminary Injunction filed by Cerzetdf, Goddess Sunflower, Heevina, Laueyweo, Lionmki, MCHAOJIE, Nagub, Plufnvea, TrendySSS. Attorney Alan Mensa-Wilmot added to party Cerzetdf(pty:dft), Attorney Alan Mensa-Wilmot added to party Goddess Sunflower(pty:dft), Attorney Alan Mensa-Wilmot added to party Heevina(pty:dft), Attorney Alan Mensa-Wilmot added to party Laueyweo(pty:dft), Attorney Alan Mensa-Wilmot added to party Lionmki(pty:dft), Attorney Alan Mensa-Wilmot added to party MCHAOJIE(pty:dft), Attorney Alan Mensa-Wilmot added to party Nagub(pty:dft), Attorney Alan Mensa-Wilmot added to party Plufnvea(pty:dft), Attorney Alan Mensa-Wilmot added to party TrendySSS(pty:dft). Replies due by 1/28/2026.

(Affidavit)

PAPERLESS ORDER denying 18 Motion for Preliminary Injunction for reasons stated on the record. Signed by Judge Beth Bloom

PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom:. Signed by Judge Beth Bloom, Evidentiary Hearing held on 1/22/2026. Counsel for the parties appeared. For the reasons stated on the record, Plaintiff's Motion for Preliminary Injunction, ECF No. 18, was denied. Total time in court: 20 minutes. Attorney Appearance(s): Alan Mensa-Wilmot, Andrew Jonathan Palmer, Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov.

NOTICE of Voluntary Dismissal as to Defendants Nos. 3, 11, 15, 27, 29, 30, 33, 36, 38, 43, 47, 50, 54, 60, 61, 65, 68, 72, 77, 80, 84, 87, 94 and 110 by Zhaozhe Wu

NOTICE of Voluntary Dismissal as to Defendants Nos. 1, 2, 4, 5, 7, 8, 9, 10, 12, 13, 14, 16, 17, 18, 21, 22, 23, 24, 26, 28, 31, 34, 37, 39, 40, 41, 42, 44, 46, 49, 51, 53, 56, 57, 58, 59, 63, 64, 66, 69, 70, 71, 73, 74, 75, 78, 79, 81, 82, 83, 85, 86, 88, 89, 90, 92, 93, 95, 96, 97, 98, 99, 101, 102, 103, 104, 105, 106, 107, 108, 109 and 111 by Zhaozhe Wu

(Text of Proposed Order proposed order)

Plaintiff's MOTION for Clerk's Entry of Default as to Big off Fall&Winter Trendy Clothes 2025, Derloar, FRODQYX Swimwear, GAANBODI, Jiaochang, Kdemeng, LYSTAO ONLINE, Pieux, Wenihue, YDNGF, dongguanshifeizhaoshangmaoyouxiangongsi, fanwenen, huang jing qing, leileifushi, liujiaostore by Zhaozhe Wu. Responses due by 2/19/2026.

Clerk's Entry of Default as to Big off Fall&Winter Trendy Clothes 2025, Derloar, FRODQYX Swimwear, GAANBODI, Jiaochang, Kdemeng, LYSTAO ONLINE, Pieux, Wenihue, YDNGF, dongguanshifeizhaoshangmaoyouxiangongsi, fanwenen, huang jing qing, leileifushi, liujiaostore - Granting: 29 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 2/5/2026.

ORDER ON DEFAULT JUDGMENT PROCEDURE: Plaintiff's failure to file a Motion for Default Judgment or Notice of Joint Liability within the specified time will result in sanctions, including but not limited to, dismissal without prejudice as to these defendants. Signed by Judge Beth Bloom on 2/5/2026. See attached document for full details.

Plaintiff's MOTION for Default Judgment by Zhaozhe Wu. Responses due by 2/27/2026.

Exhibit Ex. 1 - Declaration of Palmer in support of Motion

Text of Proposed Order Proposed Order

(Text of Proposed Order Proposed Order)

CERTIFICATE OF SERVICE by Zhaozhe Wu re 32 Plaintiff's MOTION for Default Judgment