2025-cv-14403

COMPLAINT filed by Kuiper Ventures LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-24400280.

Redacted Schedule A

Exhibit 1 - Redacted

Exhibit 2 - Redacted

(Civil Cover Sheet)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kuiper Ventures LLC

MOTION by Plaintiff Kuiper Ventures LLC to seal document complaint, 1

MOTION by Plaintiff Kuiper Ventures LLC to seal document complaint, 1 CORRECTED

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motions to file under seal [3][4] are granted. Plaintiff is to file the documents unredacted under seal by 12/8/25. Mailed notice.

SEALED DOCUMENT by Plaintiff Kuiper Ventures LLC Verified Complaint & Exhibits

Miscellaneous Relief

Order on Motion for Miscellaneous Relief

MOTION by Plaintiff Kuiper Ventures LLC for temporary restraining order, MOTION by Plaintiff Kuiper Ventures LLCtemporary restraining order, early discovery, asset restraint, MOTION by Plaintiff Kuiper Ventures LLC for discovery early

MEMORANDUM by Kuiper Ventures LLC in support of motion for temporary restraining order, motion for miscellaneous relief, motion for discovery, [10]

Exhibit 1 - Patent at Issue

Exhibit 2 - Declaration of N. Jermolenko

MOTION by Plaintiff Kuiper Ventures LLC to seal document sealed document, [11]

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to seal [13] is granted. The Court grants Plaintiff's motion for a Temporary Restraining Order [10]. Plaintiff is to send a proposed TRO to the Court's proposed order box for review. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 12/9/2025.

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Xuanjie Wang for Defendant Bedsure

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Hao Tan for Defendant Bedshe

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Yu Di for Defendant Bedsure

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Christopher James Fahy for Defendant Bedsure

Registry Deposit Information Form by Kuiper Ventures LLC

BOND in the amount of $4000.00 cashier's check, Receipt No. 100027658, posted by Kuiper Ventures LLC

ATTORNEY Appearance for Defendant Elite Collection US by David Silver

SEALED MOTION by Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The motion to seal for Defendant Bedsure

SEALED MOTION by Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The DEFENDANTS EMERGENCY OPPOSED MOTION TO MODIFY TRO for Defendant Bedsure

SEALED DOCUMENT by Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The MEMORANDUM IN SUPPORT OF EMERGENCY OPPOSED MOTION TO MODIFY TRO for Defendant Bedsure

MEMORANDUM by Kuiper Ventures LLC in Opposition to Sealed motion, [23]

Exhibit 1 - Email Chain

Exhibit 2 - Declaration of N. Jermolenko

Exhibit 3 - Declaration of Counsel

SEALED DOCUMENT by Plaintiff Kuiper Ventures LLC Unredacted Declaration of Nathan Jermolenko

MOTION by Plaintiff Kuiper Ventures LLC to seal document sealed document[26]

MOTION by Plaintiff Kuiper Ventures LLC to amend/correct SEALED Order[15] to Modify Asset Restraint of Defendant 1-Bedsure

MOTION by Plaintiff Kuiper Ventures LLC to amend/correct SEALED Order[15] to Modify Asset Restraint of Defendants 3 and 4

MOTION by Plaintiff Kuiper Ventures LLC to unseal document sealed document, [11], sealed document[26], SEALED Order[15], sealed document, [6]

MINUTE entry before the Honorable Mary M. Rowland: The Court has considered Plaintiff's motion to modify the asset restraint. [29]. That motion is granted. Enter order. Defendant Bedsure's motion to modify the TRO [23] is denied as moot. The parties' motions to seal [22] and [27] are granted. Mailed notice.

ORDER Signed by the Honorable Mary M. Rowland on 12/23/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to unseal documents [30] is granted. The Clerk is directed to unseal documents [6][11][15] and [26]. Mailed notice.

MOTION by Plaintiff Kuiper Ventures LLC early discovery re: Amazon takedowns against Plaintiff and follow up messages

MEMORANDUM by Kuiper Ventures LLC in support of motion for miscellaneous relief[34]

Exhibit 1 - Messages Suggesting Takedowns Would Be Removed In Exchange for Sett

Exhibit 2 - Takedown Dashboard and Response

MOTION by Plaintiff Kuiper Ventures LLC for extension of time of Temporary Restraining Order

NEW PARTIES: Bedshe International Co., Ltd., SUZHOU LIMIT TRADING CO.,LTD. and Changshushizhilankejiyouxiangongsi added to case caption.

MEMORANDUM by Kuiper Ventures LLC in support of extension of time[36]

Exhibit 1 - Declaration of Counsel

MOTION by Plaintiff Kuiper Ventures LLC for extension of time to file for extension of TRO.

Exhibit 1 - Declaration of Counsel

SUMMONS Submitted (Court Participant) for defendant(s) changshushizhilankejiyouxiangongsi (Def. 4) by Plaintiff Kuiper Ventures LLC

SUMMONS Submitted (Court Participant) for defendant(s) BEDSHE INTERNATIONAL CO., LTD (Def. 1) by Plaintiff Kuiper Ventures LLC

SUMMONS Submitted (Court Participant) for defendant(s) SUZHOU LIMIT TRADING CO.,LTD. (Def. 3) by Plaintiff Kuiper Ventures LLC

NOTICE of Voluntary Dismissal by Kuiper Ventures LLC of guawodianzishangwuyixingyouxiangongsi d/b/a Elite Collection US (Defendant 2

SUMMONS - ERROR UNPROCESSED due to an order is required to issue a summons applicable to all defendants, or those that differ from the case caption of the complaint filed.

SUMMONS Submitted (Court Participant) for defendant(s) Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associates Identified On Schedule A by Plaintiff Kuiper Ventures LLC

MOTION by Plaintiff Kuiper Ventures LLC for preliminary injunction

MEMORANDUM by Kuiper Ventures LLC in support of motion for preliminary injunction[44]

Exhibit 1 - Patent at Issue

Exhibit 2 - Declaration of N. Jermolenko re: investigation

Exhibit 3 - Declaration of Counsel

Exhibit 4 - Declaration of N. Jermolenko re: Bedsure

Exhibit 5 - Declaration of N. Jermolenko re: Plush & Plaid

Exhibit 6 - Declaration of N. Jermolenko re: Sochow

MEMORANDUM by Kuiper Ventures LLC in support of motion for preliminary injunction[44] CORRECTED

Exhibit 1 - Patent at Issue

Exhibit 2 - Declaration of N. Jermolenko re: investigation

Exhibit 3 - Declaration of Counsel

Exhibit 4 - Declaration of N. Jermolenko re Bedsure

Exhibit 5 - Declaration of N. Jermolenko re: Plush & Plaid

Exhibit 6 - Declaration of N. Jermolenko re: Sochow

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/31/2025: Mailed notice.

SUMMONS - ERROR UNPROCESSED due to an order is required to issue a summons applicable to all defendants, or those that differ from the case caption of the complaint filed.