2025-cv-01975

COMPLAINT against SCHEDULE A DEFENDANTS (Filing fee, including Administrative fee, $405, receipt number APAWDC-9257924), filed by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

Civil Cover Sheet

Exhibit 1

Exhibit 2

Exhibit 4

Exhibit 5

(Exhibit 6)

MOTION for Leave to File Documents Under Seal Schedule A by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

(Proposed Order)

MOTION for Temporary Restraining Order, MOTION to Expedite Discovery, MOTION for Preliminary Injunction, MOTION for Order Restraining Assets and Storefronts by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

(Proposed Order)

BRIEF in Support re 3 Motion for TRO, Motion to Expedite, Motion for Preliminary Injunction, Motion for Order Restraining Assets and Storefronts, filed by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

Declaration Mitchell Declaration

(Declaration Liao Declaration) Modified text on 12/19/2025 to identify miscellaneous relief. (ept)

MOTION for Leave to File Excess Pages by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

(Proposed Order)

MOTION for Alternative Service by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

(Proposed Order)

BRIEF in Support re 6 Motion for Alternative Service filed by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

Disclosure Statement identifying None as corporate parent or other affiliate, declaring citizenship by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

NOTICE of Appearance by Michael Mitchell on behalf of DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

NOTICE of Appearance by Abby Marie Neu on behalf of DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

NOTICE of Appearance by Keaton David Smith on behalf of DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

Judge W. Scott Hardy added.

PATENT/TRADEMARK DOCUMENTS ISSUED.

Complaint

Exhibit 1

Exhibit 2

Exhibit 4

Exhibit 5

Exhibit 6

(Docket Sheet) (tla)

SEALED ORDER granting 2 Motion for Leave to File Documents Under Seal. Signed by Judge W. Scott Hardy on 12/22/25.

SEALED ORDER granting 5 Plaintiff's Motion to Exceed Page Limit. Signed by Judge W. Scott Hardy on 12/22/25.

SEALED ORDER granting 6 Plaintiff's Motion for an Order Authorizing Alternative Service. Signed by Judge W. Scott Hardy on 12/22/25.

SEALED DOCUMENT by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD. This document Sealed pursuant to 13 Sealed Order.

SEALED EXHIBIT in support of Complaint Schedule A by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD pursuant to 13 Sealed Order.

SEALED EXHIBIT in support of Complaint Exhibit 3 by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD pursuant to 13 Sealed Order.

Exhibit 3-2

Exhibit 3-3

(Exhibit 3-4)

SEALED DOCUMENT by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD. This document Sealed pursuant to 13 Sealed Order.

Set/Reset Hearings: Show Cause Hearing is set for 1/6/2026 at 10:00 AM in Courtroom 3B before Judge W. Scott Hardy.

SEALED ORDER granting 3 Motion for Temporary Restraining Order. Opposing papers, if any, shall be filed electronically with the Court and served on Plaintiff's Counsel at least one business day before the Show Cause Hearing. A Show Cause Hearing on Preliminary Injunction is set for 1/6/2026 at 10:00 AM in Courtroom 3B before Judge W. Scott Hardy. See Order for further details. Signed by Judge W. Scott Hardy on 12/23/2025. (kas) Modified text on 12/23/2025.

SEALED ORDER indicating that, upon consideration of 3 Plaintiff's Ex Parte Motion for TRO/Preliminary Injunction, Plaintiff shall supplement its Motion for TRO/PI, Memoranda of Law, and supporting declarations and exhibits by close of business on 1/5/2026 as further set forth in the Court's Order. See Order for further details. Signed by Judge W. Scott Hardy on 12/23/2025.

Set/Reset Hearings: Show Cause Hearing is set for 1/6/2026 at 10:00 AM in Courtroom 3B before Judge W. Scott Hardy.

Surety BOND in the amount of $50,000, posted by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD NGM Insurance Company as Surety.

MOTION to Extend Time to Temporary Restraining Order by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

(Proposed Order)

BRIEF in Support re 23 Motion to Extend Time filed by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

(Declaration Mitchell Declaration)

STATUS REPORT by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

SEALED ORDER granting 23 Motion to Extend Temporary Restraining Order. Signed by Judge W. Scott Hardy on 1/5/2026.

Set/Reset Hearings: Show Cause Hearing set for 1/16/2026 11:30 AM in Courtroom 3B before Judge W. Scott Hardy.

NOTICE of Voluntary Dismissal as to Defendant SZHexuan (Def. 1) by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD

SEALED ORDER indicating that the Show Cause Hearing set for 1/16/2026 is rescheduled for 1/20/2026 at 9:30 AM in Courtroom 3B before Judge W. Scott Hardy. Signed by Judge W. Scott Hardy on 1/9/2026.

NOTICE TO ALL PARTIES: This Court has implemented new Practices and Procedures for Judge W. Scott Hardy effective 1/1/26. These Practices and Procedures can be found on the Court's website at https://www.pawd.uscourts.gov/content/w-scott-hardy-district-judge. Text-only entry. No PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

PRAECIPE to Issue Summons by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD

(Summons)

Summons Issued as to SCHEDULE A DEFENDANTS

NOTICE of Voluntary Dismissal as to Defendants accessories.ltd (Def. 42), aghaffar-333 (Def. 43), ats_digilabs (Def. 44), Boyce.Int.Ltd (Def. 45), discounted7 (Def. 46), Discounthouse (Def. 47), emmerichx (Def. 48), Flex Sell Ltd (Def. 50), Fynn-ValueVault (Def. 51), Gamehood (Def. 52), giovmasc-81 (Def. 53), han9985 (Def. 54), iaenter (Def. 55), kamrav19 (Def. 59), lukeblagden (Def. 61), luxurythe (Def. 62), magic-outlet365 (Def. 63), My Best French Shop (Def. 66), nickypickles2508 (Def. 67), pragyuk (Def. 69), pureperks (Def. 70), Pytek Shop (Def. 71), Robinson_Retail2024 (Def. 73), Sajfs-286 (Def. 75), samiyhusn0 (Def. 76), slixtar_enterprises (Def. 78), uk-retro (Def. 81), variety-dealsstore (Def. 82), wojcglo45 (Def. 84), women_shoes_clothes (Def. 85), yamark_uk (Def. 86), and zeppozstarlimited (Def. 88) by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD

NOTICE of Voluntary Dismissal as to Defendant Nu Lifestyle Marketing LLC (Def. #15) by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD

SUMMONS/Return of Service Returned Executed by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD. SCHEDULE A DEFENDANTS served on 1/13/2025, answer due 2/3/2025.

Declaration Mitchell Declaration

Exhibit Schedule A

Errata re 33 Notice of Voluntary Dismissal by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD. Reason for Correction: Dismissal with Prejudice.

Proposed Order re 3 Motion for TRO, Motion to Expedite, Motion for Preliminary Injunction, Motion for Miscellaneous Relief, by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

STATUS REPORT by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

Minute Entry for proceedings held before Judge W. Scott Hardy: Show Cause Hearing held on 1/20/2026. (Court Reporter: J. Fisher)

PRELIMINARY INJUNCTION ORDER. The Clerk of Court is hereby directed to unseal all documents previously filed under seal in this case. See Order for further details. Signed by Judge W. Scott Hardy on 1/20/2026.

ORDER indicating that Plaintiff is directed to file the Unredacted Complaint and add all defendants to the Docket in accordance with the Schedule A instructions for filers available on the Court's website. Signed by Judge W. Scott Hardy on 1/22/2026. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Order

UNREDACTED COMPLAINT against AFB SOOCOOL DIRECT, BERNADA MARKETPLACE, CANGRUIDIANPU, CAOHENGJUN, DALIAN GUYUFENGHONG TRADING CO., LTD., DHINGU ENTERPRISE, FLYING US, IBIS UNLIMITED LLC, JINGYE1, JINJIANG YINGHUO YINMENG INTERNATIONAL TRADE CO., LTD, LONGKOUCHENGHEYIXINGSHANGMAOYOUXIANGONGSI, LYJUN-US, MLCLL US, MONEY SAVING SHOPS, NU LIFESTYLE MARKETING LLC, ONEMARKET SHOPPE, RICHARD DOU, RSN GROUP, SAMCHYNSKYI21, SHELL'S, SHHUAKEJI-US, SUXIAOQING, THE LAKESIDE COLLECTION, US HT, VOYAGE TRADE, WENZHOURONGHUIFALANGUANJIANYOUXIANGONGSI, YAN STORE113, YDX SHOP, YISHUODIANZI, YJIN-US, YONGCHUNXIANFABAMAOYIYOUXIANGONGSI, YONGCHUNXIANQINYERONGMAOYIYOUXIANGONGSI, YUING, YUJIEE STORE, ZWSTARS, A1YSHEEP4DMDO7, A3D3B8H0ACI39U, A1WZME46JRXBDM, AP0K7FWXWXCIS, A3KL77M6C2MQR7, A25ZGU35WMQZIC, ACCESSORIES.LTD, AGHAFFAR-333, ATS_DIGILABS, BOYCE.INT.LTD, DISCOUNTED7, DISCOUNTHOUSE, EMMERICHX, FEEL CAMERA, FLEX SELL LTD, FYNN-VALUEVAULT, GAMEHOOD, GIOVMASC-81, HAN9985, IAENTER, IZU-SHOP.JAPAN, JAPANACCESS, JAPAN-LIMIT, KAMRAV19, K'S JAPAN BRAND STORE, LUKEBLAGDEN, LUXURYTHE, MAGIC-OUTLET365, MIRUM JULIUS, MUZLEE85, MY BEST FRENCH SHOP, NICKYPICKLES2508, NRSYOKAI1, PRAGYUK, PUREPERKS, PYTEK SHOP, RISUKE, ROBINSON_RETAIL2024, RYMIZU93, SAJFS-286, SAMIYHUSN0, SKY WHITE DIAMOND, SLIXTAR_ENTERPRISES, SUPERDEALS_25, TRENDYMART_17, UK-RETRO, VARIETY-DEALSSTORE, WILLPARTNERS1964, WOJCGLO45, WOMEN_SHOES_CLOTHES, YAMARK_UK, YUTSU_JAPAN, ZEPPOZSTARLIMITED, BBTS, BBTS N2, BBTS NEO, COLLECTIONS ETC, CONQUEROR STORE, GULGUL, LINDISHIPIN, SUIYU TRADING, SZHEXUAN, WASSERSTEIN, WDTIE, YABUWANJU, filed by DONGGUAN TESIMAI ELECTRONIC TECHNOLOGY CO., LTD.

Exhibit 1

Exhibit 2

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 4

Exhibit 5

Exhibit 6

(Exhibit Schedule A)

RESPONSE IN OPPOSITION to 3 Motion for TRO, Motion to Expedite, Motion for Preliminary Injunction, Motion for Restraining Assets and Storefronts, 39 Preliminary Injunction, filed by SCHEDULE A DEFENDANTS.

(Exhibit Consent to Electronic Notice) Relief title added. Modified text on 1/28/2026. (tla)