Toka, LLC v. Schedule A Defendants

COMPLAINT against SCHEDULE A DEFENDANTS (Filing fee, including Administrative fee, $405, receipt number APAWDC-9426750), filed by TOKA, LLC.

Civil Cover Sheet

Exhibit 1

(Exhibit 2)

MOTION for Leave to File Documents Under Seal REDACTION WAIVER REQUESTED by TOKA, LLC.

(Proposed Order)

First MOTION for Temporary Restraining Order, MOTION ORDER RESTRAINING ASSETS AND MERCHANT STOREFRONTS, MOTION for Order to Show Cause Why a Preliminary Injunction Should Not Issue, MOTION to Expedite Discovery by TOKA, LLC.

Disclosure Statement identifying NONE as corporate parent or other affiliate by TOKA, LLC.

Chief Judge Cathy Bissoon added. (Text entry; no document attached.)

CLERK'S REQUEST FOR CORRECTIVE ACTION re 1 COMPLAINT. ERROR: Civil Cover Sheet missing the county for the plaintiff. CORRECTION: Filer to submit a corrected civil cover sheet by using the Errata event, linking it to the initial pleading. (Text entry; no document attached.)

ORDER governing procedures for motions filed under Fed. R. Civ. P. 12. See contents of this filing for instructions. Signed by Chief Judge Cathy Bissoon on 3/13/2026.

PATENT/TRADEMARK DOCUMENTS ISSUED.

Complaint

Exhibit 1

Exhibit 2

(Docket Sheet) (kss)

MOTION for Status Conference by TOKA, LLC.

CLERK'S REQUEST FOR CORRECTIVE ACTION re 7 MOTION for Status Conference. ERROR: Filer did not attach a Proposed Order as required by LCvR 7. CORRECTION: Filer to submit a proposed order using the Proposed Order event. Filer is to link the Proposed Order to the relevant motion in the event. (Text entry; no document attached.)

ORDER denying as moot 7 Motion for Status Conference. Plaintiff's reason for requesting the conference has been resolved. Signed by Chief Judge Cathy Bissoon on 4/24/2026. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

ORDER granting 2 MOTION for Leave to File Documents Under Seal. The redaction requirement is WAIVED. You are required to serve the sealed document on counsel using traditional service methods. Decision to Unseal Document deferred. Signed by Chief Judge Cathy Bissoon on 4/24/2026.

SEALED DOCUMENT This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by TOKA, LLC.

Proposed Order TRO

Declaration Joynt

Declaration Ference

Exhibit 1 - Intellectual Property Rights Seizure Statistics

Exhibit 2 - Northwestern Journal of International Law & Business

Exhibit 3 - Combatting Trafficking in Counterfeit and Pirated Goods

Declaration Odell

1 Composite

2 Composite

3 Composite

4 Composite

(5 Composite) Modified text on 4/27/2026 to correct event and terminate motion. (kss)

SEALED DOCUMENT This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by TOKA, LLC.

7 Composite

8 Composite

9 Composite

(10 Conposite) Modified text on 4/27/2026 to correct event and terminate motion. (kss)

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by TOKA, LLC. (Attachments: # 1 Proposed Order Exceed Page Limit) Document removed from view and refiled at 16. Motion terminated. Modified text on 4/27/2026.

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by TOKA, LLC.

Proposed Order Alternative Service

Exhibit

Declaration Ference

(Ference Exhibit)

SEALED DOCUMENT by TOKA, LLC. This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal.

CLERK'S NOTICE OF CORRECTION re 11 SEALED MOTION, 10 SEALED MOTION. ERROR: Wrong event selected. CORRECTION FOR FUTURE FILINGS: Clerk has redocketed the entry with the correct event, SEALED DOCUMENT. THIS MESSAGE IS FOR INFORMATIONAL PURPOSES ONLY AND NO FURTHER ACTION IS REQUIRED ON THE FILING AT ISSUE. (Text entry; no document attached.)

CLERK'S REQUEST FOR CORRECTIVE ACTION re 12 SEALED MOTION. ERROR: No case number on motion. CORRECTION: Filer is directed to file the document with a corrected case number using the SEALED MOTION event. (Text entry; no document attached.)

Proposed Order Summons

(Schedule A)

SEALED DOCUMENT by TOKA, LLC. This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal.

(Schedule A) (kss)

SEALED MOTION This document Sealed pursuant to 9 Order on Motion for Leave to File Documents Under Seal, by TOKA, LLC.

(Proposed Order Exceed Page Limit)

MOTION for Status Conference by TOKA, LLC.

CLERK'S REQUEST FOR CORRECTIVE ACTION re 17 MOTION for Status Conference. ERROR: Filer did not attach a Proposed Order as required by LCvR 7. CORRECTION: Filer to submit a proposed order using the Proposed Order event. Filer is to link the Proposed Order to the relevant motion in the event. (Text entry; no document attached.)

Proposed Order re 17 Motion for Status Conference by TOKA, LLC.

ORDER GRANTING Plaintiff's 17 MOTION for Status Conference. It is hereby ORDERED that a Telephonic Status Conference is set for 5/27/2026 at 1:30 PM before Chief Judge Cathy Bissoon. Signed by Chief Judge Cathy Bissoon on 5/26/2026. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Order (Text entry; no document attached.)

ORDER. On or before 6/3/2026, Plaintiff's counsel shall file with the Court an affidavit indicating whether Plaintiff has brought any suit in this or any other court against any Defendant in this case based on one or more of the patents at issue, regardless of whether said Defendant was dismissed. If so, Plaintiff's counsel shall provide the name of the case, the court in which the case was filed, the docket number of the case and the procedural history of the case. Signed by Chief Judge Cathy Bissoon on 5/27/2026. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

SEALED ORDER granting Plaintiff's 16 MOTION to Exceed Page Limit. Signed by Chief Judge Cathy Bissoon on 5/27/2026.

SEALED ORDER re: 1) TEMPORARY RESTRAINING ORDER; 2) ORDER RESTRAINING ASSETS AND MERCHANT STOREFRONTS; 3) ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; and 4) ORDER AUTHORIZING EXPEDITED DISCOVERY: A Show Cause Hearing on Preliminary Injunction is set for 6/9/2026 at 10:00 AM (Eastern Daylight Time), in Courtroom 3A, United States Courthouse, 700 Grant Street, Pittsburgh, PA 15219. Counsel entering an appearance on behalf of any party must appear in person at the Hearing, and Defendants are on notice that failure to appear at the Hearing may result in the imposition of a preliminary injunction against them. Opposing papers, if any, shall be filed electronically with the Court and served on Plaintiff's counsel by delivering copies thereof to the office of Ference & Associates LLC at 409 Broad Street, Pittsburgh, Pennsylvania 15143, on or before 6/3/2026. Plaintiff shall file any reply papers on or before 6/5/2026. See contents of this filing for detailed instructions and deadlines. Plaintiff should note the additional provisions entered after paragraph I.D and the elimination of Section VI. Finally, Plaintiff shall take notice that in addition to the traditional preliminary injunction factors, the Court views the criteria set forth in the SAFE Best Practices for Schedule A Litigation, https://safeip.org/best-practices/, to be those that would minimally justify injunctive relief in Schedule A cases, to the extent those criteria are consistent with Third Circuit practice and precedent. Plaintiff shall be prepared to address how Plaintiff meets the SAFE criteria, as well as the traditional preliminary injunction factors, at the show cause hearing. Signed by Chief Judge Cathy Bissoon on 5/27/2026. (jrr)Signed by Chief Judge Cathy Bissoon on 5/27/2026.

SEALED ORDER granting 13 MOTION for Alternative Service. Signed by Chief Judge Cathy Bissoon on 5/28/2026.

Set/Reset Hearings. (Text entry; no document attached.)

Surety BOND in the amount of $5,000.00 Receipt Number S-422136, posted by TOKA, LLC NGM Insurance Company as Surety.

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on May 27, 2026 before Judge Cathy Bissoon. Court Reporter Amanda M. Williamson, E-mail: awilliamson2232@gmail.com. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely, electronically available to the public without redaction after 90 calendar days. For redaction purposes, or otherwise, during this 90 day period a copy of the transcript may be purchased from the court reporter or viewed at the clerk's office public terminal. Any Notice of Intent to Request Redaction and Redaction Request must be separately mailed to the court reporter of said proceedings. Notice of Intent for Redaction of Personal Data Identifiers due by 6/9/2026. Redaction Request due 6/23/2026. Redacted Transcript Deadline set for 7/6/2026. Release of Transcript Restriction set for 8/31/2026.

NOTICE of Appearance by Ruoting Men on behalf of Shenzhen Andalian Tech Co., Ltd (d/b/a Beeyoung)).

CLERK'S REQUEST FOR CORRECTIVE ACTION re [27] Notice of Appearance. ERROR: Party did not file disclosure statement as required by LR 7.1.A. CORRECTION: Filer advised to docket statement within 7 days by using the Disclosure Statement event. This event is located by going to Civil > Other Filings > Other Documents > Disclosure Statement. (Text entry; no document attached.)

NOTICE of Appearance by Ruoting Men on behalf of Shenzhen Shengxin Technology Co., Ltd., Bengbu YueShao E-Commerce Co., Ltd., Guangzhou Kaizichen Technology Co., Ltd. /d/b/a Haodsso Direct.

CLERK'S REQUEST FOR CORRECTIVE ACTION re [28] Notice of Appearance. ERROR: Party did not file disclosure statement as required by LR 7.1.A. CORRECTION: Filer advised to docket statement within 7 days by using the Disclosure Statement event. This event is located by going to Civil > Other Filings > Other Documents > Disclosure Statement. (Text entry; no document attached.)

SEALED MOTION This document Sealed pursuant to [9] Order on Motion for Leave to File Documents Under Seal, by TOKA, LLC.

RESPONSE to [21] Order, filed by TOKA, LLC.

Declaration of Stanley D. Ference III

Disclosure Statement identifying None as corporate parent or other affiliate, declaring citizenship by Bengbu YueShao E-Commerce Co., Ltd., Guangzhou Kaizichen Technology Co., Ltd., Shenzhen Andalian Tech Co., Ltd, Shenzhen Shengxin Technology Co., Ltd.

NOTICE by Bengbu YueShao E-Commerce Co., Ltd., Guangzhou Kaizichen Technology Co., Ltd., Shenzhen Andalian Tech Co., Ltd, Shenzhen Shengxin Technology Co., Ltd. re [21] Order

Exhibit Re_ Inquiry Regarding Defendant List

Exhibit Re_ communication with Amazon

Exhibit Re_communication with Plaitniff's counsel

Exhibit Re_communication with Plaitniff's counsel 593

Declaration Decl. of Men