Lulu to Pro LLC v. The Partnerships and Unincorporated Associations Identified On Schedule A

COMPLAINT against The Partnerships and Unincorporated Associations Identified On Schedule A (Filing fee, including Administrative fee, $405, receipt number BPAWDC-9819148), filed by LULU TO PRO LLC.

Civil Cover Sheet

Exhibit Redacted Exhibit 1

Exhibit Redacted Schedule A

Summons

MOTION for attorney Zejian Zhou to Appear Pro Hac Vice, (Filing fee $70, Receipt # APAWDC-9819154) by LULU TO PRO LLC.

Affidavit Pro Hac Vice

Proposed Order Pro Hac Vice

MOTION for Leave to File Documents Under Seal by LULU TO PRO LLC.

Proposed Order

MOTION to Expedite Discovery by LULU TO PRO LLC.

Proposed Order

MOTION for Alternative Service by LULU TO PRO LLC.

Proposed Order

Declaration Attorney Declaration

Exhibit Exhibit 2

ORDER GRANTING [3] MOTION for Leave to File Documents Under Seal filed by LULU TO PRO LLC. Signed by Judge Christy Criswell Wiegand on 8/24/2026.

ORDER DENYING WITHOUT PREJUDICE [10] Motion for Alternative Service. In the [17] Motion, Plaintiff LULU TO PRO LLC. requests leave to serve Defendants via email and website publication pursuant to Rule 4(f)(3) of the Federal Rules of Civil Procedure. The Court declines to authorize service by such alternative means at this time. First, where it applies, the Hague Service Convention "is exclusive, and provides the relevant catalogue of possible means of transmission for service abroad." SEC v. Lahr, No. 22-2497, 2024 WL 3518309, at *34 (3d Cir. July 24, 2024). Here, the [1] Complaint alleges that the Defendants reside in China or other foreign jurisdictions. Thus, the Hague Convention presumptively governs service. See Vanderhoef v. China Auto Logistics Inc., No. 218CV10174CCCSCM, 2019 WL 6337908, at *3 (D.N.J. Nov. 26, 2019) (explaining that the United States and China are both signatories to the Hague Convention). China has objected to Article 10 of the Hague Convention, so service by email on Chinese defendants is not authorized under the Convention. See D Squared Plant Traps LLC v. Guangdong Bixing Trading Co., LTD., 716 F. Supp. 3d 352, 356 n.2 (W.D. Pa. 2024) (Conti, J.) ("[C]ourts have refused to authorize service via email when the receiving country has objected to [Article 10 of the Hague Convention]."). And the Court cannot authorize service under Rule 4(f)(3) by means that would violate the Hague Convention. See id. at 357 (quoting Rio Properties, Inc. v. Rio Int'l Interlink, 284 F.3d 1007, 1015 n.4 (9th Cir. 2002)) ("A federal court [is] prohibited from issuing a Rule 4(f)(3) order in contravention of an international agreement, including the Hague Convention."). Finally, Plaintiff has not established that an exception applies such that the Hague Convention is not applicable in this case. See, e.g., Lahr, 2024 WL 3518309, at *34 (explaining that the Convention does not apply where the address of the party to be served is unknown, and that courts employ a reasonable diligence test that examines whether a plaintiff engaged in reasonably diligent efforts to discover a defendant's address). Accordingly, IT IS HEREBY ORDERED that the [10] Motion is DENIED WITHOUT PREJUDICE to Plaintiff's ability to file a renewed motion for alternative service as appropriate. Signed by Judge Christy Criswell Wiegand on 8/24/2026. 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 [9] MOTION for Expedited Discovery filed by LULU TO PRO LLC. Signed by Judge Christy Criswell Wiegand on 8/24/2026.