2025-cv-60094

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18124353, filed by Believe Pursue LLC.

Exhibit 1

Exhibit 2

(Civil Cover Sheet)

Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt 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 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

(Complaint and Exhibits) (jas)

Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by Believe Pursue LLC

Plaintiff's MOTION to Seal Schedule A to Complaint per Local Rule 5.4 by Believe Pursue LLC.

(Text of Proposed Order)

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT. Signed by Judge William P. Dimitrouleas on 1/21/2025. See attached document for full details.

ORDER granting 5 Motion to Seal. Signed by Judge William P. Dimitrouleas on 1/21/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 8 [misc] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

Plaintiff's MOTION for Leave to File Excess Pages re Ex Parte Motion for TRO by Believe Pursue LLC.

SYSTEM ENTRY - Docket Entry 10 [motion] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

(Text of Proposed Order)

ORDER GRANTING 9 MOTION for Leave to File Excess Pages. Signed by Judge William P. Dimitrouleas on 1/31/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 12 [order] restricted/sealed until further notice. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 13 [motion] restricted/sealed until further notice. (1857863) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 14 [order] restricted/sealed until further notice. (Text entry; no document attached.)

NOTICE of Filing Proposed Summons(es) in Compliance with the Court's Sealed Order Granting Ex Parte Application for Entry of Temporary Restraining Order [DE 14] by Believe Pursue LLC

Summon(s)

Summons Issued as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A.

NOTICE of Attorney Appearance by Leigh Benjamin Salomon on behalf of Believe Pursue LLC. Attorney Leigh Benjamin Salomon added to party Believe Pursue LLC(pty:pla).

NOTICE OF POSTING BOND in the amount of $50,000.00 receipt # 298429 posted by Believe Pursue LLC. Approved by Judge William P. Dimitrouleas from DE# 14.

(Receipt for Bond) (scn)

Plaintiff's MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines (Responses due by 2/25/2025.), MOTION to Reschedule PI Hearing by Believe Pursue LLC.

Affidavit Declaration of Nicole Fundora ISO Motion to Extend TRO and Reschedule PI Hearing

(Text of Proposed Order)

ORDER: GRANTING 19 MOTION to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on Its Motion for Preliminary Injunction, and Extend the Briefing Deadlines. The TRO shall remain in effect until after the conclusion of the rescheduled hearing. Responses due by 2/28/2025. PRELIMINARY INJUNCTION HEARING set for 3/7/2025 at 10:00 AM before Judge William P. Dimitrouleas. Signed by Judge William P. Dimitrouleas on 2/12/2025. See attached document for full details.

Deadline(s)/Hearing(s) terminated. per DE[20] (Text entry; no document attached.)

Deadline(s)/Hearing(s) terminated. per DE 20 (Text entry; no document attached.)

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Believe Pursue LLC. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 2/26/2025, response/answer due 3/19/2025.

(Exhibit Schedule A to Complaint - list of defendants served)

Plaintiff's MOTION to Unseal Case by Believe Pursue LLC. Responses due by 3/12/2025.

(Text of Proposed Order)

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Anhui Craftsmanship E-Commerce Co., Ltd., Dingzhou Feisheng Sporting Goods Co., Ltd., Hebei Shuaicool International Trade Co., Ltd., Hefei Strong Sports Co., Ltd., Hengshui Jiankang Trading Co., Ltd., Hengshui Tuobang Medical Equipment Co., Ltd., Meng Rui (Shanghai) Industrial Development Co., Ltd., Ningbo Trendfrom Imp And Exp Co., Ltd., Shandong Paramount Import&Export Co., Ltd., Shenzhen Shenzhouxing Outdoor Products Company Limited, Suzhou One Two Three Sports Goods Co., Ltd., zerxify, Suzhou Rola Fitness Co., Ltd., Yangzhou Hualong Body Protection Supplies Factory, Yiwu Greefun Import & Export Co., Ltd., Yiwu Kuer Sporting Goods Co., Ltd., Yiwu Zhanji Import And Export Co., Ltd., Yiwu Zhouyou Trade Co., Ltd., Aerobicsports Store, BUDDING LAND OUTDOOR, Fatburnsports Store, MaTraveler Store, RainSport Store, Shop1102800360 Store, UNIX-SPORT Store, WIN-TOP Store, FAQIUQI, zhangjiee, litao-xiaodi, nexify.sale, BENHONG, Dezvous, intothesecret, LanJing Sports, Must-have In The Wild Store, Benhongs, BINGYIKKK, ChicPants Couture, Donop local, DONT GO DOWN, Duan yu, Duoduo Ri Zai, feifanhaowuguan, Fitup, FIVE BILLION FITNESS, Green gymnasium, GYM WORK, Halo Out Sports, LDSIN, leIPO, LI GAO kai, Long Way outdoor, Mi la mi ka commodities, PILANPO, Playery, QY SPORT, RAIN SHOP HOME, Runningyouyou, The Mamba Sports Stadium, yeah mall, youMK, Yuanlingdianzi, YYYYYOOOO, YYYYYTT, ADHYRO, DONGRUO Co.Ltd, DONGXUAN Co.Ltd, Dutchman, ELXM, ENYAO Co.Ltd, Fufenkejiltd, gaoshengchanglvcai, guangzhouliangyuefushi, HAONAI Co.Ltd, HAOWEN Co.Ltd, hongshengdazhinengkeji, HUYUCo.Ltd, JIAYANG Co.Ltd, KEWITY, Langzhongshangmaoltd, liboshangmaa, LINGNA Co.Ltd, RobinaLavern, SHUJIN Co.Ltd, weilejianzhugongcheng, WEIRUN Co.Ltd, Xiao jie market, YANFENG Co.Ltd, yuanchijiaju, YUNJIN Co.Ltd, YUTI Co.Ltd, ZHANGYAO Co.Ltd, ZHONGMEI Co.Ltd, alphafitshop, garmade, kensuifitness, sunsky-online and swiftsupplyshop.

ORDER Granting 22 Motion to Unseal Case. The Clerk is directed to unseal all docket entries in this case and return those portions of the file to the public records. Signed by Judge William P. Dimitrouleas on 2/27/2025. See attached document for full details.

NOTICE of Attorney Appearance by Jared Jules Schifman on behalf of Believe Pursue LLC. Attorney Jared Jules Schifman added to party Believe Pursue LLC(pty:pla).

Plaintiff's NOTICE of Filing Proposed Order on Plaintiff's Motion for Preliminary Injunction by Believe Pursue LLC

(Text of Proposed Order)

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Believe Pursue LLC

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 3/7/2025 re 13 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Internet Stores, a Temporary Asset Restraint, and Expedited Discovery MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by Believe Pursue LLC. No Defendants appeared. Court will enter an Order granting Plaintiff's motion for a preliminary injunction. Total time in court: 5 minutes. Attorney Appearance(s): Jared Jules Schifman, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov.

ORDER GRANTING 13 PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION. Signed by Judge William P. Dimitrouleas on 3/7/2025. See attached document for full details.

Order Dismissing Party JIAYANG Co. Ltd, Defendant 77 re 27 Notice of Voluntary Dismissal. This case is Dismissed without Prejudice. Signed by Judge William P. Dimitrouleas on 3/7/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Believe Pursue LLC

ORDER: DISMISSING WITHOUT PREJUDICE as to the following Defendants ONLY: Dutchman, FIVE BILLION FITNESS, yeah mall, BENHONG and Dezvous. Signed by Judge William P. Dimitrouleas on 3/17/2025. See attached document for full details.

NOTICE of Attorney Appearance by Andrew Jonathan Palmer on behalf of DONGRUO Co.Ltd, DONGXUAN Co.Ltd, ENYAO Co.Ltd, HAONAI Co.Ltd, HAOWEN Co.Ltd, LINGNA Co.Ltd, SHUJIN Co.Ltd, WEIRUN Co.Ltd, YANFENG Co.Ltd, YUNJIN Co.Ltd, YUTI Co.Ltd, ZHANGYAO Co.Ltd, ZHONGMEI Co.Ltd. Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party, Attorney Andrew Jonathan Palmer added to party.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by DONGRUO Co.Ltd, DONGXUAN Co.Ltd, ENYAO Co.Ltd, HAONAI Co.Ltd, HAOWEN Co.Ltd, LINGNA Co.Ltd, SHUJIN Co.Ltd, WEIRUN Co.Ltd, YANFENG Co.Ltd, YUNJIN Co.Ltd, YUTI Co.Ltd, ZHANGYAO Co.Ltd, ZHONGMEI Co.Ltd.

MOTION for Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A by Believe Pursue LLC.

(Affidavit Declaration of Nicole Fundora ISO Request for Entry of Clerk's Default)

ORDER granting 34 Motion for Extension of Time to File Answer to Complaint or Other Case Initiating Document DONGRUO Co.Ltd. Response/Answer due 4/18/2025; DONGXUAN Co.Ltd. Response/Answer due 4/18/2025; ENYAO Co.Ltd. Response/Answer due 4/18/2025; HAONAI Co.Ltd. Response/Answer due 4/18/2025; HAOWEN Co.Ltd. Response/Answer due 4/18/2025; LINGNA Co.Ltd. Response/Answer due 4/18/2025; SHUJIN Co.Ltd. Response/Answer due 4/18/2025; WEIRUN Co.Ltd. Response/Answer due 4/18/2025; YANFENG Co.Ltd. Response/Answer due 4/18/2025; YUNJIN Co.Ltd. Response/Answer due 4/18/2025; YUTI Co.Ltd. Response/Answer due 4/18/2025; ZHANGYAO Co.Ltd. Response/Answer due 4/18/2025; ZHONGMEI Co.Ltd. Response/Answer due 4/18/2025. Signed by Judge William P. Dimitrouleas on 3/20/2025. See attached document for full details.

Clerk's Entry of Default as to RainSport Store, Shop1102800360 Store, UNIX-SPORT Store, WIN-TOP Store, FAQIUQI, zhangjiee, litao-xiaodi, nexify.sale, intothesecret, LanJing Sports, Must-have In The Wild Store, Benhongs, BINGYIKKK, ChicPants Couture, Donop local, DONT GO DOWN, Duan yu, Duoduo Ri Zai, feifanhaowuguan, Fitup, Green gymnasium, GYM WORK, Halo Out Sports, LDSIN, leIPO, LI GAO kai, Long Way outdoor, Mi la mi ka commodities, PILANPO, Playery, QY SPORT, RAIN SHOP HOME, Runningyouyou, The Mamba Sports Stadium, yeah mall, youMK, Yuanlingdianzi, YYYYYOOOO, YYYYYTT, ADHYRO, ELXM, Fufenkejiltd, gaoshengchanglvcai, guangzhouliangyuefushi, hongshengdazhinengkeji, HUYUCo.Ltd, KEWITY, Langzhongshangmaoltd, liboshangmaa, RobinaLavern, weilejianzhugongcheng, Xiao jie market, yuanchijiaju, alphafitshop, garmade, kensuifitness, sunsky-online, swiftsupplyshop, The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A, Anhui Craftsmanship E-Commerce Co., Ltd., Dingzhou Feisheng Sporting Goods Co., Ltd., Hebei Shuaicool International Trade Co., Ltd., Hefei Strong Sports Co., Ltd., Hengshui Jiankang Trading Co., Ltd., Hengshui Tuobang Medical Equipment Co., Ltd., Meng Rui (Shanghai) Industrial Development Co., Ltd., Ningbo Trendfrom Imp And Exp Co., Ltd., Shandong Paramount Import&Export Co., Ltd., Shenzhen Shenzhouxing Outdoor Products Company Limited, Suzhou One Two Three Sports Goods Co., Ltd., zerxify, Suzhou Rola Fitness Co., Ltd., Yangzhou Hualong Body Protection Supplies Factory, Yiwu Greefun Import & Export Co., Ltd., Yiwu Kuer Sporting Goods Co., Ltd., Yiwu Zhanji Import And Export Co., Ltd., Yiwu Zhouyou Trade Co., Ltd., Aerobicsports Store, BUDDING LAND OUTDOOR, Fatburnsports Store, MaTraveler Store - Motions Terminated: 35 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 3/21/2025.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Believe Pursue LLC

ORDER. The Motion [DE 38] is GRANTED. This case is DISMISSED WITHOUT PREJUDICE as to the following Defendants ONLY: Party(ies) kensuifitness, Shenzhen Shenzhouxing Outdoor Products Company Limited and garmade. (Without Prejudice) Signed by Judge William P. Dimitrouleas on 4/1/2025. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Believe Pursue LLC.

Exhibit Schedule A - list of Defaulting Defendants

Exhibit Exhibit 1 to Motion for Default

Affidavit Declaration of Nicole Fundora ISO Motion for Default

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 1 of 2)

Exhibit Exhibit 1 to Declaration of Nicole Fundora (part 2 of 2)

Exhibit Exhibit 2 to Declaration of Nicole Fundora

Text of Proposed Order

Text of Proposed Order

ORDER TO SHOW CAUSE WHY COURT SHOULD NOT GRANT MOTION FOR DEFAULT FINAL JUDGMENT. Show Cause Response due by 4/16/2025. Signed by Judge William P. Dimitrouleas on 4/3/2025. See attached document for full details.

CERTIFICATE OF SERVICE by Believe Pursue LLC re 41 Order to Show Cause

(Exhibit Schedule A to Complaint - list of defendants served)

MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by kensuifitness.

ORDER GRANTING 43 MOTION for Extension of Time to File Response/Answer to a Complaint by kensuifitness. Response/Answer due 4/18/2025. Signed by Judge William P. Dimitrouleas on 4/7/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Believe Pursue LLC

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Believe Pursue LLC

Order, Dismissing Party The Mamba Sports Stadium, Halo Out Sports and Playery. Signed by Judge William P. Dimitrouleas on 4/10/2025. See attached document for full details.

Order Dismissing Party FAQIUQI and PILANPO, Per DE 46. Signed by Judge William P. Dimitrouleas on 4/10/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Believe Pursue LLC

ANSWER and Affirmative Defenses to Complaint by DONGRUO Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by DONGXUAN Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by HAONAI Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by HAOWEN Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by ENYAO Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by LINGNA Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by SHUJIN Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by WEIRUN Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by YANFENG Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by YUNJIN Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by YUTI Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by ZHANGYAO Co.Ltd.

ANSWER and Affirmative Defenses to Complaint by ZHONGMEI Co.Ltd.

ORDER REQUIRING PLAINTIFF TO FILE AN UPDATED LIST OF DEFAULTING DEFENDANTS FOR PURPOSES OF ITS PENDING MOTION FOR DEFAULT JUDGMENT. Signed by Judge William P. Dimitrouleas on 4/21/2025. See attached document for full details.

ORDER DISMISSING DEFENDANT Donop local. Signed by Judge William P. Dimitrouleas on 4/21/2025. See attached document for full details.

Plaintiff's NOTICE of Filing Updated Schedule A by Believe Pursue LLC re 63 Order, 40 Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof

(Exhibit Updated Schedule A - list of Defaulting Defendants)

ORDER GRANTING 40 MOTION FOR DEFAULT FINAL JUDGMENT AS TO CERTAIN DEFENDANTS. Signed by Judge William P. Dimitrouleas on 4/25/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of PLAINTIFF, Believe Pursue LLC, and against DEFENDANTS, Individuals, Partnerships, or Unincorporated Associations identified in the list of Defaulting Defendants attached at the end of this Order. Signed by Judge William P. Dimitrouleas on 4/25/2025. See attached document for full details.

Plaintiff's MOTION for clarification 67 Default Judgment, as to Damages Awarded by Believe Pursue LLC. Responses due by 5/13/2025.

(Text of Proposed Order)

ORDER GRANTING 68 PLAINTIFF'S MOTION FOR CLARIFICATION OF DAMAGES AWARDED IN FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION. Signed by Judge William P. Dimitrouleas on 4/30/2025. See attached document for full details.

CERTIFICATE OF SERVICE by Believe Pursue LLC re 67 Default Judgment, 69 Order on Motion for Clarification

(Exhibit Schedule A- list of defendants served)

STIPULATION of Dismissal of Certain Claims with Respect to Certain Defendants (Joint) by Believe Pursue LLC

ORDER Approving Stipulation of Dismissal of Certain Claims With Respect to Certain Defendants. Signed by Judge William P. Dimitrouleas on 5/7/2025. See attached document for full details.

Agreed MOTION for Entry of Consent Judgment as to Defendant No. 69 by Believe Pursue LLC.

Text of Proposed Order

Agreed MOTION for Entry of Consent Judgment as to Defendant No. 81 by Believe Pursue LLC.

Text of Proposed Order

Agreed MOTION for Entry of Consent Judgment as to Defendant No. 83 by Believe Pursue LLC.

Text of Proposed Order

Agreed MOTION for Entry of Consent Judgment as to Defendant No. 85 by Believe Pursue LLC.

Text of Proposed Order

Agreed MOTION for Entry of Consent Judgment as to Defendant No. 89 by Believe Pursue LLC.

Text of Proposed Order

Joint MOTION for Extension of Time to File Joint Scheduling Report re [6] Order Requiring Joint Scheduling Report by Believe Pursue LLC. Responses due by 6/5/2025.

Text of Proposed Order

CONSENT JUDGMENT AS TO DEFENDANT ENYAO CO.LTD. The Motion [DE 73 ] is hereby GRANTED. Signed by Judge William P. Dimitrouleas on 5/23/2025. See attached document for full details.

CONSENT JUDGMENT AS TO DEFENDANT LINGNA CO.LTD. The Motion [DE 74 ] is hereby GRANTED. Signed by Judge William P. Dimitrouleas on 5/23/2025. See attached document for full details.

CONSENT JUDGMENT AS TO DEFENDANT SHUJIN CO.LTD. The Motion [DE 75 ] is hereby GRANTED. Signed by Judge William P. Dimitrouleas on 5/23/2025. See attached document for full details.

CONSENT JUDGMENT AS TO DEFENDANT WEIRUN CO.LTD. The Motion [DE 76 ] is hereby GRANTED. Signed by Judge William P. Dimitrouleas on 5/23/2025. See attached document for full details.

CONSENT JUDGMENT AS TO DEFENDANT YUNJIN CO.LTD. The Motion [DE 77 ] is hereby GRANTED. Signed by Judge William P. Dimitrouleas on 5/23/2025. See attached document for full details.

ORDER ON JOINT MOTION FOR EXTENSION OF TIME. The Motion [DE 78 ] is GRANTED. Joint Scheduling Report due by 6/23/2025. Signed by Judge William P. Dimitrouleas on 5/23/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by Believe Pursue LLC

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Believe Pursue LLC

Order Dismissing Party HAOWEN Co.Ltd, YANFENG Co.Ltd, YUTI Co.Ltd, ZHANGYAO Co.Ltd, ZHONGMEI Co.Ltd, sunsky-online, DONGRUO Co.Ltd and HAONAI Co.Ltd re 86 Notice of Voluntary Dismissal, 85 Notice of Voluntary Dismissal Signed by Judge William P. Dimitrouleas on 5/28/2025. See attached document for full details.

Unopposed MOTION to Withdraw as Attorney by Andrew Palmer for / by DONGXUAN Co.Ltd. Responses due by 7/2/2025.

ORDER deferring ruling on [88] Motion to Withdraw as Counsel. Signed by Judge William P. Dimitrouleas on 6/23/2025. See attached document for full details.

Second MOTION for Extension of Time to File Joint Scheduling Report (Joint) re 6 Order Requiring Joint Scheduling Report by Believe Pursue LLC. Responses due by 7/7/2025.

(Text of Proposed Order)

ORDER granting 90 Second Joint Motion for Extension of Time. Joint Scheduling Report due by 7/22/2025 Signed by Judge William P. Dimitrouleas on 6/23/2025. See attached document for full details.

ORDER REQUIRING ANDREW J. PALMER TO COMPLY WITH COURT'S ORDER DEFERRING RULING ON MOTION TO WITHDRAW AS COUNSEL re 89 Order on Motion to Withdraw as Attorney, as to 89 Order on Motion to Withdraw as Attorney. (Responses due by 7/9/2025.) Signed by Judge William P. Dimitrouleas on 7/3/2025. See attached document for full details.

NOTICE of Compliance by DONGXUAN Co.Ltd re 89 Order on Motion to Withdraw as Attorney

(Exhibit Ex. 1 - Email notice to Defendant DONGXUAN Co.Ltd)

ORDER granting 88 Unopposed Motion to Withdraw as Attorney. Andrew Jonathan Palmer representing DONGXUAN Co.Ltd (Defendant) withdrawn from case. Deadline to obtain new counsel 7/22/2025. Signed by Judge William P. Dimitrouleas on 7/7/2025. See attached document for full details.

Third MOTION for Extension of Time to File Joint Scheduling Report (Joint) re 6 Order Requiring Joint Scheduling Report by Believe Pursue LLC. Responses due by 8/5/2025.

(Text of Proposed Order)

SATISFACTION OF JUDGMENT re 67 Default Judgment, as to Defendant No. 49 (leIPO) by Believe Pursue LLC

ORDER granting [95] Third Joint Motion for Extension of Time. Joint Scheduling Report due by 8/22/2025 Signed by Judge William P. Dimitrouleas on 7/22/2025. See attached document for full details.

SATISFACTION OF JUDGMENT re 67 Default Judgment, as to Defendant No. 34 (Must-have In The Wild Store) by Believe Pursue LLC

Plaintiff's MOTION to Strike [51] Answer to Complaint pursuant to DE 94 by Believe Pursue LLC. Responses due by 8/6/2025.

Text of Proposed Order

ORDER granting 99 Motion to Strike 51 Answer to Complaint. Signed by Judge William P. Dimitrouleas on 7/24/2025. See attached document for full details.

SATISFACTION OF JUDGMENT re 67 Default Judgment, as to Defendant No. 43 (Fitup); Defendant No. 45 (Green gymnasium); and Defendant No. 51 (Long Way outdoor) by Believe Pursue LLC

Plaintiff's MOTION for Default Judgment Against Defendant DONGXUAN Co.Ltd and Memorandum of Law in Support Thereof by Believe Pursue LLC.

Exhibit Schedule A - list of Defaulting Defendant

Exhibit Table identifying the patent infringed and the calculated damages sought for Defaulting Defendant

Affidavit Declaration of Nicole Fundora ISO Motion for Default

Text of Proposed Order

(Text of Proposed Order)

ORDER TO SHOW CAUSE re 102 Plaintiff's MOTION for Default Judgment Against Defendant DONGXUAN Co.Ltd and Memorandum of Law in Support Thereof filed by Believe Pursue LLC. Show Cause Response due by 8/19/2025. Signed by Judge William P. Dimitrouleas on 8/8/2025. See attached document for full details.

CERTIFICATE OF SERVICE by Believe Pursue LLC re 103 Order to Show Cause

Fourth MOTION for Extension of Time to File Joint Scheduling Report and Joint Discovery Report (Joint) re 6 Order Requiring Joint Scheduling Report by Believe Pursue LLC. Responses due by 9/2/2025.

(Text of Proposed Order)

ORDER granting 105 Motion for Extension of Time to File Joint Scheduling Report and Joint Discovery Report. Joint Scheduling Report due by 9/22/2025 Signed by Judge William P. Dimitrouleas on 8/19/2025. See attached document for full details.

NOTICE of Voluntary Dismissal as to Certain Defendants Only by Believe Pursue LLC

ORDER Dismissing Certain Defendant's re 107 Notice of Voluntary Dismissal filed by Believe Pursue LLC Signed by Judge William P. Dimitrouleas on 8/22/2025. See attached document for full details.

ORDER REQUIRING PLAINTIFF TO FILE AN UPDATED LISTOF REMAINING DEFENDANTS AND THE STATUS AS TO EACH. Accordingly, it is ORDERED AND ADJUDGED that or before August 29, 2025, Plaintiff shall file an updated list of as to the remaining Defendants in this action and the status as to each. Signed by Judge William P. Dimitrouleas on 8/22/2025. See attached document for full details.

Plaintiff's NOTICE of Filing Update Schedule A of Remaining Defendants by Believe Pursue LLC re 109 Order

(Exhibit Updated Schedule A listing remaining Defendants)

ORDER granting [102] Motion for FINAL Default Judgment against Defendant Dongxuan Co. Ltd. Signed by Judge William P. Dimitrouleas on 8/26/2025. See attached document for full details.

DEFAULT JUDGMENT in favor of Believe Pursue LLC against DONGRUO Co.Ltd Closing Case. Signed by Judge William P. Dimitrouleas on 8/26/2025. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

(Final Default Judgment) (drz)

Plaintiff's MOTION for Disbursement of Funds Return of Bond by Believe Pursue LLC.

(Text of Proposed Order)

ORDER granting 114 Motion for Disbursement of Funds to Boies Schiller Flexner LLP in the amount of $50,000.00. Signed by Judge William P. Dimitrouleas on 8/27/2025. See attached document for full details.

SATISFACTION OF JUDGMENT re 67 Default Judgment, as to Defendant No. 61 (Yuanlingdianzi) by Believe Pursue LLC