2025-cv-21899

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto. Filing fees $ 405.00 receipt number AFLSDC-18399920, filed by Hong Kong Leyuzhen Technology Co. Limited.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Civil Cover Sheet

(Summon(s))

Clerks Notice of Judge Assignment to Judge Darrin P. Gayles. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman 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 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE

(Complaint) (ksr)

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

NOTICE OF COURT PRACTICE. Unless otherwise specified by the Court, every motion shall be double-spaced in Times New Roman 12-point typeface. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Failure to comply with ANY of these procedures may result in the imposition of appropriate sanctions, including but not limited to, the striking of the motion or dismissal of this action. Signed by Judge Darrin P. Gayles on 4/25/2025.

MOTION to Seal per Local Rule 5.4 by Hong Kong Leyuzhen Technology Co. Limited.

(Text of Proposed Order)

ORDER granting 6 Motion to Seal. Signed by Judge Darrin P. Gayles on 4/29/2025. See attached document for full details.

Corporate Disclosure Statement by Hong Kong Leyuzhen Technology Co. Limited identifying Corporate Parent Yu Zhen E-Commerce Co. Limited for Hong Kong Leyuzhen Technology Co. Limited

SYSTEM ENTRY - Docket Entry 9 [misc] restricted/sealed until further notice. (1735549)

MOTION to Seal per Local Rule 5.4 by Hong Kong Leyuzhen Technology Co. Limited.

Affidavit of W. Brees in Support of Motion to Seal

Exhibit 1 to the Declaration of W. Brees

Exhibit 1 to the Declaration of W. Brees

(Text of Proposed Order)

SYSTEM ENTRY - Docket Entry 11 [motion] restricted/sealed until further notice. (1735549)

SYSTEM ENTRY - Docket Entry 12 [motion] restricted/sealed until further notice. (1735549)

ORDER granting 10 Motion to Seal. Signed by Judge Darrin P. Gayles on 6/10/2025. See attached document for full details.

SYSTEM ENTRY - Docket Entry 14 [misc] restricted/sealed until further notice. (1735549)

SYSTEM ENTRY - Docket Entry 15 [misc] restricted/sealed until further notice. (1735549)

SYSTEM ENTRY - Docket Entry 16 [order] restricted/sealed until further notice.

SYSTEM ENTRY - Docket Entry 17 [order] restricted/sealed until further notice.

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

MOTION to Deposit Funds into Court Registry Pursuant to the Temporary Restraining Order (Dkt. No. 16)) by Hong Kong Leyuzhen Technology Co. Limited.

Exhibit Registry Deposit Information

(Text of Proposed Order)

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Hong Kong Leyuzhen Technology Co. Limited. The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto served on 6/18/2025, response/answer due 7/9/2025.

NOTICE of Change of Address/Contact Information; by Emily Marie Heim

CLERK'S NOTICE - Attorney Admissions has updated the address information as submitted through attorneys PACER account for attorney Emily Marie Heim

Order

ORDER granting [19] Motion for Leave to Deposit Funds into Court Registry. Signed by Judge Darrin P. Gayles on 6/25/2025. See attached document for full details.

MOTION for Preliminary Injunction by Hong Kong Leyuzhen Technology Co. Limited.

Affidavit of E. Heim in Support of Motion

Text of Proposed Order

ORDER granting [25] Motion for Preliminary Injunction. Signed by Judge Darrin P. Gayles on 7/7/2025. See attached document for full details.

CLERK'S NOTICE of Compliance (All Previously Sealed Pleading and Documents in this Case have Been Unsealed) re 26 Order on Motion for Preliminary Injunction

MOTION for Clerk's Entry of Default AGAINST CERTAIN DEFENDANTS IDENTIFIED IN SCHEDULE "A" as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto by Hong Kong Leyuzhen Technology Co. Limited.

Affidavit of W. Brees in Support of Motion for Entry of Clerk's Default

Exhibit 1 to the Affidavit of of W. Brees

Text of Proposed Order

Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto. Granting DE 28 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 7/14/2025.

CERTIFICATE OF SERVICE by Hong Kong Leyuzhen Technology Co. Limited re 29 Clerk's Entry/Non-Entry of Default

NOTICE of Attorney Appearance by Ziqi Yu on behalf of LaiyiVic, ZonJie, PaladMom. Attorney Ziqi Yu added to party LaiyiVic(pty:dft), Attorney Ziqi Yu added to party ZonJie(pty:dft), Attorney Ziqi Yu added to party PaladMom(pty:dft).

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Benjamin Solter. Filing Fee $ 250.00 Receipt # AFLSDC-18660278 by LaiyiVic, PaladMom, ZonJie. Responses due by 8/13/2025.

Certification of Benjamin Solter

Text of Proposed Order

PAPERLESS ORDER granting 32 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. Attorney Benjamin Solter is permitted to appear before this Court on behalf of Defendants LaiyiVic, ZonJie, PaladMom for all purposes relating to this action. The clerk is directed to provide Notice of Electronic Filings to Attorney Benjamin Solter at bsolter@cbcounselor.com. Signed by Judge Darrin P. Gayles on 7/31/2025.

MOTION for Default Judgment AGAINST THE IDENTIFIED SCHEDULE "A" DEFENDANTS by Hong Kong Leyuzhen Technology Co. Limited.

Affidavit of W. Brees in Support of Motion for Default Judgment

Text of Proposed Order Granting Motion for Default Judgment

Text of Proposed Order Final Default Judgment and Permanent injunction

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [1] Complaint, by LaiyiVic, PaladMom, ZonJie.

Text of Proposed Order

PAPERLESS ORDER granting 35 Unopposed Motion for Extension of Time. On or before August 18, 2025, Defendants LaiyiVic, ZonJie, and PaladMom shall file a response to the Complaint. Signed by Judge Darrin P. Gayles on 8/8/2025.

ANSWER and Affirmative Defenses to Complaint with Jury Demand by LaiyiVic, PaladMom, ZonJie.

Corporate Disclosure Statement by LaiyiVic, PaladMom, ZonJie

ORDER granting [34] Motion for Default Judgment. Signed by Judge Darrin P. Gayles on 8/19/2025. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Hong Kong Leyuzhen Technology Co. Limited against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto Signed by Judge Darrin P. Gayles on 8/19/2025. See attached document for full details.

Corrected Corporate Disclosure Statement by ZonJie identifying Other Affiliate Qinglai Wang, Other Affiliate Yishun Wang for ZonJie

PAPERLESS ORDER REQUIRING JOINT SCHEDULING REPORT AND PROPOSED SCHEDULING ORDER. Pursuant to S.D. Fla. Local Rule 16.1, on or before September 30, 2025, the parties shall prepare and file a Joint Scheduling Report, as well as Certificates of Interested Parties and Corporate Disclosure Statements. The parties shall also file a Proposed Scheduling Order, adhering to the format and guidance of the attached form. If the parties deviate in any way from that format and guidance, they shall contemporaneously submit a written explanation, which provides their purported justification for each and every deviation. If the parties fail to submit such written explanation, the Court may enter a Scheduling Order that does not take into account the parties' proposed dates. Failure to comply with this Order shall be grounds for dismissal without prejudice and without further notice. Signed by Judge Darrin P. Gayles on 9/16/2025.

Joint MOTION to Amend/Correct [26] Order on Motion for Preliminary Injunction TO MODIFY PRELIMINARY INJUNCTION ORDER by LaiyiVic, PaladMom, ZonJie. Responses due by 10/8/2025.

Text of Proposed Order

ORDER granting [43] Motion to Modify Preliminary Injunction Order. Signed by Judge Darrin P. Gayles on 9/26/2025. See attached document for full details.

Joint SCHEDULING REPORT - Rule 26(f) by Hong Kong Leyuzhen Technology Co. Limited

SCHEDULING ORDER SETTING CIVIL TRIAL DATE AND PRETRIAL SCHEDULE, REQUIRING MEDIATION, AND REFERRING CERTAIN MOTIONS TO MAGISTRATE JUDGE: (Jury Trial set for 8/10/2026 in Miami Division before Judge Darrin P. Gayles., Calendar Call set for 8/5/2026 09:30 AM before Judge Darrin P. Gayles., Status Conference set for 5/27/2026 10:00 AM before Judge Darrin P. Gayles.), ORDER REFERRING CASE to Mediation. (Mediation Deadline 5/8/2026.), ORDER REFERRING CASE to Magistrate Judge Detra Shaw-Wilder for Discovery Matters. Signed by Judge Darrin P. Gayles on 10/1/2025. See attached document for full details. (ksr) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here.