2025-cv-22127

COMPLAINT against The Individuals, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18432956, filed by ZURU INC.

(Civil Cover Sheet)

Clerks Notice of Judge Assignment to Judge Jose E. Martinez. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Eduardo I. Sanchez 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) (blc)

MOTION to Seal per Local Rule 5.4 by ZURU INC.

(Text of Proposed Order)

OMNIBUS ORDER Regarding Schedule "A" Causes of Action. Signed by Judge Jose E. Martinez on 5/12/2025. See attached document for full details.

MOTION to Extend Deadlines for Response to Omnibus Order re 5 Order by ZURU INC.

(Text of Proposed Order)

PAPERLESS ORDER granting 6 Plaintiff's Motion to Extend Deadlines for Response to Omnibus Order. Plaintiff shall file its Motion for Entry of a Temporary Restraining Order, Motion for Alternate Service, Motion to Seal, and Verified Response to the Court's Omnibus Order Regarding Schedule "A" Causes of Action on or before June 2, 2025. Signed by Judge Jose E. Martinez on 5/21/2025.

"STRICKEN" Second MOTION to Extend Deadlines for Response to Omnibus Order re 7 Order on Motion for Miscellaneous Relief, 5 Order by Zuru Inc.

(Text of Proposed Order) Modified on 5/29/2025 (ls). (per DE #11)

PAPERLESS ORDER granting 8 Motion Extension of Time. Plaintiff shall file its Motion for Entry of a Temporary Restraining Order, Motion for Alternate Service, Motion to Seal, and Verified Response to the Court's Omnibus Order Regarding Schedule "A" Causes of Action on or before June 6, 2025. Signed by Judge Jose E. Martinez on 5/29/2025.

Clerk's Notice to Filer re 8 Second MOTION to Extend Deadlines for Response to Omnibus Order re 7 Order on Motion for Miscellaneous Relief, 5 Order. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and LR 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules.

NOTICE of Striking 8 Second MOTION to Extend Deadlines for Response to Omnibus Order re 7 Order on Motion for Miscellaneous Relief, 5 Order filed by Zuru Inc. by Zuru Inc.

Amended Second MOTION to Extend Deadlines for Response to Omnibus Order re 7 Order on Motion for Miscellaneous Relief, by Zuru Inc.

(Text of Proposed Order) Modified Text on 5/29/2025 (ls)

PAPERLESS ORDER granting 12 Motion for Extension of Time. Plaintiff shall file its Motion for Entry of a Temporary Restraining Order, Motion for Alternate Service, Motion to Seal, and Verified Response to the Court's Omnibus Order Regarding Schedule "A" Causes of Action on or before June 6, 2025. Signed by Judge Jose E. Martinez on 5/29/2025.

AMENDED COMPLAINT against Bytor, CANGLI US (MUYMUT), nan'jing'bo'ang'wang'luo'ke'ji'you'xian' gong'si, zhangshuyai22, Anyanghanzi, ZhengZhouChuanChunShangMaoYouXianGongSi, aixinfustore, Tezget (Piragha), pengfeikuajingdianzishangwuyouxiangongsi, yaojinhuadedianpu, filed by Zuru Inc.

(Exhibit 1 - Registration)

NOTICE of Striking [14] Amended Complaint/Amended Notice of Removal, filed by Zuru Inc. by Zuru Inc.

AMENDED COMPLAINT against Anyanghanzi, Bytor, CANGLI US (MUYMUT), Tezget (Piragha), ZhengZhouChuanChunShangMaoYouXianGongSi, aixinfustore, nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si, pengfeikuajingdianzishangwuyouxiangongsi, yaojinhuadedianpu, zhangshuyai22, filed by Zuru Inc.

Exhibit 1 - Registration

MOTION to Amend/Correct Case Caption and Incorporated Memorandum of Law by Zuru Inc. Responses due by 6/18/2025.

Text of Proposed Order

ORDER GRANTING MOTION TO AMEND CASE CAPTION granting [17] Motion to Amend/Correct. Signed by Judge Jose E. Martinez on 6/5/2025. See attached document for full details.

Plaintiff's RESPONSE to [5] Order Verified Response by Zuru Inc.

MOTION for Temporary Restraining Order and Order Restraining Transfer of Assets and Incorporated Memorandum of Law by Zuru Inc. Responses due by 6/20/2025.

Exhibit A to Motion for Entry of Temporary Restraining Order

Declaration of Sam Shen

Exhibit 1 to Declaration of Sam Shen

Declaration of Joel B. Rothman

Exhibit 1 to Declaration of Joel B. Rothman

Exhibit 2 to Declaration of Joel B. Rothman

Exhibit 3 to Declaration of Joel B. Rothman

Exhibit 4 to Declaration of Joel B. Rothman

Exhibit 5 to Declaration of Joel B. Rothman

Text of Proposed Order

MOTION to Extend Deadline to File Motion for Alternate Service re [13] Order on Motion for Miscellaneous Relief, by Zuru Inc.

Text of Proposed Order

Clerk's Notice to Filer re 21 MOTION to Extend Deadline to File Motion for Alternate Service re 13 Order on Motion for Miscellaneous Relief. Filer Selected the Wrong Motion Relief(s); ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs.

PAPERLESS ORDER granting 21 Motion for Extension of Time. The deadline for Plaintiff to file any motion for alternate service is extended until the Court has ruled on 20 Plaintiff's motion for a temporary restraining order. Plaintiff shall file any motion for alternate service no more than five days after the Court issues its ruling on Plaintiff's motion for a temporary restraining order. Signed by Judge Jose E. Martinez on 6/9/2025.

ORDER granting [20] Ex Parte Motion for Temporary Restraining Order. Signed by Judge Jose E. Martinez on 6/11/2025. See attached document for full details.

Second MOTION for Extension of Time to Extend Deadline to File Motion for Alternate Service by Zuru Inc. Responses due by 6/26/2025.

Text of Proposed Order

PAPERLESS ORDER granting in part and denying in part 25 Motion for Extension of Time. Plaintiff shall file any motion for alternate service on or before June 23, 2025. Plaintiff's request for an indefinite extension of time is DENIED. Plaintiff's request to file any motion for alternate service within thirty days after the issuance of a preliminary injunction is DENIED. Signed by Judge Jose E. Martinez on 6/13/2025.

Surety Bond in the amount of $5,000.00 receipt # S-981605 posted by Zuru Inc. Approved by Judge Jose E. Martinez.

Third MOTION for Extension of Time to Extend Deadline to File Motion for Alternate Service re [26] Order on Motion for Extension of Time, by Zuru Inc. Responses due by 7/7/2025.

Text of Proposed Order

MOTION to Extend the Temporary Restraining Order re [24] Order on Motion for Temporary Restraining Order by Zuru Inc.

Text of Proposed Order

PAPERLESS ORDER granting 28 Second Motion for Extension of Time. Plaintiff shall file any Motion for Alternate Service on or before July 14, 2025. No further extensions of time will be granted absent exigent circumstances. Signed by Judge Jose E. Martinez on 6/23/2025.

PAPERLESS ORDER granting 29 Motion to Extend the Temporary Restraining Order. The Court, having considered the Motion and having found good cause, therefore hereby ORDERS that the Motion is GRANTED and the Temporary Restraining Order shall be extended for a period of fourteen (14) days, up to and including July 9, 2025. Signed by Judge Jose E. Martinez on 6/23/2025.

NOTICE of Filing Proposed Summons(es) as to Defendant zhangshuyai22 by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant aixinfustore by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant ZhengZhouChuanChunShangMaoYouXianGongSi by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant yaojinhuadedianpu by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant pengfeikuajingdianzishangwuyouxiangongsi by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant Anyanghanzi by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant CANGLI US (MUYMUT) by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant Bytor by Zuru Inc.

NOTICE of Filing Proposed Summons(es) as to Defendant Tezget (Piragha) by Zuru Inc.

Summons Issued as to Anyanghanzi, Bytor, CANGLI US (MUYMUT), Tezget (Piragha), ZhengZhouChuanChunShangMaoYouXianGongSi, aixinfustore, nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si, pengfeikuajingdianzishangwuyouxiangongsi, yaojinhuadedianpu, zhangshuyai22.

Order (Text entry; no document attached.)

Summons Issued as to Anyanghanzi, Bytor, CANGLI US (MUYMUT), Tezget (Piragha), ZhengZhouChuanChunShangMaoYouXianGongSi, aixinfustore, nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si, pengfeikuajingdianzishangwuyouxiangongsi, yaojinhuadedianpu, zhangshuyai22.

Clerk's Notice of Docket Correction re 42 Summons Issued. Document Restricted Due to Error; Original document restricted. Document refiled, see DE# 43.

Notice of Action/Publication filed by Zuru Inc. Anyanghanzi answer/written defenses due by 7/21/2025; Bytor answer/written defenses due by 7/21/2025; CANGLI US (MUYMUT) answer/written defenses due by 7/21/2025; Tezget (Piragha) answer/written defenses due by 7/21/2025; ZhengZhouChuanChunShangMaoYouXianGongSi answer/written defenses due by 7/21/2025; aixinfustore answer/written defenses due by 7/21/2025; nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si answer/written defenses due by 7/21/2025; pengfeikuajingdianzishangwuyouxiangongsi answer/written defenses due by 7/21/2025; yaojinhuadedianpu answer/written defenses due by 7/21/2025; zhangshuyai22 answer/written defenses due by 7/21/2025.

MOTION for Preliminary Injunction and Incorporated Memorandum of Law by Zuru Inc.

Text of Proposed Order

ORDER REFERRING [46] MOTION for Preliminary Injunction. Motions referred to Judge Eduardo I. Sanchez. Signed by Judge Jose E. Martinez on 7/3/2025. See attached document for full details.

ORDER Setting Preliminary Injunction Hearing and Briefing Schedule. Preliminary Injunction Hearing is set for 7/14/2025 at 02:00 PM in Miami Division before Magistrate Judge Eduardo I. Sanchez. Responses due by 7/11/2025 at 5:00 PM; Reply due by 7/13/25 at 2:00 PM. Signed by Magistrate Judge Eduardo I. Sanchez on 7/7/2025. See attached document for full details. (ab05)

MOTION to Extend the Temporary Restraining Order re [31] Order on Motion for Miscellaneous Relief, [24] Order on Motion for Temporary Restraining Order by Zuru Inc.

Text of Proposed Order

PAPERLESS ORDER. The Court, having considered 49 Plaintiff's Motion to Extend the Temporary Restraining Order, and having found good cause, therefore hereby ORDERS that the Motion is GRANTED. The Temporary Restraining Order shall remain in effect for an additional fourteen (14) days, until July 23, 2025, or until Magistrate Judge Sanchez enters a Report and Recommendation on Plaintiff's Motion for a Preliminary Injunction, whichever is sooner. Signed by Judge Jose E. Martinez on 7/8/2025.

NOTICE of Voluntary Dismissal WITHOUT PREJUDICE AS TO DEFENDANT ZHANGSHUYAI22 by Zuru Inc.

Text of Proposed Order

Order of Dismissal upon [51] Notice of Voluntary Dismissal; Dismissing Case without prejudice solely as to Defendant zhangshuyai22. Case Remains Open. Signed by Judge Jose E. Martinez on 7/11/2025. See attached document for full details.

Plaintiff's NOTICE to Defendants regarding ECF No. 46 and ECF No. 48 by Zuru Inc. re [46] MOTION for Preliminary Injunction and Incorporated Memorandum of Law, [48] Order Setting Hearing on Motion

WAIVER OF SERVICE Returned Executed by Zuru Inc. CANGLI US (MUYMUT) waiver sent on 7/1/2025, response/answer due 9/29/2025.

PAPERLESS Minute Order for proceedings held before Magistrate Judge Eduardo I. Sanchez: Motion Hearing held on 7/14/2025 re 46 MOTION for Preliminary Injunction. Order to follow. Total time in court: 10 minutes. Attorney Appearance(s): Angela Nieves -Plaintiff's Counsel (Digital 14:28:32)

MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Incorporated Memorandum of Law re [30] Order on Motion for Extension of Time, by Zuru Inc.

Declaration of Joel B. Rothman

Exhibit 1 to Declaration of Joel B. Rothman

Exhibit 2 to Declaration of Joel B. Rothman

Text of Proposed Order

REPORT AND RECOMMENDATION re [46] Plaintiff's MOTION for Entry of Preliminary Injunction. Objections to R&R due by 7/24/2025. Signed by Magistrate Judge Eduardo I. Sanchez on 7/17/2025. See attached document for full details. (ab05)

ORDER Authorizing Alternate Service of Process on Defendants Pursuant to Fed. R. Civ. P. 4(f)(3): granting [56] Ex Parte Motion for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3). Signed by Judge Jose E. Martinez on 7/21/2025. See attached document for full details.

Third MOTION for Extension of Time for Temporary Restraining Order re [24] Order on Motion for Temporary Restraining Order by Zuru Inc. Responses due by 8/5/2025.

Text of Proposed Order

PAPERLESS ORDER. The Court, having considered 59 Plaintiff's Motion to Extend the Temporary Restraining Order, and having found good cause, ORDERS that the Motion is GRANTED. The Temporary Restraining Order shall remain in effect for an additional seven (7) days, until July 30, 2025, or until the Court rules on the Report and Recommendation entered by the Honorable Eduardo I. Sanchez following the Preliminary Injunction hearing, whichever is sooner. Signed by Judge Jose E. Martinez on 7/22/2025.

SUMMONS (Affidavit) Returned Executed on [16] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Zuru Inc. Anyanghanzi served on 7/22/2025, response/answer due 8/12/2025; Bytor served on 7/22/2025, response/answer due 8/12/2025; Tezget (Piragha) served on 7/22/2025, response/answer due 8/12/2025; ZhengZhouChuanChunShangMaoYouXianGongSi served on 7/22/2025, response/answer due 8/12/2025; aixinfustore served on 7/22/2025, response/answer due 8/12/2025; nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si served on 7/22/2025, response/answer due 8/12/2025; pengfeikuajingdianzishangwuyouxiangongsi served on 7/22/2025, response/answer due 8/12/2025; yaojinhuadedianpu served on 7/22/2025, response/answer due 8/12/2025.

ORDER ADOPTING REPORT AND RECOMMENDATIONS adopting Report and Recommendations re [57] Report and Recommendations; granting [46] Motion for Preliminary Injunction. Signed by Judge Jose E. Martinez on 7/25/2025. See attached document for full details.

MOTION for Clerk's Entry of Default as to Anyanghanzi, Bytor, Tezget (Piragha), ZhengZhouChuanChunShangMaoYouXianGongSi, aixinfustore, nan'jing'bo'ang'wang'luo'ke'ji'you'xian'gong'si, pengfeikuajingdianzishangwuyouxiangongsi, yaojinhuadedianpu by Zuru Inc.

Declaration of Joel B. Rothman

Exhibit 1 to Declaration of Joel B. Rothman

PAPERLESS ORDER by Clerk of Entry of Default re 63 Motion for Clerk's Entry of Default as to Anyanghanzi, Bytor, Tezget (Piragha), ZhengZhouChuanChunShangMaoYouXianGongSi, aixinfustore, nan'jing'bo'ang'wang'luo'ke'ji'you'xian' gong'si, pengfeikuajingdianzishangwuyouxiangongsi, yaojinhuadedianpu. Signed by DEPUTY CLERK on 8/20/2025.

ORDER on Final Default Judgment Procedure: Defendants Answer/Response to Complaint due 9/3/2025; If Defendants Fail to do so, Plaintiff's Motion for Final Default Judgment due 9/10/2025. Signed by Judge Jose E. Martinez on 8/20/2025. See attached document for full details.

CERTIFICATE OF SERVICE by Zuru Inc. re [65] Order, Set Response/Answer Due Deadline

NOTICE of Voluntary Dismissal as to Defendant CANGLI US (MUYMUT) by Zuru Inc.

Text of Proposed Order

Order of Dismissal upon [67] Notice of Voluntary Dismissal; Dismissing Action with prejudice as to Defendant CANGLI US (MUYMUT); Administratively Closing Case. Signed by Judge Jose E. Martinez on 8/27/2025. See attached document for full details.

Civil Case Terminated. Closing Case. (Text entry; no document attached.)

MOTION for Default Judgment by Zuru Inc.

Declaration of Rachel I. Kaminetzky

Text of Proposed Order Granting Motion for Entry of Final Judgment by Default an

Text of Proposed Order Final Default Judgment and Permanent Injunction

ORDER REFERRING [69] MOTION for Default Judgment. Motions referred to Judge Eduardo I. Sanchez. Signed by Judge Jose E. Martinez on 9/11/2025. See attached document for full details.