2025-cv-22977

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto. Filing fees $ 405.00 receipt number AFLSDC-18587254, filed by Hong Kong Leyuzhen Technology Co. Limited.

Exhibit 1 to the Complaint

(Complaint with Exhibits) (wce)

Exhibit 1 the Declaration of J. Sheskin in Support of Verified Response

(Text of Proposed Order)

(Text of Proposed Order)

Affidavit of E. Heim in Support of Motion for Preliminary Injunction

Certification of Benjamin Solter

Text of Proposed Order

Exhibit Declaration of Xiaoling Weng

Exhibit 1 Verification of Translation

Exhibit Declaration of SxClub onsite worker Yujie Chen

Text of Proposed Order

Text of Proposed Order

Clerks Notice of Judge Assignment to Judge Rodolfo A. Ruiz, II. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis 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.

Exhibit 2 to the Complaint

Exhibit 2 to the Verified Response

(Text of Proposed Order)

Text of Proposed Order

Exhibit The Dismissal Notice From NDIL Case 24-cv-2939 (Moving Defendant was No.

Exhibit 2 Declaration of W. Brees in Support of Response in Opposition

Exhibit Declaration of Ziqi Yu

FORM AO 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE.

Exhibit 3 to the Complaint

(Exhibit 3 to the Verified Response)

Exhibit the docket of NDIL Case 24-cv-2939 as of August 18, 2025

Exhibit China Hague Convention Information

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

Civil Cover Sheet

Exhibit Amazon Address Verification Policy

Omnibus Order Regarding Schedule "A" Causes of Action; Administratively Closing Case. Signed by Judge Rodolfo A. Ruiz, II on 7/3/2025. See attached document for full details. (nn00)

(Summon(s))

Exhibit China's Ministry of Justice's website

RESPONSE to 5 Administrative Order by Hong Kong Leyuzhen Technology Co. Limited.

Exhibit China's Ministry of Justice's website with Google Chrome Brows

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

Exhibit Copyright Registration Certificate

SYSTEM ENTRY - Docket Entry 8 [motion] restricted/sealed until further notice. (1735549) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 9 [motion] restricted/sealed until further notice. (1735549) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 11 [order] restricted/sealed until further notice. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 12 [misc] restricted/sealed until further notice. (1735549) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 13 [misc] restricted/sealed until further notice. (1735549) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 14 [misc] restricted/sealed until further notice. (1735549) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 15 [order] restricted/sealed until further notice. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 16 [misc] restricted/sealed until further notice. (Text entry; no document attached.)

Hearing(s) terminated. Reset Hearing as to [19] MOTION for Preliminary Injunction.(Telephonic Motion Hearing set for 9/4/2025 10:00 AM before Judge Rodolfo A. Ruiz II.) (ls)(per DE #28) (Text entry; no document attached.)

Hearing(s) terminated. Reset Hearing as to [19] MOTION for Preliminary Injunction.(Telephonic Motion Hearing set for 9/4/2025 10:00 AM before Judge Rodolfo A. Ruiz II.) (ls)(per DE #28) (Text entry; no document attached.)

ORDER granting 7 Motion to File Under Seal. Signed by Judge Rodolfo A. Ruiz, II on 7/21/2025. See attached document for full details.

Exhibit Exhibit A to Exhibit 9, Declaration of Benjamin Solter

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 8/7/2025, response/answer due 8/28/2025.

MOTION to Reopen Case by Hong Kong Leyuzhen Technology Co. Limited.

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

PAPERLESS ORDER Setting Telephonic Hearing on 19 Plaintiff's Motion for Preliminary Injunction for Thursday, August 21, 2025, at 11:00 A.M. The parties are instructed to call +1 833-568-8864 by no later than 10:55 A.M. The phone conference ID is 160 623 6605 and the password is 304850. The Court requires that the parties appear via a landline (i.e., not a cellular phone or a speaker phone) if possible for clarity. Accordingly, Plaintiff's 18 Motion to Reopen Case is GRANTED. Signed by Judge Rodolfo A. Ruiz, II on 8/12/2025. (nn00)

NOTICE of Attorney Appearance by Ziqi Yu on behalf of SxClub. Attorney Ziqi Yu added to party SxClub(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-18713356 by SxClub. Responses due by 9/2/2025.

NOTICE of Hearing by ATTORNEY: re [19] MOTION for Preliminary Injunction Preliminary Injunction Hearing set for 8/21/2025 11:00 AM in Miami Division before Judge Rodolfo A. Ruiz II.

PAPERLESS ORDER granting Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for attorney Benjamin Solter, [ECF No. 22]. Signed by Judge Rodolfo A. Ruiz, II on 8/19/2025. (nn00)

Joint MOTION to Continue PI Hearing and Extend TRO re [20] Order on Motion to Reopen Case, Order on Motion for Preliminary Injunction, [23] Notice re Hearing by Attorney filed by SxClub by SxClub. Responses due by 9/3/2025.

Corporate Disclosure Statement by SxClub

MOTION to Vacate [19] MOTION for Preliminary Injunction and to Dissolve TRO by SxClub. Responses due by 9/3/2025.

ORDER granting [25] Motion to Continue. Signed by Judge Rodolfo A. Ruiz, II on 8/20/2025. See attached document for full details. (nn00)

Clerk's Notice to Filer re 26 Certificate of Other Affiliates/Corporate Disclosure Statement. Other Affiliates Not Entered; ERROR - The Filer failed to enter all Other Affiliates from the Certificate of Other Affiliates/Corporate Disclosure Statement. Filer is instructed to refile their Certificate of Other Affiliates/Corporate Disclosure Statement and enter the missing Other Affiliates. Note - Other Affiliates do not appear on the docket sheet.

CERTIFICATE OF SERVICE by Hong Kong Leyuzhen Technology Co. Limited re [28] Order on Motion to Continue

Corporate Disclosure Statement by SxClub identifying Other Affiliate Xiaoling Weng for SxClub

RESPONSE in Opposition re [27] MOTION to Vacate [19] MOTION for Preliminary Injunction and to Dissolve TRO filed by Hong Kong Leyuzhen Technology Co. Limited. Replies due by 9/4/2025.

Defendant's REPLY to [32] Response in Opposition to Motion, In Support of Motion to Vacate [27] by SxClub.

NOTICE of Voluntary Dismissal ONLY AS TO DEFENDANT NUMBERS 3 - 6 WITH PREJUDICE by Hong Kong Leyuzhen Technology Co. Limited

ORDER Dismissing Certain Defendants upon [34] Notice of Voluntary Dismissal; Dismissing with prejudice Defendants oelaio amaz0n prime day 2024 deals aka oelaio black friday deals cyber monday deals 2024 aka oelaio spring deals 2025 (No. 3); RKSTN Fashion (No. 4); jsaierl womens clothing aka fashion clothing clearance (No. 5); and XUNRYAN (No. 6). Signed by Judge Rodolfo A. Ruiz, II on 9/2/2025. See attached document for full details.

STATUS REPORT (Joint) IN COMPLIANCE WITH DKT. NO. 28 by Hong Kong Leyuzhen Technology Co. Limited

STIPULATION Regarding an Agreed Asset Restraint by Hong Kong Leyuzhen Technology Co. Limited

PAPERLESS Minute Entry for proceedings held before Judge Rodolfo A. Ruiz, II: Telephonic Motion Hearing held on 9/4/2025 re 19 MOTION for Preliminary Injunction filed by Hong Kong Leyuzhen Technology Co. Limited. Attorney Appearance(s): William Robert Brees, Ziqi Yu, Benjamin Solter, Court Reporter: Ilona Lupowitz, 305-523-5737 / Ilona_lupowitz@flsd.uscourts.gov.

Joint MOTION for Extension of Time TO MODIFY AND EXTEND TEMPORARY RESTRAINING ORDER by Hong Kong Leyuzhen Technology Co. Limited. Responses due by 9/18/2025.

NOTICE OF FILING AMENDED [PROPOSED] PRELIMINARY INJUNCTION ORDER by Hong Kong Leyuzhen Technology Co. Limited re [19] MOTION for Preliminary Injunction

ORDER GRANTING [39] JOINT MOTION TO MODIFY AND EXTEND TEMPORARY RESTRAINING ORDER. Signed by Judge Rodolfo A. Ruiz, II on 9/4/2025. See attached document for full details. (nn00)

ORDER granting [19] Motion for Preliminary Injunction. Signed by Judge Rodolfo A. Ruiz, II on 9/5/2025. See attached document for full details. (nn00)

PAPERLESS ORDER denying without prejudice [27] Defendant SxClub (No. 2)'s Motion to Dissolve the Ex Parte Temporary Restraining Order Nunc Pro Tunc and Deny Preliminary Injunction ("Motion"). The Court entered an [41] Order Granting Plaintiff and Defendant SxClub (No. 2)'s Joint Motion to Modify and Extend Temporary Restraining Order on September 4, 2025 ("Order'"). The [41] Order extends the [15] Temporary Restraining Order in this case by fourteen (14) days to allow the parties time to reach a settlement agreement, as discussed at the [38] Hearing on Plaintiff's Motion for Preliminary Injunction held on September 4, 2025. Given that the parties expect to reach a settlement agreement as discussed at the [38] Hearing and the Court has granted Plaintiff's [19] Motion for Preliminary Injunction as to all remaining Defendants save Defendant SxClub (No. 2), Defendant SxClub (No. 2)'s [27] Motion is DENIED without prejudice. Signed by Judge Rodolfo A. Ruiz, II on 9/6/2025. (nn00)

Exhibit SxClub's Registration Information in China's official corporat

Exhibit Declaration of Benjamin Solter