2024-cv-05583

COMPLAINT filed by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd; Filing fee $ 405, receipt number AILNDC-22207325.

Exhibit 1

Exhibit 2

(Schedule A)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd by Genesis Shin

SEALED DOCUMENT by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd - Schedule A to Complaint

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd

CLAIM - AO 120 Form (Trademark) by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd

MEMORANDUM by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd in Support of Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

MOTION by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd for leave to file excess pages re Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

(Exhibit A)

DECLARATION of Genesis Shin in Support of Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

Exhibit 1 - Jan 2011 MarkMonitor

Exhibit 2 - IP Rights Seizure Statistics

Exhibit 3 - BASCAP Report

Exhibit 4 - 2013 Registrar Agreement

Exhibit 5 - Hague Convention of Service Abroad

(Exhibit 6 - Translation of Civil Procedure Law of the People of China)

DECLARATION of Cedar Anderson in Support of Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

Exhibit 1 - Patents

(Exhibit 2 - Trademarks)

SEALED DOCUMENT by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd Exhibit 3 (Part 1 of 33)

Exhibit 3 (Part 2 of 33)

Exhibit 3 (Part 3 of 33)

Exhibit 3 (Part 4 of 33)

Exhibit 3 (Part 5 of 33)

Exhibit 3 (Part 6 of 33)

Exhibit 3 (Part 7 of 33)

Exhibit 3 (Part 8 of 33)

Exhibit 3 (Part 9 of 33)

Exhibit 3 (Part 10 of 33)

Exhibit 3 (Part 11 of 33)

Exhibit 3 (Part 12 of 33)

Exhibit 3 (Part 13 of 33)

Exhibit 3 (Part 14 of 33)

Exhibit 3 (Part 15 of 33)

Exhibit 3 (Part 16 of 33)

Exhibit 3 (Part 17 of 33)

Exhibit 3 (Part 18 of 33)

Exhibit 3 (Part 19 of 33)

Exhibit 3 (Part 20 of 33)

Exhibit 3 (Part 21 of 33)

Exhibit 3 (Part 22 of 33)

Exhibit 3 (Part 23 of 33)

Exhibit 3 (Part 24 of 33)

Exhibit 3 (Part 25 of 33)

Exhibit 3 (Part 26 of 33)

Exhibit 3 (Part 27 of 33)

Exhibit 3 (Part 28 of 33)

Exhibit 3 (Part 29 of 33)

Exhibit 3 (Part 30 of 33)

Exhibit 3 (Part 31 of 33)

Exhibit 3 (Part 32 of 33)

(Exhibit 3 (Part 33 of 33))

ATTORNEY Appearance for Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd by Samantha Diane Parrish

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 1). (Text entry; no document attached.)

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (Text entry; no document attached.)

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Jeffrey I Cummings for all further proceedings; pursuant to the provisions of 28 USC 294(b). Honorable Judge Thomas M. Durkin no longer assigned to the case. Mailed notice

(Request for Reassignment)

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. Plaintiff's motion for leave to file under seal 7 is granted. Plaintiff's motion for temporary restraining order 8, and plaintiff's motion for leave to file excess pages 10 are entered and continued. Upon review of the complaint and the TRO submissions, the Court sua sponte raises the proprietary of joinder of over 180 defendants in this case. See, e.g. Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D.Ill. 2020). By 8/7/24, plaintiff shall file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder. In the alternative, plaintiff has leave to file an amended complaint with a smaller subset of defendants along with its memorandum explaining specifically why each defendant is properly joined to all of the others. Estee Lauder, 334 F.R.D. at 189. Status hearing set for 9/23/24 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MEMORANDUM order on motion for exparte, order on motion for leave to file excess pages, set deadlines/hearings, 16 by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd

Declaration of Samantha Parrish

Exhibit 1

Exhibit 2

(Exhibit 3)

MINUTE entry before the Honorable Jeffrey I Cummings: The 9/23/24 tracking status hearing is stricken and re-set to 10/14/24 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed plaintiffs' memorandum in support of joinder 16 and finds that joinder is proper at this preliminary stage pursuant to Fed.R.Civ.P. 20(a)(2). Specifically, plaintiffs have alleged that beyond just infringing the same patent and trademark - which alone is insufficient to establish the propriety of joinder, see Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182, 187 (N.D.Ill. 2020), the defendants are based in China and other foreign jurisdictions, certain of the defendant stores bear virtually identical layouts using the same text and images with the same incorrect grammar and misspellings, and - most importantly to this Court - the counterfeit products of plaintiffs' "unique and radically innovative artificial honeycomb frame" "bear similar irregularities and indicia of being unauthorized to one another," suggesting that they were "manufactured by and come from a common source and that defendants are interrelated." (See Dckt. #12 - Declaration of Cedar Anderson). Further, no defendants will be prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D.Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. And, of course, the Court's finding regarding joinder in this case is not dispositive of the propriety of joinder in any other cases before the Court. Plaintiff's motion for leave to file excess pages 10 is granted. Plaintiff's ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and electronic service of process 8 is granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. The Temporary Restraining Order being entered along with this order will also be entered under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. The previously set 10/14/24 tracking status hearing is stricken and re-set to 1/10/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 11/15/2024. Mailed notice

BOND in the amount of $ $5,000, law firm check, Receipt No. 100013420 posted by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd (Text entry; no document attached.)

MEMORANDUM in Support of Plaintiff's Ex Parte Motion to Extend Temporary Restraining Order (DE 21)

DECLARATION of Samantha Parrish in Support of Plaintiff's Ex Parte Motion to Extend Temporary Restraining Order (DE 21)

MINUTE entry before the Honorable Jeffrey I. Cummings: Plaintiff's motion for extension of the TRO 21 is granted. The TRO entered on 11/15/24 is extended to 12/13/24. Mailed notice

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint (Text entry; no document attached.)

SUMMONS Returned Executed by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint on 12/12/2024, answer due 1/2/2025.

MOTION by Plaintiffs FlowBee Australia Pty Ltd, BeeInventive Pty Ltd to Extend the Temporary Restraining Order, MOTION by Plaintiffs FlowBee Australia Pty Ltd, BeeInventive Pty Ltd for preliminary injunction

MEMORANDUM by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd in support of motion for miscellaneous relief, motion for preliminary injunction, 26

DECLARATION of Samantha Parrish regarding memorandum in support of motion 27, motion for miscellaneous relief, motion for preliminary injunction, 26

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 26. In connection with that motion, plaintiff must serve all remaining defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by or before December 23, 2024." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's order entering the TRO, the TRO is extended to and including the date upon which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under Fed.R.Civ.P. 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

AFFIDAVIT of Service filed by Plaintiffs FlowBee Australia Pty Ltd, BeeInventive Pty Ltd regarding Court's December 13, 2024 Minute Entry served on Defendants at the email addresses identified on the Aliexpress, Amazon, eBay, and Walmart platforms on December 13, 2024

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant Nos. 21 (BANGCHENDA), 41 (lufeizhuangshi), 73 (85836781dd), 92 (chenggong-bi2023), 95 (darnellh_95), 105 (factorymachineseller), 120 (honest-machine-store), 126 (jianpingsunstore), 127 (jiaoyangruhuo), 133 (machineseller-plus), 134 (machine-toolstore), 137 (manman2018), 146 (onegoodseller-machine), 151 (qingfengxulai), and 180 (xiguatian)

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 26 is granted as to the remaining defendants. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any remaining defendant. By 1/3/25, plaintiff shall submit an updated proposed preliminary injunction order reflecting only the remaining defendants to the Court's proposed order inbox (proposed_order_cummings@ilnd.uscourts.gov). Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. The 1/10/25 tracking status hearing is stricken and re-set to 2/10/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant Nos. 20 (BaiJiaShengUS), 35 (JuEUS), 51 (Vibrant linebuy), and 59 (YXRabrin)

ATTORNEY Appearance for Defendant PrecisionTech Instruments by Jianyin Liu

MOTION by Defendant PrecisionTech Instruments for extension of time to file answer regarding summons returned executed, 25, complaint 1, Unopposed

NOTICE by PrecisionTech Instruments re MOTION by Defendant PrecisionTech Instruments for extension of time to file answer regarding summons returned executed, 25, complaint 1, Unopposed 35 of Striking of Filing [DE 35]

MOTION by Defendant PrecisionTech Instruments for extension of time to file answer regarding summons returned executed, 25, complaint 1, Unopposed

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant Nos. 132 (Machine Supplier Store) and 147 (outlets-plus)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant Nos. 17 (ANSHENGSHENG), 18 (AOZHIZHANG), 26 (DiMeiYa), 34 (JingYanUS), 39 (LiChuanShiLanMengDianZiShangWuYouXianGongSi), 47 (SHASHAKUAI), and 57 (YUWEIT)

NEW PARTIES: CCXC Tools Store(1), China convenience grocery store Store(2), China happiness products Store(3), China Shenzhen super factory Store(4), Emily Wholesale Tool Store(5), Haotools Global Store(6), Happy family of Hainan Island Store(7), Kitchen Accessories Factory Direct Store(8), KSMT Store(9), Shop1102141026 Store(10), Shop1102732749 Store(11), Shop1102772252 Store(12), Shop1103184963 Store(13), Shop1103414207 Store(14), Tools&Instruments Factory Store(15), AKELUN(16), BACHINCNC(19), BieXuUS(22), Bottle TBox(23), BYFDZ(24), CKUS(25), Eric Marion(27), Happy^Buy(28), HUAYIDE(29), Ido Bee Beat(30), intonly(31), JGUYDHY(32), JingniUS(33), JunLing-US(36), Karanja Phone Accessories(37), LANGLANG(38), lin xian cheng xin ri za bai huo shang dian(40), L-Westine(42), Onetuon(43), PrecisionTech Instruments(44), Rayden store(45), Richo Goodday(46), ShengShiAiUS(48), taiyuanshijinyuanqujinfengwangdian(49), The Days Store(50), Vonluxeer(52), Wbjmaoyi(53), wuyule(54), XiaoQiLin(55), XiLiHua(56), YWYCNC(58), zhongguoren(60), zosolatestore(61), 3cstorenew(62), 6Kmoto shop(63), 7color-life(64), 19hyacinth(65), 20sunnymall(66), 21flash-deals(67), 21sundream(68), 24hhome(69), 88auto-motors(70), 313newstard(71), 2019sunshine(72), amoy-Eshop(74), aufuture(75), auto-motorrad(76), Awesome2022(77), beautyday68(78), bechanging(79), Beehouse(80), Beekeepingtools(81), Beekpking77(82), bestengraving(83), better19future(84), better-life888(85), biety0315(86), bradleym-83(87), breakthrough86(88), byan-2479(89), cart88moto(90), charmantjoy(91), Clean-2024(93), CynthiaLove7(94), deselfmall(96), deyifly3(97), dkxc5980(98), dominate17(99), easy-shopping12(100), eb1good(101), efunparts21(102), e-lab-4u(103), enjoysale858(104), familia*rize203(106), faststores(107), fireflyaurora(108), fly-rainbow7(109), fruitful_2024(110), full4smile(111), genuineshenzhen2020(112), greatbabyshop2014(113), happyending10(114), happyever2019(115), happyexperience15(116), happylife8(117), happymiao68(118), happytimes2020(119), hskywin8(121), htl2020rich(122), htpow666(123), ice-beauty19(124), increasable-7(125), KaariDream(128), kaariok(129), kingmotobike741(130), Lovehome20(131), magmiiow688(135), mallsun18(136), miaomore88(138), michael_store45(139), moscar388(140), motofire241(141), motosales368(142), nicepercent(143), nissan_store(144), nuri_shop23(145), pentium19(148), probike838(149), pslmche(150), salebuymoto174(152), SatanniyaRoom(153), sharing668(154), shoppingonetheway12(155), siyuxiruchou(156), smartcity541(157), smartview12(158), smiledeals32(159), smoothly2020(160), stronghold-7(161), sun9rise(162), sunmeeting(163), sunshine3996(164), sunsicooper(165), superauto88(166), sushigo(167), sweet2019life(168), sysler(169), tomorrow-top(170), tool-life(171), topsun20(172), ultra-eshop6(173), vercarenest(174), wehonest uk(175), wellonetop(176), welove222(177), wishsunshine99(178), workers66(179), yaleader(181), zhenzhi-37(182), zhenzhi-37(183) and Spoon Rare Home Store(184) added to case caption. (Text entry; no document attached.)

AMENDED PRELIMINARY INJUNCTION ORDER Signed by the Honorable Jeffrey I Cummings on 1/7/2025. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: Defendant PrecisionTech Instruments' unopposed motion for extension of time 37 is granted. If this matter is not resolved as to defendant PrecisionTech, defendant shall answer or otherwise plead by 1/16/25. The previously filed motion 35 is terminated as moot. Mailed notice

ANSWER to Complaint with Jury Demand by PrecisionTech Instruments

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant Nos. 16 (AKELUN), 22 (BieXuUS), 23 (Bottle TBox), 24 (BYFDZ), 25 (CKUS), 27 (Eric Marion), 28 (Happy^Buy), 30 (Ido Bee Beat), 33 (JingniUS), 36 (JunLing-US), 40 (lin xian cheng xin ri za bai huo shang dian), 43 (Onetuon), 48 (ShengShiAiUS), 53 (Wbjmaoyi), 55 (XiaoQiLin), 58 (YWYCNC), 139 (michael_store45), and 144 (nissan_store)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant No. 54 (wuyule)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant No. 165 (sunsicooper)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant No. 31 (intonly)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant Nos. 13 (Shop1103184963 Store), 14 (Shop1103414207 Store), 98 (dkxc5980), and 161 (stronghold-7)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant No. 19 (BACHINCNC)

NOTICE of Voluntary Dismissal by FlowBee Australia Pty Ltd, BeeInventive Pty Ltd of Defendant No. 29 (HUAYIDE)

MINUTE entry before the Honorable Jeffrey I Cummings: By 3/11/25, plaintiff and defendant PrecisionTech Instruments shall file a joint status report regarding any ongoing settlement negotiations. If the parties have not resolved their dispute, they shall include a proposed case schedule in accordance with the template available on the Court's website under the case management procedure titled "Initial Status Report for Newly Filed Cases." The previously set 2/10/25 tracking status hearing is stricken and re-set to 3/24/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

NOTICE of Voluntary Dismissal by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd of Defendant Nos. 81 (Beekeepingtools), 82 (Beekpking77), 93 (Clean-2024), and 164 (sunshine3996)

NOTICE of Voluntary Dismissal by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd of Defendant Nos. 104 (enjoysale858), 140 (moscar388), 141 (motofire241), 142 (motosales368), and 152 (salebuymoto174)

NOTICE of Voluntary Dismissal by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd of Defendant No. 44 (PrecisionTech Instruments)

MINUTE entry before the Honorable Jeffrey I Cummings: The 3/11/25 status report deadline for plaintiff and defendant Precision Tech is stricken in light of plaintiff's notice of voluntary dismissal of defendant Precision Tech. If plaintiff intends to move for an order of default and default judgment, any such motion shall be filed by 4/4/25. The 3/24/25 tracking status hearing is stricken and re-set to 4/25/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

NOTICE of Voluntary Dismissal by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd of Defendant No. 61 (zosolatestore)

MOTION by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd for default judgment as to the Defendants identified on the First Amended Schedule A

MEMORANDUM by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd in support of motion for default judgment 56

DECLARATION of Samantha Parrish regarding memorandum in support of motion 57, motion for default judgment 56

Exhibit A - Service Emails

Exhibit B - Case Website

(Exhibit C - Amended Schedule A to the Complaint)

MEMORANDUM by BeeInventive Pty Ltd, FlowBee Australia Pty Ltd in support of motion for default judgment 56 (AMENDED)

AFFIDAVIT of Service filed by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd regarding Plaintiffs' Motion for Default Judgment and Supporting Papers served on Defendants at the email addresses identified on the Aliexpress, Amazon, eBay, and Walmart platforms on 4/7/2025

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 56 for entry of default and default judgment against all remaining defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 4/22/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. The 4/25/25 tracking status hearing is stricken and re-set to 5/23/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

AFFIDAVIT of Service filed by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd regarding April 9, 2025 Minute Entry served on Defendants at the email addresses identified on the Aliexpress, Amazon, eBay, and Walmart platforms on April 9, 2025

MINUTE entry before the Honorable Jeffrey I Cummings: The remaining defendants have not responded to plaintiff's motion for entry of default judgment. Accordingly, the motion 56 is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. Defendants' infringement irreparably harms plaintiff and confuses the public. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, the safety risk to the public of the counterfeit bee hives at issue, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $75,000 is an appropriate award of statutory damages. Enter Final Judgment Order. All pending deadlines and hearings are stricken. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Jeffrey I Cummings on 8/1/2025. Mailed notice

MAILED patent report to Patent Trademark Office, Alexandria VA

ENTERED JUDGMENT Mailed notice

FULL SATISFACTION of Judgment regarding entered judgment 66, order 64 as to Defendant No. 145 (nuri_shop23)

FULL SATISFACTION of Judgment regarding entered judgment 66, order 64 re Defendant Nos. 63 (6Kmoto shop), 90 (cart88moto), 130 (kingmotobike741), and 149 (probike838)

MOTION by Plaintiffs BeeInventive Pty Ltd, FlowBee Australia Pty Ltd for disbursement of funds - Return of Bond

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiffs' motion for return of bond 69 is granted. Enter Order. Mailed notice

DISBURSEMENT ORDER Signed by the Honorable Jeffrey I Cummings on 10/2/2025. Mailed notice