2025-cv-00138

COMPLAINT filed by Bestway Inflatables & Material Corp.; Jury Demand. Filing fee $ 405, receipt number AILNDC-22918109.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bestway Inflatables & Material Corp. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Bestway Inflatables & Material Corp. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Bestway Inflatables & Material Corp. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Bestway Inflatables & Material Corp. by John Wilson

MOTION by Plaintiff Bestway Inflatables & Material Corp. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bestway Inflatables & Material Corp.

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2). (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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Bestway Inflatables & Material Corp. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bestway Inflatables & Material Corp. for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Bestway Inflatables & Material Corp. in support of motion for temporary restraining order, 13

Declaration Liu Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 1 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 2 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 3 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 4 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 5 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 6 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 7 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 8 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 9 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 10 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 11 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 12 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 13 of Liu Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 14 of Liu Declaration

Notice of Claims Involving Trademarks by Bestway Inflatables & Material Corp.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 7 and motion for leave to file excess pages 12 are granted. Plaintiff's ex parte motion for a temporary restraining order 13 is denied, without prejudice to refiling. Plaintiff has named 280 defendants. In the Court's view, this stretches the bounds of proper joinder beyond what is appropriate. Plaintiff will have to dismiss at least 30 defendants before the case may proceed.

AMENDED complaint by Bestway Inflatables & Material Corp. against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Amended Schedule A

MOTION by Plaintiff Bestway Inflatables & Material Corp. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bestway Inflatables & Material Corp. for temporary restraining order Plaintiff's Renewed Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Bestway Inflatables & Material Corp. in support of motion for temporary restraining order, 34

Declaration Li Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 1 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 2 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 3 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 4 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 5 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 6 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 7 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 8 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 9 of Li Declaration

SEALED DOCUMENT by Plaintiff Bestway Inflatables & Material Corp. Exhibit 2 Part 10 of Li Declaration

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file excess pages 33 is granted. Plaintiff's renewed ex parte motion for a temporary restraining order (etc.) 34 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 2/19/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO must be filed by 2/12/2025. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. In addition plaintiff must promptly serve summons electronically. The Court may deny entry of a preliminary injunction based on inadequate notice of the lawsuit if there is too short an interval between completion of electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 2/5/2025.

SURETY BOND in the amount of $ 10,000.00 posted by Bestway Inflatables & Material Corp. (Document not imaged)

MOTION by Plaintiff Bestway Inflatables & Material Corp. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to extend the temporary restraining order 49 is granted; the ex parte TRO entered by the Court on 2/5/2025 is extended through 3/5/2025. The telephonic preliminary injunction hearing set for 2/19/2025 is vacated and reset to 3/5/2025 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction must be filed by 2/26/2025. Plaintiff is reminded that it must promptly serve summons electronically and that the Court may deny entry of a preliminary injunction based on inadequate notice of the lawsuit if there is too short an interval between completion of electronic service of summons and the preliminary injunction hearing.

ATTORNEY Appearance for Defendant Best Choice Outdoor by Steven G Kalberg

MOTION by Plaintiff Bestway Inflatables & Material Corp. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Bestway Inflatables & Material Corp. in support of motion for preliminary injunction 53

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 53

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

SUMMONS Returned Executed by Bestway Inflatables & Material Corp. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto on 2/26/2025, answer due 3/19/2025.

ATTORNEY Appearance for Defendant BlueStars by Zhongyi Huang

ATTORNEY Appearance for Defendants PeggyDoll, Guichaokj, DiMaddie by Adam Edward Urbanczyk

RESPONSE by BlueStars in Opposition to MOTION by Plaintiff Bestway Inflatables & Material Corp. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction [53]

MOTION by Defendants DiMaddie, Guichaokj, PeggyDoll to set a briefing schedule re: Dkt. 53

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 3/5/2025. Any response to the motion for preliminary injunction is due 3/12/2025. Plaintiff's reply to the responses is due 3/19/2025. The case is set for a telephonic status hearing on 3/24/2025 at 9:10 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. The previously entered temporary restraining order is extended to 3/24/2025 due to good cause having been shown and for time to consider the briefing by the parties who are objecting the preliminary injunction. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRO SE Appearance by Defendants Usa-best-deal, unogoo_trade05 (Received via pro se email on 3/5/2025)

MOTION by Defendants unogoo_trade05, Usa-best-deal to dismiss TRO and Complaint and ANSWER and Affirmative Defenses (Received via pro se email on 3/5/2025)

MINUTE entry before the Honorable Matthew F. Kennelly: Response to motion to dismiss by defendants unogoo_trade05 and Usa-best-deal is to be filed by 3/13/2025; reply to response is to be filed by 3/19/2025. Telephonic hearing is set for 3/24/2025 at 9:10 AM, using call-in number 650-479-3207, access code 2305-915-8729.

Emergency Motion to Modify Asset Restraint by BlueStars

Declaration

Exhibit 1

Exhibit 2

ATTORNEY Appearance for Defendant slamate by Christopher Paul Keleher

MINUTE entry before the Honorable Matthew F. Kennelly: At the 3/5/2025 hearing in this case, defendant BlueStars asked for time to respond to plaintiff's motion for preliminary injunction. The Court set a schedule for BlueStars to respond and plaintiff to reply on that motion and set the matter for a further telephonic hearing on 3/24/2025. The Court extended the TRO after finding good cause. Then two days later BlueStars filed an "emergency" motion to reduce the asset restraint, saying that the amount restrained exceeds by hundreds of thousands of dollars the amount of any conceivable profits on infringing sales. The Court is left to wonder why BlueStars's attorney said nothing about this during the 3/5/2025 hearing, not even at the end of the hearing when the Court asked, "Anything else that we haven't already talked about that anybody wants to bring up?" Given the circumstances, the Court sees no basis to modify the existing schedule, though it does urge plaintiff to return defense counsel's communications and attempt to resolve the matter of the amount secured prior to the 3/24/2025 hearing and reminds plaintiff that there are consequences if a party is found to have been wrongfully restrained. Plaintiff's response to the motion to modify is due on 3/19/2025, the same date as its reply on the motion for preliminary injunction.

MOTION by Defendant slamate to set a briefing schedule Plaintiff's Motion for Preliminary Injunction

ATTORNEY Appearance for Defendant Wowreed by Sydney Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Wowreed

MINUTE entry before the Honorable Matthew F. Kennelly: Defendant Slamate is given until 3/17/2025 to file a response to plaintiff's motion for preliminary injunction.

ATTORNEY Appearance for Defendant Dongguan Yuanfeng Technology Co., Ltd. d/b/a BeckacherDirect by Tao Liu

ATTORNEY Appearance for Defendant Dongguan Yuanfeng Technology Co., Ltd. d/b/a BeckacherDirect by Wei Wang

MEMORANDUM by Best Choice Outdoor in Opposition to motion for preliminary injunction[53]

Exhibit List

Declaration of Yusen Dong

Exhibit A Best Choice Outdoor Accused Sales

Exhibit B Best Choice Outdoor Restrained Balance

Exhibit C Amazon.com's Trademark Policy

Exhibit D Best Choice Outdoor Accused Products

RESPONSE by DiMaddie, Guichaokj, PeggyDollin Opposition to MOTION by Plaintiff Bestway Inflatables & Material Corp. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction [53]

Exhibit 1

Declaration of Qinghua Liao

RESPONSE by Dongguan Yuanfeng Technology Co., Ltd. d/b/a BeckacherDirectin Opposition to MOTION by Plaintiff Bestway Inflatables & Material Corp. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction [53]

Declaration of Qingyang Yu

Exhibit A

MOTION by Defendants DiMaddie, Guichaokj, PeggyDoll for leave to file excess pages UNOPPOSED

RESPONSE by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Response to the Motion to Dismiss by Defendant Nos. 27 "Unogoo Trade05" and 28 "USA-Best-Deal" [Dkt. No. 64]

Exhibit 1

Exhibit 2

Exhibit 3

MINUTE entry before the Honorable Matthew F. Kennelly: Certain defendants' motion for leave to file a 24-page memorandum [78] is granted.

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

RESPONSE by slamatein Opposition to MOTION by Plaintiff Bestway Inflatables & Material Corp. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction [53]

Exhibit Store owner declaration

Exhibit Amazon product listing

Motion by Wowreed to Dissolve TRO and Unfreeze Assets

Exhibit Wowreed Trademark

Exhibit Declaration

Exhibit Amazon Policy

Exhibit Defendant's Listing

MOTION by Defendant Wowreed for extension of time to file answer

MOTION by Defendant Wowreed for extension of time to file response/reply to Plaintiff's Motion for PI

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BlueStars

ATTORNEY Appearance for Defendant Ningbo Bichun Technology Co., Ltd by Gary Zhao

ATTORNEY Appearance for Defendant Ningbo Bichun Technology Co., Ltd by Jennifer Elizabeth Lacroix

ANSWER to amended complaint by Ningbo Bichun Technology Co., Ltd

MOTION by Defendant Ningbo Bichun Technology Co., Ltd for extension of time to file response/reply to motion for preliminary injunction

RESPONSE by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Reply in Support of Entry of a Preliminary Injunction and Response to the Motion to Modify the Asset Restraint of Defendant No. 141 "BLUESTARS LLC"

Exhibit 1

Exhibit 2

Exhibit 3

MOTION by Plaintiff Bestway Inflatables & Material Corp. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

REPLY by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Reply in Support of Entry of a Preliminary Injunction Against Defendant No. 140 "BEST CHOICE OUTDOOR"

Exhibit 1

Exhibit 2

Exhibit 3

REPLY by Defendant Sholamit Rubin to Plaintiff's response (Document No. 79) and motion to dismiss preliminary injunction remove Defendant's stores from the complaint, with Amended Affirmative Defenses following Plaintiff's submission of alleged item screenshots via email and Document no. 79. (Exhibits). (jn,)

REPLY by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Reply in Support of Entry of a Preliminary Injunction Against Defendant No. 139 "BECKACHERDIRECT"

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

REPLY by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Reply in Support of Entry of a Preliminary Injunction Against Defendant No. 179 "SLAMATE"

Exhibit 1

Exhibit 2

(Exhibit 3)

MOTION by Plaintiff Bestway Inflatables & Material Corp. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

REPLY by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Reply in Support of a Preliminary Injunction Against Defendants [Dkt. No. 76]

Exhibit 1

Exhibit 2

Exhibit 3

ATTORNEY Appearance for Defendant UniMax Direct by Adam Edward Urbanczyk

MOTION by Defendants DiMaddie, Guichaokj, PeggyDoll, UniMax Direct for extension of time UNOPPOSED

Notice of Settlement by Bestway Inflatables & Material Corp.

MINUTE entry before the Honorable Matthew F. Kennelly: This order addresses a number of pending motions. (1) Motion by DiMaddie and other defendants to set a briefing schedule [61] is moot, because the Court has set a briefing schedule on the motion for preliminary injunction. (2) Motion by defendant Wowreed for extension of time [84] is granted; response to complaint by that defendant is to be filed by 4/9/2025. This does not affect any other date or deadline set by the Court. (3) Motions by defendants Wowreed [85] and Ningbo Bichun Tech. Co. [90] for extension of time to respond to the motion for preliminary injunction are denied, because the temporary restraining order has been extended only through 3/24/2025, the defendants have not consented to a further extension, and thus the Court must decide the preliminary injunction motion by 3/24/2025. (4) Plaintiff's motions to exceed page limitations [92] [97] are granted. (5) Motion by defendants DiMaddie and 3 others for extension of time [100] is granted; responses to complaint by those defendants are to be filed by 4/18/2025. This does not affect any other date or deadline set by the Court. mk)

RESPONSE by Wowreedin Opposition to MOTION by Plaintiff Bestway Inflatables & Material Corp. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction [53]

Exhibit Wowreed Trademark

Exhibit Declaration of LuYi

Exhibit Amazon Policy

Exhibit Defendant's Listing

MOTION by Defendant Dongguan Yuanfeng Technology Co., Ltd. d/b/a BeckacherDirect for extension of time to file answer UNOPPOSED

Notice of Settlement by Bestway Inflatables & Material Corp.

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Defendant Nos. 139 BeckacherDirect and 179 Slamate

ATTORNEY Appearance for Defendant BlueStars by Shaoyi Che

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 3/24/2025. The preliminary injunction motion 53 is granted as to all defendants except for the following: BlueStars, entities controlled by Sholamit Rubin (unogoo_trade05; Usa-best-deal); Best Choice Outdoor; PeggyDoll; Guichaojk; DiMaddie; Dongguan Yuanfeng Technology Co., Ltd. d/b/a BeckacherDirect; Slamate; and Wowreed. The Court notes that some of these defendants may have already been dismissed by stipulation or voluntarily. By no later than 3/25/2025 plaintiff's counsel must notify all selling platforms in writing that the temporary restraining order has extinguished as to the entities just named even if they have been dismissed by stipulation or voluntarily. Plaintiff must file a certification on the docket regarding compliance with this direction by 3/31/2025. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add the defendant names listed in the Amended Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The parties are directed to file a joint status report with a proposed pretrial and discovery schedule by 4/22/2025. The case is set for a telephonic status hearing on 4/29/2025 at 9:10 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 3/24/2025. Mailed notice.

CERTIFICATE Certificate of Compliance

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

RESPONSE by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Response to the Counterclaim of Defendant Nos. 27 "UNOGOO TRADE05" and 28 "USA-BEST-DEAL" [Dkt. No. 64]

NEW PARTIES: Gongjiang Trading Co.Ltd, GETNOIVAS Co. Ltd, Get rich, Fule, Dengmeiqun, Daoke Technology Co., Ltd., ChampionPlus, Buy More Technology, Aimeyuan Technology Co, Ltd, Xinxiang North Filter Co., Ltd., Xinxiang Intelcontrol Filtration Equipment Co.,ltd., Tongxiang Jiacheng Environmental Protection Technology Co., Ltd., Taizhou Dibiao Technology Co., Ltd., Ningbo Bichun Technology Co., Ltd., Nanjing Blue Sky Filter Co., Ltd., Henan Clande Filter Technology Co., Ltd., Hangzhou Buda Water Processing Equipment Co., Ltd., Guangzhou Royal Sanitary Ware Co., Ltd., Guangzhou OHO Inflatables Co., Ltd., Xinchen06 Store, Warm Series Home Store Store, Shop1103808194 Store, Shop1103622146 Store, Meiya life Store, Life Three Store, JingShang Store, Isfriday Tool Store, Homewave Store, Home Preference Store, Home Life Yeah Store, Fitness Club 1 Store, Enrich Your Life Store, decor&tool supplies Store, Aquarium Spa Parts Store, zwdkjh, ZKWLXS, Zhiziwufang, Zemusinet, YUQING SHOP, Yuehuse, YIYIFELY, yanlingxianweiyihuamuyouxiangongsi, Ulovelystore, Ulimymei, Taiyuan City Xiaodian District Congman Daily Necessities Department Store, Swimming Pool Filter Element, SHUGd, Shen Zhen San Fen Mu She Ji You Xian Gong Si, Queeke-us, Prexey, OneZero Parts Store, Oceaniax, MSNECY, Moonby USA, MEIYIN, MAOSUO, Mancaogongsi, Magictown88, Lingma, Likewise, Lidoy, LHuiwed, Kaitan Liu, JMooKoo, JDNRXO-US, Ifuloves Store, huhushop, HUGUWEDING, HRUIaq, HJSIUTV, HISPAH, HeptaFiltra official store, hefengxianghuixinwujinyouxiangongsi, Hao Ba Bi, Fre.Filtor, Fahclio, dabuxing, Cxshimi, CKANDAY, chengyuwei, CHENGBEI, CALL, BeadChica LLC, yonibarak115, yoel_store45, wuaitoeng2020 and workin_38 added to case caption. (Text entry; no document attached.)

NEW PARTIES: whyl-722, usydrq-63, uk.discount7, turgmanstore, the-real-deal-usa, take_7656, sydnewline88, sport7771, sonorousstore, semayan-0, rbltobh65, rasan517145, ranasmart, popi1001, phuonnguy-46, orlya80, nsxbyg8, ningduxianwuyidianzi_0, michael_store99, mahoge_0, lsgoods8, lovestory888, linvjf, layor11, kkcartoolstore, justfo_59, just-believe01, jksy6164, homieshop, homeimprovement8, homefactoryoutlet558, hofoo816, hauseled, hardwareinstrument, goodforyou-ra, globalstorehk, girl-of-wonder, fuafr-57, foyashop, enjoybetterlife1223, edenco_1995, e-shop-e1, dreamrealize2021, cycloneboy99, cuddlylet, bestofmodern, bestforyourstore, besla66, beautymarket88, artscraftstop, arshaw6, almosthome64, 4hotseason, 1stonlineshopping, Yz Jewelry Co., Ltd., Yu Heng Heng Co.Ltd, YC motor Co. Ltd, yankemaoyi, yangquanguoushangmaoyouxiangongsi, Xiang Shenhong Store, xi ming ga wang luo, tai yuan pi de kai dian zi shang wu you xian gong si, Suyin, shannxiqinglianlan, Safini, RUDRS, QNG Electronics Co.Ltd, Qiang La Jue Co. Ltd, LTQ Vehicle Co.Ltd, LTG Toys Co.Ltd, LP Electronics Co.Ltd, leichengweishangmao, Kunjizuo Store, keshunfangshuicailiao, JJ Sport Co.Ltd, HYKHOME Store, Home-Cook Co.Ltd, High quality discount store, Grocery store, good stuff store, Good Neighbor Store, foshancomus Co.ltd, Discount department store, cleverly, Yunchin Parts Store and YouHong added to case caption. (Text entry; no document attached.)

NEW PARTIES: Xianyou County Bangtou Town Jingyue Crafts Store, WOOYOOHEY' STORE, Wanpo, WangchuanDiy, LIANGLIN WU, GuangZhouShaoHuMaoYiYouXianGongSi, Dongguanshiyufenghangzhongbiaoyouxiangongsi, CHOOFAN'S STORE, BELLEY, zhouq60, xuant_16, xiaodingdangaijitui, wordking7, whwybest, warmencounter, theolivine, supco_shop, savemoneyforyou, royer8518, ronishop-1, remedy-8, olmil7614, newshop2023, mosfet, lightluxurylife, ideal4yourdream, huahuashoping268, houselifeliving, guangxun, forevermotor, fivestarshopping, fashionrome, enthusiasmmatters, elireu26, ebestfuljoy, dressingleader, dacaizhu14, comfortableforyou, bloomfyyear, biautoshows and bad-8599 added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendants Fahclio, Prexey, Yuehuse, chengyuwei, huhushop by Timothy Tiewei Wang

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

CERTIFICATE of Service by William Benjamin Kalbac on behalf of Bestway Inflatables & Material Corp.

MOTION by Plaintiff Bestway Inflatables & Material Corp. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bestway Inflatables & Material Corp. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

MEMORANDUM by Bestway Inflatables & Material Corp. in support of motion for default judgment[121]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit A

DECLARATION of Michael A. Hierl regarding motion for default judgment[121]

Exhibit Hierl Exhibit 1

MOTION by Defendants Fahclio, Prexey, Yuehuse, chengyuwei, huhushop for extension of time to file answer regarding complaint[1] Unopposed

ATTORNEY Appearance for Defendants Dongguanshiyufenghangzhongbiaoyouxiangongsi, HRUIaq, JMooKoo, LHuiwed, LIANGLIN WU, MEIYIN, Mancaogongsi, SHUGd, WangchuanDiy, Wanpo, YouHong, ZKWLXS, Zemusinet, hefengxianghuixinwujinyouxiangongsi by Yong Chen

MOTION by Defendants Dongguanshiyufenghangzhongbiaoyouxiangongsi, HRUIaq, JMooKoo, LHuiwed, LIANGLIN WU, MEIYIN, Mancaogongsi, SHUGd, WangchuanDiy, Wanpo, YouHong, ZKWLXS, Zemusinet, hefengxianghuixinwujinyouxiangongsi for extension of time to file answer regarding complaint[1], CONSENTED

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file excess pages [120] is granted. Various defendants' motions for extension of time [124] is granted; those defendants' responses to the complaint are to be filed by 4/24/2025.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default judgment as to certain defendants [121] is denied, without prejudice to renewal, because the motion and proposed order include defendants who have been given an extension of time to respond to the complaint.

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

CERTIFICATE of Service by William Benjamin Kalbac on behalf of Bestway Inflatables & Material Corp.

MOTION by Plaintiff Bestway Inflatables & Material Corp. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bestway Inflatables & Material Corp. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

Exhibit A

MEMORANDUM by Bestway Inflatables & Material Corp. in support of motion for default judgment, [132]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit Figueroa Exhibit A

DECLARATION of Michael A. Hierl regarding motion for default judgment, [132]

Exhibit Hierl Exhibit 1

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file excess pages [131] is granted. Plaintiff's motion for entry of default judgment as to certain defendants [132] is set for a telephonic hearing on 4/29/2025 at 9:10 AM, using call-in number 650-479-3207, access code 2305-915-8729.

ATTORNEY Appearance for Defendant HeptaFiltra official store by Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by HeptaFiltra official store

STIPULATION of Dismissal Stipulation of Voluntary Dismissal with Prejudice

STATUS Report Joint Status Report by Bestway Inflatables & Material Corp.

MOTION by Defendant HeptaFiltra official store for extension of time to file answer

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendant HeptaFiltra official store for extension of time [140] is granted; response to complaint is to be filed by 5/11/2025.

MINUTE entry before the Honorable Matthew F. Kennelly: At a telephonic hearing this morning, the Court orally granted plaintiff's motion for entry of default judgment [132] but said that it would reduce the requested amount significantly given the points discussed during the hearing. The Court did not fully appreciate at that time the breadth of the proposed default judgment order submitted by plaintiff. Among other things it purports to permanently shut down the Amazon (etc.) accounts of the defendants, and it imposes very broad injunctive relief upon the defendants. The Court is not persuaded that the latter is appropriate given the very narrow and focused nature of the claimed "false designation of origin" as described by plaintiff's counsel during this morning's hearing, and the former is likely overbroad as well. The Court needs to address these points further with plaintiff and therefore sets the matter for a further telephonic hearing on for 5/5/2025 at 8:55 AM, using call-in number 650-479-3207, access code 2305-915-8729.

MINUTE entry before the Honorable Matthew F. Kennelly: Telephone conference held on 4/29/2025.

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic motion hearing held on 5/5/2025. Plaintiff's counsel is directed to send a revised default judgment order to Judge Kennelly's proposed order email address. Mailed notice.

DEFAULT JUDGMENT ORDER AS TO CERTAIN DEFENDANTS, signed by the Honorable Matthew F. Kennelly on 5/8/2025. Motion for entry of default judgment is granted. Plaintiff is directed to file a status report on 5/12/2025 identifying which, if any, defendants remain in the case and the status of proceedings or discussions as to each such defendant.

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 152

STATUS Report Joint Status Report by Bestway Inflatables & Material Corp.

MINUTE entry before the Honorable Matthew F. Kennelly: The Court has reviewed plaintiff's status report. The case is set for a telephonic status hearing on 6/17/2025 at 8:55 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. A joint status report is to be filed on 6/10/2025.

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

SATISFACTION of Judgment

ANSWER to amended complaint by Wowreed

NOTICE of Voluntary Dismissal by Bestway Inflatables & Material Corp. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Wowreed (OPPOSED)

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Declaration

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Exhibit

MINUTE entry before the Honorable Matthew F. Kennelly: Response to defendant Wowreed's motion to dismiss is to be filed on 6/19/2025; reply by Wowreed is to be filed by 6/26/2025. The telephonic status hearing set for 6/17/2025 is vacated and reset to 6/30/2025 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file on 6/23/2025 a status report identifying any and all remaining defendants in the case and the status of proceedings on each.

STATUS Report Joint Status Report by Bestway Inflatables & Material Corp.

SATISFACTION of Judgment

RESPONSE by Plaintiff Bestway Inflatables & Material Corp. Plaintiff's Response to Motion to Dismiss Defendant No. 186 "Wowreed" [Dkt. No. 155]

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Exhibit 2

Exhibit 3

Exhibit 4

STATUS Report by Bestway Inflatables & Material Corp.

REPLY by Wowreed to Response, [159]

Exhibit Wowreed Trademark Registration

Exhibit Amazon Policies

MINUTE entry before the Honorable Matthew F. Kennelly: At the Court's instance, the telephonic status hearing set for 6/30/2025 is vacated and reset to 7/2/2025 at 8:50 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MINUTE entry before the Honorable Matthew F. Kennelly: Telephonic status hearing held on 7/2/2025. Defendant Wowreed's motion to dismiss [155] is granted. Plaintiff has until 7/16/2025 to file an amended complaint against defendant Wowreed. The case is set for a telephonic status hearing on 7/23/2025 at 9:05 a.m. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff did not file a proposed amended complaint against defendant Wowreed by the 7/16/2025 deadline. Plaintiff is directed to file a status report on 7/21/2025 regarding how (if at all) it intends to proceed with respect to Wowreed, the last remaining defendant in the case.

STATUS Report by Bestway Inflatables & Material Corp.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff has filed a status report stating that it does not intend to pursue its claims against the last remaining defendant in this case (Wowreed). The Clerk is directed to close the case and vacate any dates and deadlines. Civil case terminated. Mailed notice.

SATISFACTION of Judgment