2025-cv-02312

CIVIL COVER SHEET by Plaintiff Potato Ventures LLC.

Redacted Appendix Schedule A

(Exhibit Poplin declaration)

Declaration of Tingting Ni Iso

Supplemental Declaration of Fei Jiang Iso

Exhibit 1

Second Supplemental Declaration of Fei Jiang Iso

COMPLAINT with trial location of Kansas City (Filing fee $405, Internet Payment Receipt Number AKSDC-6683012.), filed by Potato Ventures LLC.

Redacted Appendix Schedule A-1

Exhibit 1 - Shunfeida Design File

Exhibit 8 - Elaine WeChat Screenshots - translation

Exhibit 2

Exhibit 13 - Screenshot Metadata w translation

Schedule A re 2 Complaint by Plaintiff Potato Ventures LLC. Modified on 7/9/2025 to unseal and remove "provisional sealed" language per 30 Order

Redacted Appendix Schedule A-2

Exhibit 2 - Xumiao 1688 Purchase

Exhibit 9 - Vola WeChat Screenshots - translation

Exhibit 3

Exhibit 14 - Zeyu 1688 Listing

Schedule A-1 re 2 Complaint by Plaintiff Potato Ventures LLC. Modified on 7/9/2025 to unseal and remove "provisional sealed" language per 30 Order

(Exhibit 1)

Declaration of Fei Jiang Iso

Declaration of Yong Zeng Iso

Exhibit 4

Exhibit 15 - Vola sales agmt w translation

Schedule A-2 re 2 Complaint by Plaintiff Potato Ventures LLC. Modified on 7/9/2025 to unseal and remove "provisional sealed" language per 30 Order

Exhibit 3 - Zeyu to Aonig1688 Purchase

Exhibit 10 - AI Design Files

Exhibit 5

Exhibit 16 - Vola sales payment record w translation

MOTION for Leave to File Provisionally Sealed Documents Without Notice to Other Parties (Docs. 3 - 5) by Plaintiff Potato Ventures LLC.

Exhibit 4 - Product Images

Exhibit 11 - Accused Product Measurement

Exhibit 6

First Supplemental Declaration of Shruti Aggarwal Iso

AO FORM 120: REPORT on the Filing or Determination of an Action Regarding a Patent or Trademark.

Declaration of Shruti Aggarwal Iso

Exhibit 12 - SKU Economics

Exhibit 7

Exhibit 17 - Brilliance _ Profile _ Fiverr

CORPORATE DISCLOSURE STATEMENT by Potato Ventures LLC identifying None as corporate parent.

Exhibit 5 - D816 Patent

Exhibit 8

Exhibit 18 - Two Women Shutterstock

MOTION for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) by Plaintiff Potato Ventures LLC.

Exhibit 6 - Amazon Product Listing - BNYD

(Affidavit Husseini Declaration)

Exhibit 19 - Steak Shutterstock

MOTION for Temporary Restraining Order and Expedited Discovery by Plaintiff Potato Ventures LLC.

(Exhibit 7 - Amazon Product Listing - BNYD Reviews 2019)

Exhibit 20 - AboutMe Photography Profile

MEMORANDUM IN SUPPORT of 10 Motion for Temporary Restraining Order and Expedited Discovery by Plaintiff Potato Ventures LLC.

Exhibit 21 - Fiverr Webpage

NOTICE OF PROPOSED SEALED RECORD by Potato Ventures LLC re 3 - 5.

Exhibit 22 - Alibaba - Cute Glass Spice Shaker - Print

NOTICE OF JUDGE ASSIGNMENT: Case assigned to District Judge Daniel D. Crabtree and Magistrate Judge Rachel E. Schwartz for all proceedings. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) NOTICE OF MAGISTRATE JUDGE AVAILABILITY: A United States magistrate judge is available to conduct all proceedings in this civil action if all parties voluntarily consent. Information & consent forms are available at https://www.uscourts.gov/file/459/download (Text entry; no document attached.)

MOTION REFERRAL to Magistrate Judge REMOVED as to 6 Motion for Leave to File Provisionally Sealed Documents Without Notice to Other Parties (Docs. 3 - 5). The motion will be resolved by the District Judge. (Text entry; no document attached.)

MOTION REFERRAL to Magistrate Judge REMOVED as to: 22 MOTION to Seal or Redact Document(s) 21 Temporary Restraining Order. The motion will be resolved by the District Judge. (Text entry; no document attached.)

SUMMONS ISSUED as to Partnerships and Unincorporated Associations Identified on Schedule A, The. (issued to Attorney for service) Notice, Consent, and Reference of a Civil Action to a Magistrate Judge Form provided to counsel for service with complaint. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.) (Text entry; no document attached.)

MEMORANDUM AND ORDER. Plaintiff's Motion for Temporary Restraining Order (Doc. 10) is granted in part and denied in part. The portion of the motion requesting expedited discovery is referred to Magistrate Judge Schwartz and remains pending. Signed by District Judge Daniel D. Crabtree on 6/16/2025.

ORDER denying without prejudice 9 Motion for Service. Signed by Magistrate Judge Rachel E. Schwartz on 6/17/2025.

ORDER denying without prejudice 10 Motion to Expedite Discovery. Signed by Magistrate Judge Rachel E. Schwartz on 6/17/2025.

RENEWED MOTION for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) by Plaintiff Potato Ventures LLC. (Motion referred to Magistrate Judge Rachel E. Schwartz.)

RENEWED MOTION for Expedited Discovery by Plaintiff Potato Ventures LLC. (Motion referred to Magistrate Judge Rachel E. Schwartz.)

CASH BOND in the amount of $15,000.00 posted by Potato Ventures LLC. (receipt #200002186)

ORDER granting 16 Renewed Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3). This order does not apply to Defendants in jurisdictions other than China, and nothing in this order prevents any Defendant from challenging service. Signed by Magistrate Judge Rachel E. Schwartz on 6/20/2025.

ORDER granting in part and denying in part 17 Renewed Motion for Expedited Discovery. Signed by Magistrate Judge Rachel E. Schwartz on 6/20/2025.

TEMPORARY RESTRAINING ORDER. Signed by District Judge Daniel D. Crabtree on 6/20/2025.

MOTION to Seal or Redact Document(s) 21 Temporary Restraining Order by Plaintiff Potato Ventures LLC.

ORDER denying plaintiff's Motion to Seal (Doc. 22). On June 20, 2025, the court issued a Temporary Restraining Order (Doc. 21) without notice, enjoining defendants from certain conduct involving products that allegedly infringe plaintiff's patent. Shortly thereafter, plaintiff asked the court to seal its Temporary Restraining Order, concluding it's "necessary to prevent Defendants from learning of this Order prior to the implementation of the temporary restraining order." Doc. 22 at 1. The Temporary Restraining Order became effective when it issued on June 20, 2025. See Doc. 21 at 2. And plaintiff asks the court to prevent defendants' access to a Temporary Restraining Order that binds them. That request just won't tote. And it certainly can't conclude this request overcomes the presumption of public access to court documents and decisions. The court thus denies the motion (Doc. 22). Signed by District Judge Daniel D. Crabtree on 06/20/2025. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)

NOTICE OF VOLUNTARY DISMISSAL by Potato Ventures LLC regarding Defendants 9, 10, 11, 12, and 13

MOTION for extension of time of Temporary Restraining Order by Plaintiff Potato Ventures LLC Modified motion event on 7/1/2025

MEMORANDUM IN SUPPORT of 25 MOTION for Temporary Restraining Order extension by Plaintiff Potato Ventures LLC

MEMORANDUM AND ORDER. Plaintiff's Motion to Extend Temporary Restraining Order (Doc. 25) is granted. The court's Temporary Restraining Order (Doc. 21) is extended for a period of 14 additional days. Signed by District Judge Daniel D. Crabtree on 7/2/2025.

ENTRY OF APPEARANCE by Wangxue Deng on behalf of Potato Ventures LLC

SUMMONS RETURNED EXECUTED -- alternative service by Potato Ventures LLC upon Partnerships and Unincorporated Associations Identified on Schedule A, The served on 7/8/2025, answer due 7/29/2025

ORDER denying as moot plaintiff's Motion for Leave to File Provisionally Sealed Documents without Notice to Other Parties (Doc. 6). At the time of filing this motion, plaintiff also had a motion for an ex parte temporary restraining order pending. See Doc. 10; Doc. 21 (granting TRO). Under D. Kan. Rule 5.4.2(a)(ii), a party may move the court to order that service of provisionally sealed documents isn't required, contrary to our court's general sealing practice. Concerned that defendants would destroy relevant evidence or improperly transfer assets before a TRO could issue, plaintiff asked the court for such an order. Doc. 6 at 1-2 (concerning three unredacted attachments to Complaint, Docs. 3-5 on CM/ECF). But on July 8, 2025, plaintiff served the provisionally sealed documents on defendants. See Doc. 29 at 1 (designating service of Docs. 3-5, among other docket entries, on all remaining defendants). So, plaintiff's Motion for Leave to File Provisionally Sealed Documents without Notice to Other Parties (Doc. 6) is now moot. And so the court denies the motion for that reason. But there's one more item of business for Docs. 3-5. Plaintiff didn't move the court to seal or redact the three provisionally sealed documents within 7 days, as our rule requires. See D. Kan. Rule 5.4.2(c) ("A Proponent that seeks to maintain any portion of the document under seal, or to allow the document to be filed in the public record with redactions, must file a motion to seal or redact. within 7 days after the document is filed provisionally under seal[.]"). And in plaintiff's Notice of Proposed Sealed Record (Doc. 12), it suggested it would move to unseal the documents after the TRO was served on defendants. Doc. 12 at 2. When a proponent "does not timely file a motion to seal or redact" under subsection (c), it "waives its right to maintain that the filing contains confidential information." D. Kan. Rule 5.4.2(d). Plaintiff hasn't so moved. The court thus directs the Clerk of the Court to remove the provisional designation from the following filings, and unseal them, leaving them publicly available on the docket: Doc. 3; Doc. 4; Doc. 5. Signed by District Judge Daniel D. Crabtree on 07/09/2025. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)

NOTICE OF VOLUNTARY DISMISSAL by Potato Ventures LLC regarding Defendant 1

MOTION for Preliminary Injunction by Plaintiff Potato Ventures LLC

CERTIFICATE OF SERVICE of ECF No. 32 by Potato Ventures LLC re 32 MOTION for Preliminary Injunction.

MEMORANDUM AND ORDER ENTERED: Plaintiff's Motion to Convert the Temporary Restraining Order to Preliminary Injunction (Doc. 32) is granted in part--just to the extent it asks the court to extend the TRO. The portion of the motion seeking a preliminary injunction remains pending. The Temporary Restraining Order (Doc. 21) is extended until the court rules the portion of plaintiff's motion seeking a preliminary injunction. A Preliminary Injunction Hearing is set for 7/23/2025 at 09:30 AM in KC Courtroom 476 (DDC) before District Judge Daniel D. Crabtree. Plaintiff must serve this Order on defendants. Defendants may respond to the pending Motion to Convert the Temporary Restraining Order to Preliminary Injunction (Doc. 32) by July 18, 2025. The court will not entertain a written reply from plaintiff but will hear arguments at the preliminary injunction hearing. Signed by District Judge Daniel D. Crabtree on 7/15/2025.

CERTIFICATE OF SERVICE of ECF No. 34 by Potato Ventures LLC re 34 Order on Motion for Extension of Time

ENTRY OF APPEARANCE by Hissan Anis on behalf of Potato Ventures LLC.

ENTRY OF APPEARANCE by Scott R. Brown on behalf of SZSPKL (Amazon Merchant ID AW69TNG18L5OM)

Unopposed MOTION for Extension of Time to File Answer re 2 Complaint (attorney), by Defendant SZSPKL (Amazon Merchant ID AW69TNG18L5OM) (referred to Magistrate Judge Rachel E. Schwartz)

ORDER granting 38 Defendant SZSPKL's Unopposed Motion for Extension of Time to Respond to the Complaint. The Court grants the Motion as unopposed and for good cause shown and extends the deadline up to and including September 12, 2025, for Defendant SZSPKL to respond to the Complaint. Signed by Magistrate Judge Rachel E. Schwartz on 7/16/2025. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)

MEMORANDUM IN OPPOSITION by Defendant SZSPKL (Amazon Merchant ID AW69TNG18L5OM) re 32 MOTION for Preliminary Injunction MOTION for extension of time

NOTICE OF VOLUNTARY DISMISSAL by Potato Ventures LLC regarding Defendant 5

MINUTE ENTRY for proceedings held before District Judge Daniel D. Crabtree: PRELIMINARY INJUNCTION HEARING held on 7/23/2025 re [32] Motion for Preliminary Injunction. (Court Reporter Kim Greiner.)

SUPPLEMENT to [40] Memorandum in Opposition to Motion, by Defendant SZSPKL (Amazon Merchant ID AW69TNG18L5OM).

ORDER granting plaintiff Potato Ventures LLC's informal Motion for Extension of Time and dissolving Temporary Restraining Order (Doc. 21). On July 29, 2025, plaintiff emailed chambers, informally requesting a 1.5-day extension to file a supplemental brief in support of its Motion for Preliminary Injunction (Doc. 32). Plaintiff, writing to support a request for extension, asserted that defendant SZSPKL's supplemental brief (Doc. 40) includes forged evidence. Plaintiff seeks to extend its deadline so it can compile evidence supporting this notion. Defendant SZSPKL opposes the informal motion. Although plaintiff's email motion does not comply with D. Kan. Rule 6.1(a), the court grants the motion. Plaintiff's deadline to file their supplemental brief is July 30, 2025. But the court doesn't grant the extension without consequence. The court had already extended the TRO for good cause once under Fed. R. Civ. P. 65(b)(2). See Doc. 27 at 2-3. And at plaintiff's request, the court further extended the TRO until the court could rule plaintiff's preliminary injunction motion. See Doc. 34 at 1-2 (extending TRO but effectively converting TRO to appealable preliminary injunction). The court then convened a preliminary injunction hearing where plaintiff and defendant SZSPKL requested an opportunity to provide more briefing. The court permitted supplemental briefs but emphasized the importance of a short briefing schedule. After all, important interests remain restricted as long as the TRO is in effect. Plaintiff's request to extend the briefing schedule--and potentially open the door to a subsequent response from defendants--has shifted the balance of the equities. The current record reveals a dispute about the patent's validity. And plaintiff's extension motion prolongs--potentially at length--the TRO's restrictions. So, the court grants plaintiff the requested extension but now dissolves the Temporary Restraining Order (Doc. 21). This decision to vacate the TRO does not predict or prejudice the outcome of the Motion for Preliminary Injunction (Doc. 32). It also doesn't resolve the parties' dispute about whether another evidentiary hearing is warranted. Signed by District Judge Daniel D. Crabtree on 07/29/2025. (This is a TEXT ENTRY ONLY. There is no.pdf document associated with this entry.)

MEMORANDUM IN SUPPORT of 32 MOTION for Preliminary Injunction; MOTION for extension of time by Plaintiff Potato Ventures LLC

INITIAL ORDER REGARDING PLANNING AND SCHEDULING: Scheduling Conference set for September 30, 2025, at 3:00 p.m. by telephone (CONFERENCE LINE 785-337-8299; CONFERENCE ID 673 598 390) before Magistrate Judge Rachel E. Schwartz. Rule 26 Planning Conference Deadline 9/9/2025. Rule 26 Initial Disclosures Deadline set for 9/19/2025. Proposed Scheduling Order Deadline 9/19/2025. Signed by Magistrate Judge Rachel E. Schwartz on August 1, 2025.

SUPPLEMENT to [40] Memorandum in Opposition to Motion, by Defendant SZSPKL (Amazon Merchant ID AW69TNG18L5OM).

ENTRY OF APPEARANCE by Joseph P. Hooper on behalf of Potato Ventures LLC.

MEMORANDUM AND ORDER denying [32] Motion for Preliminary Injunction. Signed by District Judge Daniel D. Crabtree on August 7, 2025.