Safety Nailer LLC v. THE INDIVIDUALS, PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, No. 1:2021cv22703 - Document 41 (S.D. Fla. 2021)
Court Description: ORDER granting 19 Motion for Preliminary Injunction. Signed by Judge Beth Bloom on 9/21/2021. See attached document for full details. (kpe)
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Safety Nailer LLC v. THE INDIVIDUALS, PARTNERSHIPS AND UNINCORPORATED ASS...IDENTIFIED ON SCHEDULE A Doc. 41 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 21-cv-22703-BLOOM/Otazo-Reyes SAFETY NAILER LLC, Plaintiff, v. THE INDIVIDUALS, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE “A,” Defendants. _______________________________________/ ORDER GRANTING MOTION FOR PRELIMINARY INJUNCTION THIS CAUSE is before the Court on Plaintiff’s Motion for Preliminary Injunction, ECF No. [19], filed under 15 U.S.C. § 1116, Federal Rule of Civil Procedure 65, and The All Writs Act, 28 U.S.C. § 1651(a), by Plaintiff, SAFETY NAILER, LLC (“SNLLC”). The Court has considered the Motion, the record in the case, arguments raised at the hearing, and is otherwise fully advised. On August 23, 2021 the Court entered a Temporary Restraining Order and an Order Restraining the Financial Accounts used by Defendants (the “TRO”), ECF No. [22]. The TRO set a hearing on the Plaintiff’s Motion for Preliminary Injunction for September 1, 2021. Plaintiff moved twice, see ECF Nos. [23], [28], to extend the TRO which the Court granted. ECF Nos. [24], [30]. The hearing on the Motion for Preliminary Injunction was ultimately set for September 17, 2021. Prior to the hearing on the Motion for Preliminary Injunction, Plaintiff filed Proofs of Service, ECF Nos. [35], [37] on the Defendants pursuant to the Court’s Order Authorizing Alternate Service of Process. ECF No. [16]. The Plaintiff’s proofs of service affirmed that the 1 Dockets.Justia.com Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 2 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Plaintiff served process on the Defendants identified on Schedule A by emailing those Defendants the text of the summons issued in this action and the link, http://www.sriplaw.com/notice, where the full text of the Complaint, exhibits thereto, Temporary Restraining Order, and the full text of all other documents filed in this action are available to view and download in compliance with this Court’s Order on Alternate Service, with the exception of Defendants numbered 193, 194, 195, 196, 197, and 198. At the hearing, the Court inquired whether service had been made on all Defendants, and the Plaintiff confirmed that service was made on all Defendants except the Defendants on Schedule A to the Complaint numbered (Doc. 1). Plaintiff requested that the TRO be extended as to those Defendants on which service had not yet been made. The Court found that good cause was not shown for the extension of the TRO on those Defendants and denied Plaintiff’s ore tenus motion. The Court heard argument from Plaintiff and reviewed the evidence presented to the Court on the Motion. Having considered the evidence and the arguments, the Court grants Plaintiff’s Motion for Entry of a Preliminary Injunction in its entirety against the Defendants identified in Schedule A hereto, which does not include the Defendants numbered 193, 194, 195, 196, 197, and 198 on whom service has not been made, and the TRO is dissolved as to Defendants numbered 193, 194, 195, 196, 197, and 198. The Court determines that it has personal jurisdiction over the Defendants identified on Schedule A hereto since the evidence presented on the motion shows that the Defendants (except those indicated above on whom service was not made) have been served with process pursuant to this Court’s order authorizing alternative service. The Court also determines that the evidence supports a finding that these Defendants directly target their business activities toward consumers in the United States, including Florida, and specifically that the Defendants are reaching out to do 2 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 3 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes business with Florida residents by operating one or more commercial, interactive internet stores on internet marketplaces where Florida residents can purchase products bearing infringing and/or counterfeit trademarks belonging to the Plaintiff. The Court also determines that the Defendants are selling or offering to sell products to consumers in the U.S. using copyright protected product photographs belonging to Plaintiff and are offering to sell and selling products that infringe one or more U.S. patents belonging to Plaintiff. This Court further determines that the temporary restraints previously granted in the TRO should remain in place through the pendency of this litigation and that issuing this Preliminary Injunction is warranted under Federal Rule of Civil Procedure 65. Evidence submitted in support of this Motion and in support of Plaintiff’s previously granted Motion for a Temporary Restraining Order establishes that Plaintiff has a likelihood of success on the merits; that no remedy at law exists; and that plaintiff will suffer irreparable harm if the injunction is not granted. The Court concludes that Plaintiff has a strong probability of proving at trial that consumers are likely to be confused by defendants’ advertisement, promotion, sale, offer for sale, or distribution of goods bearing counterfeits, reproductions, or colorable imitations of the products using the SAFETY NAILER Mark, U.S. Reg. No. 5,544,356 for “Hand tools, namely, clamps” in International Class 8 registered August 21, 2018; the Plaintiff’s copyrighted photographs registered with the Register of Copyrights on May 25, 2021 and assigned the registration numbers VA 2-252-882 and VA 2-252-876; U.S. Patent No. US 8,806,983 (the ‘983 Patent). The Court concludes that the products Defendants are selling and promoting for sale are copies of Plaintiff’s products that bear copies of the SAFETY NAILER Mark, the Plaintiff’s copyrighted photographs, and the ‘983 Patent, and that the infringement of the SAFETY NAILER 3 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 4 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Mark, the Plaintiff’s copyrighted photographs, and the ‘983 Patent, will likely cause Plaintiff to suffer immediate and irreparable injury if a preliminary injunction is not granted. The potential harm to defendants in restraining their trade in counterfeit and infringing branded goods if a preliminary injunction is issued is far outweighed by the potential harm to Plaintiff, its reputation, and its goodwill as a manufacturer and distributor of quality products, if such relief is not issued. The public interest favors issuance of the temporary restraining order to protect Plaintiff’s trademark interests and protect the public from being defrauded by palming off counterfeit goods as plaintiff’s genuine goods. Under 15 U.S.C. § 1117(a), Plaintiff may be entitled to recover, as an equitable remedy, the illegal profits gained through Defendants’ distribution and sales of goods bearing counterfeits and infringements of plaintiff’s trademarks. See Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d 982, 987 (11th Cir. 1995); Reebok Int’l, Ltd. v. Marnatech Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992). The Copyright Act also permits the recovery of Defendants’ profits. See 17 U.S.C. § 504. Furthermore, both the Copyright Act and the Patent Act permits the entry of an injunction to restrain violations of those acts, 17 U.S.C. § 502, 35 U.S.C. § 283, and the Copyright Act authorizes an order impounding infringing goods and articles. 17 U.S.C. §503. Plaintiff has demonstrated that it is entitled to recover, as an equitable remedy, an injunction as a result of the infringement of Plaintiff’s patent by Defendants, inasmuch as Plaintiff has demonstrated that Plaintiff has and will continue to suffer price erosion as a result of Defendants’ infringement because defendants sell their products that infringe Plaintiff’s intellectual property rights for much less than Plaintiff, Plaintiff has been forced to lower its prices as a result of the infringement, the Defendants continued infringement prevent and frustrate 4 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 5 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes plaintiff’s ability to sell its authentic products, and Plaintiff has been unable to restore the higher price point before it was able to sell at prior to the infringements and counterfeiting by Defendants. In light of the inherently deceptive nature of the counterfeiting business, and the likelihood that defendants have violated federal trademark laws, Plaintiff has good reason to believe Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction of this Court unless the restraint of those assets ordered in the TRO is continued. Accordingly, the Court, it is ORDERED AND ADJUDGED that the Motion, ECF No. [19], is GRANTED and a preliminary injunction is entered as follows: PRELIMINARY INJUNCTION Each Defendant listed on Schedule A attached hereto, its officers, directors, employees, agents, subsidiaries, distributors, and all persons in active concert or participation with any defendant having notice of this Order are hereby restrained and enjoined during the pendency of this case: a. From manufacturing, importing, advertising, promoting, offering to sell, selling, distributing, or transferring any products bearing the SAFETY NAILER Mark, or any confusingly similar trademarks, other than those actually manufactured or distributed by plaintiff; and b. From secreting, concealing, destroying, selling off, transferring, or otherwise disposing of: (i) any products, not manufactured or distributed by plaintiff, bearing and/or using the SAFETY NAILER Mark, or any confusingly similar trademarks; or (ii) any evidence relating to the manufacture, importation, sale, offer for sale, distribution, or transfer of any products bearing and/or using the SAFETY NAILER Mark, or any confusingly similar trademarks; or (iii) any assets or other financial accounts subject 5 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 6 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes to this Order, including inventory assets, in the actual or constructive possession of, or owned, controlled, or held by, or subject to access by, any Defendant, including, but not limited to, any assets held by or on behalf of any Defendant; c. From copying, displaying, distributing or creating derivative works of Plaintiff’s copyrighted photographs; and d. From making, using, selling, importing and/or offering to sell products that practice the ‘983 Patent. Each Defendant, its officers, directors, employees, agents, subsidiaries, distributors, and all persons in active concert or participation with any Defendant having notice of this Preliminary Injunction shall immediately discontinue, until further Order of this Court, the use of the SAFETY NAILER Mark, or any confusingly similar trademarks, or the Plaintiff’s copyrighted photographs, and the ‘983 Patent, on or in connection with all Internet based ecommerce stores owned and operated, or controlled by them, including the Internet based ecommerce stores operating under the Seller IDs. This order is limited to the Defendants’ listings using the SAFETY NAILER Mark, or any confusingly similar trademarks, or the Plaintiff’s copyrighted photographs, and the ‘983 Patent, on or in connection with all Internet based ecommerce stores owned and operated, or controlled by them, including the Internet based ecommerce stores operating under the Seller IDs, and does not apply to the Defendants’ entire ecommerce stores. Each Defendant, its officers, directors, employees, agents, subsidiaries, distributors, and all persons in active concert or participation with any Defendant having notice of this Preliminary Injunction shall immediately discontinue, until further Order of this Court, the use of the SAFETY NAILER Mark, or any confusingly similar trademarks, within domain name 6 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 7 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes extensions, metatags or other markers within website source code, from use on any webpage (including as the title of any web page), from any advertising links to other websites, from search engines’ databases or cache memory, and any other form of use of such terms that are visible to a computer user or serves to direct computer searches to Internet based e-commerce stores registered, owned, or operated by any Defendant, including the Internet based e-commerce stores operating under the Seller IDs. Each Defendant shall not transfer ownership of the Seller IDs during the pendency of this action, or until further order of the Court. Each Defendant shall continue to preserve copies of all computer files relating to the use of any of the Seller IDs and shall take all steps necessary to retrieve computer files relating to the use of the Seller IDs that may have been deleted before the entry of this Order. Defendants and all financial institutions, payment processors, banks, escrow services, money transmitters, or marketplace platforms, including but not limited to, Alibaba.com Hong Kong Limited, which operates the AliExpress.com platform (“AliExpress”), Zhejiang Ant Small and Micro Financial Services Group Co., Ltd. (“Ant Financial Services”), AliPay (China) Internet Technology Co. Ltd., Alipay.com Co., Ltd., and Alipay Singapore E-Commerce Private Limited (collectively, “Alipay”), Amazon Payments, Inc. (“Amazon”), Dunhuang Group which operates the DHgate.com and DHPay.com platforms, Camel FinTech Inc, ContextLogic, Inc., which operates the Wish.com website (“ContextLogic”), PayPal, Inc. (“PayPal”), eBay, Inc. (“eBay”), Payoneer, Inc. (“Payoneer”), NewEgg Commerce, Inc. (“NewEgg”), WorldFirst UK Limited (“WorldFirst”), or PingPong Global Solutions Inc. (“PingPong”), Joom, SIA (Latvia) (“Joom”), Stripe, Inc. and/or Stripe Payments Company (“Stripe”) and their related companies and affiliates shall continue the restraints imposed under the TRO until further Order of this Court and, 7 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 8 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes to the extent not already done, (i) restrain the transfer of all funds, as opposed to ongoing account activity, held or received for their benefit or to be transferred into their respective financial accounts, and any other financial accounts tied thereto; (ii) divert those restrained funds to a holding account for the trust of the Court.; (iii) identify all financial accounts and/or sub-accounts, associated with the Internet based e-commerce stores operating under the Seller IDs, store numbers, infringing product numbers, and/or the e-mail addresses identified on Schedule “A” hereto, as well as any other accounts of the same customer(s); (iv) identify all other accounts which transfer funds into the same financial institution account(s) or any of the other financial accounts subject to this Order; Upon receipt of notice of this Preliminary Injunction, Defendants and all financial institutions, payment processors, banks, escrow services, money transmitters, or marketplace platforms receiving notice of this Order, including but not limited to, AliExpress, Ant Financial Services, Alipay, Amazon, Dunhuang Group which operates the DHgate.com and DHpay.com platforms, Camel FinTech Inc, ContextLogic, PayPal, eBay, Payoneer, NewEgg WorldFirst, PingPong, Joom, Stripe, and their related companies and affiliates, shall to the extent not already done, provide plaintiff’s counsel with all data that details: (i) an accounting of the total funds restrained and identify the financial account(s) and sub-account(s) which the restrained funds are related to; (ii) the account transactions related to all funds transmitted into the financial account(s) and sub-account(s) which have been restrained; (iii) the historical sales for the defendants’ listings that are alleged to infringe plaintiff’s trademarks, copyrights and patent; and (iv) the true identities along with complete contact information including email addresses of all Defendants. The funds restrained by this Preliminary Injunction shall not be transferred or surrendered by any Defendant, financial institution, payment processor, bank, escrow service, 8 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 9 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes money transmitter, or marketplace website, including but not limited to, AliExpress, Ant Financial Services, Alipay, Amazon, Dunhuang Group which operates the DHgate.com and DHpay.com platforms, Camel FinTech Inc, ContextLogic, PayPal, eBay, Payoneer, NewEgg WorldFirst, PingPong, Joom, Stripe, and their related companies and affiliates for any purpose (other than pursuant to a chargeback made pursuant to their security interest in the funds) without the express authorization of this Court. No Defendant whose funds are restrained by this Preliminary Injunction may transfer said funds in possession of any financial institution, payment processor, bank, escrow service, money transmitter, or marketplace website, including but not limited to, AliExpress, Ant Financial Services, Alipay, Amazon, Dunhuang Group which operates the DHgate.com and DHpay.com platforms, Camel FinTech Inc, ContextLogic, PayPal, eBay, Payoneer, NewEgg WorldFirst, PingPong, Joom, Stripe, and their related companies and affiliates restrained by this Order to any other financial institution, payment processor, bank, escrow service, money transmitter or marketplace website without the express authorization of this Court. Any Defendant or financial institution account holder subject to this Preliminary Injunction may petition the Court to modify the asset restraint set out in this Order. This Order shall apply only to the Seller IDs listed on Schedule A hereto, associated e-commerce stores and websites, and any other seller identification names, e-commerce stores, websites, or financial accounts which are being used by Defendants for the purpose of counterfeiting the SAFETY NAILER Mark and/or unfairly competing with Plaintiff and/or copying the Plaintiff’s copyrighted photographs and/or infringing the Plaintiff’s ‘983 Patent. This Preliminary Injunction shall remain in effect during the pendency of this case and until further Order of the Court. Any Defendants that are subject to this Order may appear and 9 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 10 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes move to dissolve or modify the Preliminary Injunction upon notice to Plaintiff pursuant to the Federal Rules of Civil Procedure and Local Rules of the Southern District of Florida. BOND The Court determines that the bond in the amount of Ten Thousand Dollars and Zero Cents ($10,000.00) posted by Plaintiff as evidenced by the Notice of Filing Bond, ECF No. [33-], is sufficient and shall remain with the Court until a final disposition or until this Preliminary Injunction is dissolved or terminated. DONE AND ORDERED in Chambers at Miami, Florida, on September 21, 2021. _________________________________ BETH BLOOM UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record 10 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 11 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes SCHEDULE A TO ORDER GRANTING PRELIMINARY INJUNCTION Defendant # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Marketplace Alibaba Alibaba Alibaba Alibaba Alibaba Alibaba Alibaba Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress DEFENDANTS Guangzhou Bolingyu Trading Co., Ltd. Dailymag Magnetic Technology (Ningbo) Limited Ningbo Fuchuang Imp. & Exp. Co., Ltd. Yiwu Nice Daily Necessities Co., Limited Yiwu Sino E-Business Firm Yueqing Shicheng Power Technology Co., Ltd. Ningbo Z.K.L.S. Imp. & Exp. Co., Ltd. Sunny Always Online Store Buy it now shop 2013 Fairy supermarket Arrowhunt Store QST EXPress-02 Fashion Store A8 WL_XY Store Spotless Store We All Like Shopping B-shine Store XINGWEIQIANG-09 Store TOOKIE Tool Store Bulk Purchase Store Store Silvercell Store Sixth house Store Howl's Moving Tools Store decoration and furnishing Store S-life Store Tools-decorating Store Litake Store WarmHome Store Niu Besting Store Practical house tools Store Welcome-to My Store 1847 Blues Store Instrument Tech Store Brightness Store Fressia Tool Store Store Fighting!!!Fressia Tool Store Store Ali-house tools Store 11 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 12 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Defendant # 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Marketplace Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress DEFENDANTS HOmePetBall Store Drop Shipping To Worldwide Store ANCRV Store Dry Houseware Store LLD Tool Store Sunday House Store Come On Store Our Home 01 Store umogn Store YSTD Global Store Worldwide Chinese Arts Store emm Store Outbreaker77 Store Improvements Lights Store Pets World + A Store Hand Tool Box emm Store Tools Direct Store LLD Drop Shipping Store Pro Tools Direct Store Five Stars Metal Products Factory Store Guoao Measurement Store Michelle's Garden Decoration Store SunnyD Outdoor Store Shop4993329 Store DASF Global Store KK-Yellow Store LIROIODO Store HousehoId Suppies Store I use Instrument tools Store Have Funny Store Industry Tool Accessories Store Maple INstrument&Tool Store Dropship House Accessories Store Department homes Store Kinging third Store Didida Store Tool & life Store OPDBN Painting Store 100% tool Store 12 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 13 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Defendant # 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 Marketplace Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Aliexpress Amazon Amazon Amazon Amazon Amazon Amazon DEFENDANTS Hefei Home-Supply Store H-ome garden Store House Necessities Store Shop900236151 Store Ohhdeer Store Supermarket99 Store Evie Pets Store Beautifully decorated Store You And House Store COMI LIFE Store Shop910449007 Store Householdware Dropshipping Store Homehold quality life Store Better-Home-Life Store Sean's House Store Fun-Family Store Love-Life-Home Store Shop911224130 Store Warming-house Store LuxuryGaP Store Be_FlowHome Store Lovable Life Store Nine Life's Store LISM Life's Store Graceland Homey Store Leisurely Day Home-living Store Smarter Shopping Store Felici Lifestyle Store Joday Store W-Live Store Sahar House Store H-Life Dropshipping Store XiangYang Sunstor Faysida GESN DOYOUDO DianPaiShangMao BEISUOSI-TADIE 13 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 14 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Defendant # 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 Marketplace DHgate DHgate eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay DEFENDANTS Yaritsi Baixiangguo 5073283 1st.ing 1st.vzu ababhuxin abala.coco add2urcart bamboola bhee2se8cake blackyelailin celinlkeoder clicli64 colorb-56 darialingling dr3ag8on elrtronn fanghuang1996 finger-klh futuresok gelivable.2u goodexpectation gracefulvara haisea007 handymen26 hea1985 huxinwhao huzenyo jewelryzhang888 joltio895 kangkanghao kexinxinren kiwi4fruit0 lakesaw laptopallfor87 leihuyoumechenger lemontress lerenet 14 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 15 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Defendant # 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 Marketplace eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay eBay Joom DEFENDANTS liansmile lilybeibei linyuanwenh lucky.shop_7 lzhlds2010_6 magzyyd98 makimingyu mu2ff7in nau34ghty newmcx2016-8 newstarupup newzqz88_6 oneshot77-7 pandaserveyou qujidu relaxtree ruzhenan sadleft sgostore shanghai.box shanghai.vzu shenyang86y smarrashop sunstarfford supermarket8882016 tainanme taoyoumehgfd tdcq888 thatkey thsix1666 tictac88 time.ing topkoo uxpftiv320 wxfeng20168 xinqinggengyun yumuzhang ouyeda 15 Case 1:21-cv-22703-BB Document 41 Entered on FLSD Docket 09/21/2021 Page 16 of 16 Case No. 21-cv-22703-BLOOM/Otazo-Reyes Defendant # 190 191 192 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 Marketplace Joom Joom Joom Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish Wish DEFENDANTS Tasteful Childfourteen Top tool AOA Vivian A_tree Anemone A Lot of Love Mr Giraffe Candy fantasy Mutual affinity Classical instruments glasses of water get together Sown stitch wudongshanlaile nianqingnianweio all tool home fener2580 zhengrenshuo666 MR.OWEN ning peng ze JunChang Store 16
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