COMPLAINT FOR PATENT INFRINGEMENT PAGE 1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS

Kellie DeFries

Plaintiff

versus

MSB Trade Inc. dba Central Sales; SEI Boutique 

LLC dba SEI Boutique;

US entity Defendants

and

Jiarui_US dba JRUI Tech; Shenzhen Xiruiya 

Technology Inc. dba Libby’s Store; 

Guangzhou Yun He Trading Ltd. dba Honey 

Joy Beauty & Health; Qingdao Haifusheng 

Commercial and Trading Co., Ltd. dba

Haifusheng and dba HH1; 

Hefeinenxiongshangmaoyouxiangongsi dba

Zhouyanghao, dba PAFUWEI; 

Shenzhenshixinqitongdianzishangwuyouxian

ggongsi dba Xinqitong and dba SKD-US; 

Liaochengshichaoyueshangmaoyouxiangongs

i dba Chaoyues; Jiangxi Pengxian Shiye Co.

dba Lootaan; Pujiang Qiaoqiao Crystal Ltd.

dba Shiny Crystal and dba Nibiru; Nanjing 

Good Stone Sink Decoration Engineering Co.

dba Aroic; 

Shenzhenbaishenghongchangmaoyiyouxiang

ongsi dba MissDeer-US; Shenzhen Baisite 

Network Technology Co. Ltd. dba Bysiter; 

Shenzhenshi 

Honghaodianzishangwuyouxiangongsi dba

Yokilly Beauty; 

ShenZhenShiJiHengDianZiShangWu Co. 

Ltd. dba TCsupply; Xuqian Xu dba

BeautyChen; Shen Zhen Shi Xin Ji Hong Ke 

Ji You Xian Gong Si dba Ultevy and dba

Yinglong US; Shenzhen Youzen Commerce 

Co. Ltd. dba Biutee Store; Jiu Quan Lan Xin 

Shang Mao You Xian Gong Si dba Kryuie; He 

Siying dba Moibase; Gao YongXue dba

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Civil Action No. ___

Jury Demand

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 1 of 55 PageID 1
COMPLAINT FOR PATENT INFRINGEMENT PAGE 2

Yongsuus; Yueqing Ogry International Trade 

Co. Ltd. dba Orgry US Tech; HiMo Direct dba

Shenzhen Shi Baoan Qu Shajing Jingyida Muju 

xiange; Junhui Peng dba Onwon; Qiming Qin

dba Aliface and dba Winskysea and dba 

Winsocool; Guangzhou Yun He Trading Ltd.

dba Honey Joy Beauty & Health; Dongguan 

Haonuosen Network Technology Co., Ltd.

dba Dongguanshi Haonuosen Wangluokeji 

Youxiangongsi and Honoson; Shenzhen 

Jingdu Network Technology Co. Ltd. dba

Unique2u; ShenZhen ManManLi Cosmetics 

Limited dba NMKL38; Dongguan Tatuo 

Network Technology Co., Ltd. dba Deskoti, 

and dba Tatuo US; yiqingguan dianzishangwu 

youxiangongsi dba ECLEAR; Shenzhenshi 

Aodawo Shangmaoyouxiangongsi dba Audab 

Store; Shenzhen Aoshang Technology Co., 

Ltd. dba shenzhenshiaoshangkejiyouxiangongsi 

and dba Aoshang; Wuhan Xiaqi Technology 

Co., Ltd. dba Vikerer and Vikerer-US; Dequan 

Yu dba MuOu; 

Guizhoukaiyihaobangongjiajuyouxiangongsi

dba FVFGB; Wang Yue Xia dba Tophoolink; 

Guangzhou Huiqi Trading Co., Ltd. dba

GuangzhouHuiqimaoyiyouxiangongsi and dba

Amaoz; GuangZhou ShiDe Trade Company 

Limited dba Beuniar; ShenZhen GuoHao 

Technology Development Co., Ltd. dba

Eyxformula; Guangzhou Dixian Garment 

Co., Ltd dba Latibell; GuTeng technology 

Co,Ltd dba Angnya Nails; Shenzhen Shi 

Hongbisheng Ke Ji You Xian Gong Si dba

TEOYALL; 

Dongguanshijieshimeidianzikejiyouxiangong

si dba COSITTE; Liaocheng Kangyue 

Trading Co., Ltd. dba Kang Yue Trading0; 

Hefei hongteng wangluo keji you xian gong si

dba Mooerca US; Shenzhenshi Fuheng Ecommerce Co., Ltd dba Shenzhenshi Fuheng 

Dian Zi Shangwu Youxian Gongsi and dba

Noverlife; Yiwu Jingqiao Technology Co., 

Ltd. dba JQiao; Pujiang Ruiyi Hardware 

Tools Co., Ltd. dba AILIPU; Shenzhen 

Yingshihong Electronic Technology Co., Ltd.

dba Henry & Helen; Shenzhenshi Peiyun Keji 

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Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 2 of 55 PageID 2
COMPLAINT FOR PATENT INFRINGEMENT PAGE 3

Youxiangongsi dba Yuntop; Zhengding Xian 

Giaoling Shang Mao You Xian Gong Si dba

Qiaoling Trade Co., Ltd.; Zhongshanshi 

Xiaomiao Dianzi Shangwu Youxiangongsi

dba Afantti US; Dong Guan Shi Jia Sheng 

Dian Zi Shang Wu You Xian Gong si dba

Jiasheng Direct and Jiasheng Store; Huizhou 

YLTD Logistics Technology Co., Ltd. dba

Love Lifes; 

yiwushioumeidianzishangwuyouxiangongsi

dba Nail SF; 

Nanjingqianroubuliaoyouxiangongsi dba

Yinglong US; and Does 1-50.

Chinese Entity Defendants.

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COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Kellie DeFries hereby sues the Defendants listed above and alleges as follows:

THE PARTIES

1. Plaintiff Kellie DeFries is an individual residing in National City, California and 

doing business in the Northern District of Texas.

2. Defendant MSB Trade Inc. dba Central Sales is an American entity with listed 

offices at: 1 Central Sales Way, Highland Mills NY, 10930 US. On information and belief, MSB 

Trade Inc. may be reached at this address.

3. Defendant SEI Boutique LLC dba SEI Boutique is an American entity with 

listed offices at: Room 307, 1315 W Gum St., Rogers, AR, 72758-5020 US. On information and 

belief, SEI Boutique LLC. may be reached at this address.

4. Plaintiff has identified a plurality of Chinese entities with self-reported contact 

information that it finds untrustworthy. Plaintiff has drafted a motion for leave to conduct 

jurisdictional discovery of third-party Amazon.com, Inc., who can reasonably expected possess 

relevant contact information for each Defendant but, on information and belief, alleges herein:

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 3 of 55 PageID 3
COMPLAINT FOR PATENT INFRINGEMENT PAGE 4

a. Defendant Jiarui_US dba JRUI Tech is a Chinese entity with 

listed offices at: Room 301, No. 2, San Wai Road, Chung Tau, Dongguan city, 

Chang'an Town, Guangdong Province 523000 CN. On information and belief, 

JIARUI_US may be reached at this address. JRUI_US has disclosed mailroomch@mg-ip.com as a correspondence email with the USPTO and, on information 

and belief, may be reached at this email address.

b. Defendant Guangzhou Yun He Trading Ltd. dba Honey Joy 

Beauty & Health is a Chinese entity with listed offices at: Room 307, Jin Fu 

Building, Qi Fu Road No. 90,Bai Yun District, Guangzhou, Guangdong, China, 

Guangzhou, Guang Dong 510410.CN. On information and belief, Guangzhou 

Yun He Trading Ltd. may be reached at this address. Guangzhou Yun He Trading 

Ltd. has disclosed 3513807825@qq.com as a correspondence email with the 

USPTO and, on information and belief, may be reached at this address.

c. Defendant Qingdao Haifusheng Commercial and Trading Co., 

Ltd. dba Haifusheng and dba HH1 is a Chinese entity with listed offices at: 

Liuting Street, Chengyang District, 500 meters north of Shuangbu Community 

Neighborhood Committee, Qingdao, Shandong Province, 266100 CN. On 

information and belief, Qingdao Haifusheng Commercial and Trading Co., Ltd. 

may be reached at this address.

d. Defendant Hefeinenxiongshangmaoyouxiangongsi dba

Zhouyanghao and dba PAFUWEI is a Chinese entity with listed offices at: Room 

301, Office Building, Xingchen Garden, Xuancheng Road, Hefei, Baohe District, 

Anhui Province, 230000 CN. On information and belief, Qingdao Haifusheng 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 4 of 55 PageID 4
COMPLAINT FOR PATENT INFRINGEMENT PAGE 5

Commercial and Trading Co., Ltd. may be reached at this address. 

Hefeinenxiongshangmaoyouxiangongsi has disclosed topmark@vip.126.com as a 

correspondence email with the USPTO and, on information and belief, may be 

reached at this email address.

e. Defendant Shenzhenshixinqitongdianzishangwuyouxianggongsi 

dba Xinqitong and dba SKD-US is a Chinese entity with listed offices at: 

zhangshubushequzhangfubeilu8haosanqi3dong2002, 

zhangshubushequzhangfubeilu8haosanqi3dong2002, Shenzhen, Guangdong, 

518000 CN. On information and belief, 

Shenzhenshixinqitongdianzishangwuyouxianggongsi may be reached at this 

address.

f. Defendant Liaochengshichaoyueshangmaoyouxiangongsi dba

CHAOYUES is a Chinese entity with listed offices at: No. 27, Zone B, Ten 

Billion Logistics Park, Phoenix Industrial Park, Liaocheng, Dongchangfu District, 

Shandong Province, 252000 CN. On information and belief, 

Liaochengshichaoyueshangmaoyouxiangongsi may be reached at this address. 

Liaochengshichaoyueshangmaoyouxiangongsi has disclosed m.bao@kkklaw.com

and jk.oh@kkklaw.com as correspondence emails with the USPTO and, on 

information and belief, may be reached at any of these email addresses.

g. Defendant Jiangxi Pengxian Shiye Co. dba Lootaan is a Chinese 

entity with listed offices at: Gongyedadao 129 Jinxian Wengangzhen 

Tanhucunweihui, Duanjiacun, Nanchang, Jiangxi, 330017, CN. On information 

and belief, Jiangxi Pengxian Shiye Co may be reached at this address. Jiangxi 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 5 of 55 PageID 5
COMPLAINT FOR PATENT INFRINGEMENT PAGE 6

Pengxian Shiye Co. has disclosed vat_linruolan@aliyun.com as a correspondence 

email with the USPTO and, on information and belief, may be reached at this 

address.

h. Defendant Pujiang Qiaoqiao Crystal Ltd. dba Shiny Crystal and 

dba Nibiru is a Chinese entity with listed offices at: No.95, Songxi Village, Punan 

Street, Pujiang, Jinhua, Zhejiang, 322200, CN. On information and belief, Pujiang 

Qiaoqiao Crystal Ltd. may be reached at this address.

i. Defendant Nanjing Good Stone Sink Decoration Engineering 

Co. dba Aroic is a Chinese entity with listed offices at: Room 1209, Unit 1, 

Building 06, Wanhui City (North District), No. 8 Pukou Avenue, Jiangbei New 

District, Nanjing, Pukou District, Jiangsu Province, 211899 CN. On information 

and belief, Nanjing Good Stone Sink Decoration Engineering Co. may be reached 

at this address. Nanjing Good Stone Sink Decoration Engineering Co. has 

disclosed wayy634@163.com as a correspondence email with the USPTO and, on 

information and belief, may be reached at this address.

j. Defendant Shenzhenbaishenghongchangmaoyiyouxiangongsi

dba MissDeer-US is a Chinese entity with listed offices at: Shui'an New Town 

Community, Ganzhou City, Longnan, Jiangxi Province, 341700 CN. On 

information and belief, Shenzhenbaishenghongchangmaoyiyouxiangongsi may be 

reached at this address. Shenzhenbaishenghongchangmaoyiyouxiangongsi has 

disclosed HAOBIDETM@126.com, zhangariel69@gmail.com, and 

jmlawchina@gmail.com as correspondence emails with the USPTO and, on 

information and belief, may be reached at any of these email addresses.

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 6 of 55 PageID 6
COMPLAINT FOR PATENT INFRINGEMENT PAGE 7

k. Defendant Shenzhen Baisite Network Technology Co. Ltd. dba

Bysiter is a Chinese entity with listed offices at: Room 302 12th 3 Lane 

Lingxiahuayuan Xinan Street Baoan District, Shenzhen, Guangdong 518101 CN. 

On information and belief, Shenzhen Baisite Network Technology Co., Ltd. may 

be reached at this address. Shenzhen Baisite Network Technology Co. Ltd. has 

disclosed siziven@gmail.com as a correspondence email with the USPTO and, on 

information and belief, may be reached at this address.

l. Defendant Shenzhenshi Honghaodianzishangwuyouxiangongsi 

dba Yokilly Beauty is a Chinese entity with listed offices at: Longgangqu 

Bantianjiedao Wuheshequ, Zhujiangxujingjiayuan Diyidong A405 Shi, Shenzhen, 

Guangdong, 518000 CN. On information and belief, Shenzhenshi 

Honghaodianzishangwuyouxiangongsi may be reached at this address. 

Shenzhenshi Honghaodianzishangwuyouxiangongsi has disclosed 

usa@howlader.net as a correspondence email with the USPTO and, on 

information and belief, may be reached at this address.

m. Defendant ShenZhenShiJiHengDianZiShangWu Co. Ltd. dba

TCsupply is a Chinese entity with listed offices at: Yantian Community, Xixiang 

Street 102, No. 2, Lane 7, New 1 Village, Yantian ShenZhen City Baoan 518000 

CN. On information and belief, ShenZhenShiJiHengDianZiShangWu Co. Ltd. 

may be reached at this address.

n. Defendant Xuqian Xu dba BeautyChen is a Chinese entity with 

listed offices at: Yuantanzhen Shuangfenggongyequ, Anqinshi, Anhui, 246314 

CN. On information and belief, Xuqian Xu may be reached at this address. 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 7 of 55 PageID 7
COMPLAINT FOR PATENT INFRINGEMENT PAGE 8

Xuqian Xu has disclosed info@julawoffice.com and otzc010@126.com as 

correspondence emails with the USPTO and, on information and belief, may be 

reached at any of these email addresses.

o. Defendant SHEN ZHEN SHI XIN JI HONG KE JI YOU XIAN 

GONG SI dba Ultevy and dba Yinglong US is a Chinese entity with listed 

offices at: Dalang Street Peak Community, Room 505, Ayutthaya Times, 

Shenzhen, Longhua new district, Guangdong Province, 518110 CN. On 

information and belief, SHEN ZHEN SHI XIN JI HONG KE JI YOU XIAN 

GONG SI may be reached at this address. SHEN ZHEN SHI XIN JI HONG KE 

JI YOU XIAN GONG SI has disclosed shan.zhulaw@gmail.com and 

us@chanfone.com as correspondence emails with the USPTO and, on information 

and belief, may be reached at any of these email addresses.

p. Defendant Shenzhen YOUZEN Commerce Co. Ltd. dba Biutee 

Store is a Chinese entity with listed offices at: Room 502, B building, East 

Industrial Zone, Bantian street, Longgang District, SHENZHEN, GUANGDONG, 

518129 CN. On information and belief, Shenzhen YOUZEN Commerce Co. Ltd. 

may be reached at this address. Shenzhen YOUZEN Commerce Co. Ltd. has 

disclosed 2853277606@qq.com and 2850712070@qq.com as correspondence 

emails with the USPTO and, on information and belief, may be reached at any of 

these email addresses.

q. Defendant Jiu Quan Lan Xin Shang Mao You Xian Gong Si

dba Kryuie is a Chinese entity with listed offices at: 208A,2/F,A1, West 

Plaza,Shenzhen North Station, Zhiyuan Middle, Shenzhen Longhua Dist., 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 8 of 55 PageID 8
COMPLAINT FOR PATENT INFRINGEMENT PAGE 9

Guangdong 518000 CN. On information and belief, Jiu Quan Lan Xin Shang Mao 

You Xian Gong Si may be reached at this address.

r. Defendant HE SIYING dba Moibase is a Chinese entity with 

listed offices at: C, 9th Floor, Lijing Pavilion, Haizhu Peninsula Garden, No. 45, 

Binjiang East Road, Guangzhou City, Haizhu District, Guangdong Province, 

510260 CN. On information and belief, HE SIYING may be reached at this 

address. HE SIYING has disclosed richess@126.com as a correspondence email 

with the USPTO and, on information and belief, may be reached at this email 

address.

s. Defendant Gao YongXue dba Yongsuus is a Chinese entity with 

listed offices at: No. 4, Yuanshan Village, Weixin Town, Dingxi, Min County, 

Gansu, 748400 CN. On information and belief, Gao YongXue may be reached at 

this address.

t. Defendant Yueqing Ogry International Trade Co. Ltd. dba

Orgry US Tech is a Chinese entity with listed offices at: Hongqiao Town 

Shangxianyang Village, Xianlongqian Road, Num. 33, Wenzhou, Zhejiang 

325608 CN. On information and belief, Yueqing Ogry International Trade Co. 

Ltd. may be reached at this address.

u. Defendant HiMo Direct dba Shenzhen Shi Baoan Qu Shajing 

Jingyida Muju xiange is a Chinese entity with listed offices at: dongguanshi 

songshanhu keji shilu, DongGuan GuangDong 523808 CN.

v. Defendant Junhui Peng dba Onwon is a Chinese entity with listed 

offices in 402# 3 building 4th Luozhuang dongli haidian district, beijing beijing 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 9 of 55 PageID 9
COMPLAINT FOR PATENT INFRINGEMENT PAGE 10

100000 CN. Onwon has discloses kimli201504@163.com and bodoyor@126.com

as correspondence emails with the USPTO and on information and belief, would 

thus receive electronic notice at these addresses. 

w. Defendant Qiming Qin dba Aliface and dba Winskysea and dba

Winsocool is a Chinese entity with listed office in 3-1 Hao, Jiao Yu Lu Qing Xiu 

Qu Nanning Guangxi 530000 CN. On information and belief, Winskysea sells 

approximately 201 infringing units per month for approximately [amount] via 

Amazon ASIN Nos. B07CWB7YFX.

x. Defendant Guangzhou Yun He Trading Ltd. dba Honey Joy 

Beauty & Health is a Chinese entity with listed offices at: Room 307, Jin Fu 

Building, Qi Fu Road No. 90, Bai Yun District, Guangzhou, Guangdong, China. 

510410 CN. Honey Joy Beauty and Health has disclosed 3513807825@qq.com as 

a correspondence email with the USPTO and, on information and belief, would 

thus receive electronic notice at this address. 

y. Defendant Dongguan Haonuosen Network Technology Co., 

Ltd. dba Dongguanshi Haonuosen Wangluokeji Youxiangongsi and dba

Honoson is a Chinese entity [with listed offices at: CHANGANZHEN SHATOU 

ZHENGDALU 3 HAO 609 FANG ZHENGDALU 3 HAO 609 FANG 

DONGGUANSHI GUANGDONGSHENG 523866 CN. Honoson has disclosed 

hengda_Receiving@aliyun.com as a correspondence email with the USPTO and, 

on information and belief, would thus receive electronic notice at this address.

z. Defendant Shenzhen Jingdu Network Technology Co. Ltd. dba

UNIQUE2U is a Chinese entity with listed offices at: Xinan Subdistrict Baoan 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 10 of 55 PageID 10
COMPLAINT FOR PATENT INFRINGEMENT PAGE 11

District No 506 Building A4 Haibinhuayuan Qianjin 1st Road, Shenzhen 

Guangdong 518101 CN. UNIQUE2U has disclosed shzoria@gmail.com as a 

correspondence email with the USPTO and, on information and belief, would thus 

receive electronic notice at this address. 

aa. Defendant ShenZhen ManManLi Cosmetics Limited dba

NMKL38 is a Chinese entity with listed offices at: Room 401, ShenPin District 

LongXi Road No58, LongChen Street LongGang, ShenZhen, GuangDong 518100 

CN. NMKL38 has disclosed TM@sellergrowth.com as a correspondence email 

with the USPTO and, on information and belief, would thus receive electronic 

notice at this address. 

bb. Defendant DONGGUAN TATUO NETWORK 

TECHNOLOGY Co., Ltd. dba Deskoti and dba Tatuo US is a Chinese entity 

with listed offices at: Room 2610B, Aoxinya Building, No. 2030, Caitian South 

Road, Fushan Community, Futian Street, Shenzhen, Futian district, Guangdong 

Province 518000 CN. Tatuo US has disclosed linda.lei@getechlaw.com and 

general@getechlaw.com as correspondence emails with the USPTO and, on 

information and belief, would thus receive electronic notice at these addresses. 

cc. Defendant yiqingguan dianzishangwu youxiangongsi dba

ECLEAR is a Chinese entity with listed offices at: Building 1, 106 Fengze East 

Road, X1301-E1243, Guangzhou City, Nansha District, Guangdong Province 

512000 CN. 

dd. Defendant Shenzhenshi Aodawo Shangmaoyouxiangongsi dba

Audab Store is a Chinese entity with listed offices at: liutangshequ baominerlu 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 11 of 55 PageID 11
COMPLAINT FOR PATENT INFRINGEMENT PAGE 12

25hao yanisidasha B201, baoanqu xixiangjiedao, Shenzhen Shi, Guangdong 

sheng 518000 CN. Audab Store has disclosed jetstile168@outlook.com as a 

correspondence email with the USPTO and, on information and belief, would thus 

receive electronic notice at this address. 

ee. Defendant Shenzhen Aoshang Technology Co., Ltd. dba

shenzhenshiaoshangkejiyouxiangongsi and dba Aoshang is a Chinese entity with 

listed offices at: qilinluerxiang6hao903, bantianjiedaonankeshequ, longgang, 

Shenzhen 518129 CN. Aoshang has disclosed hni@nilawfirm.com and 

shu20170713@outlook.com as correspondence emails with the USPTO and, on 

information and belief, would thus receive electronic notice at these addresses. 

ff. Defendant Wuhan Xiaqi Technology Co., Ltd. dba Vikerer and 

dba Vikerer-US is a Chinese entity with listed offices at: Room A2-11-05, 2nd 

Floor, Comprehensive Building, Guannan Science and Technology Industrial 

Park, Wuhan, East Lake New Technology Development Zone, Hubei Province 

430070 CN. Vikerer has disclosed support@vikerer.com, betrue@cn-ip.cn, and 

trademark@cn-ip.cn as correspondence emails with the USPTO and, on 

information and belief, would thus receive electronic notice at these addresses. 

gg. Defendant Dequan Yu dba MuOu is a Chinese entity with listed 

offices at: SituanTown PinggangRoad883-885, 3440 Fengxian, Shanghai 201499 

CN. 

hh. Defendant Guizhoukaiyihaobangongjiajuyouxiangongsi dba

FVFGB is a Chinese entity with listed offices at: 4th Floor, Building 4, Quansen 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 12 of 55 PageID 12
COMPLAINT FOR PATENT INFRINGEMENT PAGE 13

Mahogany Creative Park, No. 4 Jingnan Road, Buji Street (411-Kaiyihao, 

Guizhou) Shenzhen, Longgang District, Guangdong Province 518000 CN. 

ii. Defendant Wang Yue Xia dba Tophoolink is a Chinese entity with 

listed offices at: 

baoanquxixiangjiedaobaoandadao5010haoxibuguiguBzuoerlouM227, Shenzhen, 

Guangdong, 518101 CN. 

jj. Defendant Guangzhou Huiqi Trading Co., Ltd. dba

GuangzhouHuiqimaoyiyouxiangongsi and dba Amaoz is a Chinese entity with 

listed offices at: 2 Hao 13 Xiang Gangwei Xincun Shapu Xintang Zhen, 

Zengcheng, Guangzhou, Guangdong 511338 CN. Amaoz has disclosed 

trademark_y@newimmi.com as a correspondence email with the USPTO and, on 

information and belief, would thus receive electronic notice at this address. 

kk. Defendant GuangZhou ShiDe Trade Company Limited dba

Beuniar is a Chinese entity with listed offices at: No.4 of Room 202, Building 

1,NO.87 Dongpu DaMa Road TianHe, NO.87 Dongpu DaMa Road TianHe 

District, GuangZhou GuangDong 510000 CN. Beuniar has disclosed 

2339161739@qq.com and 2339161739@qq.com as correspondence emails with 

the USPTO and, on information and belief, would thus receive electronic notice at 

these addresses. 

ll. Defendant ShenZhen GuoHao Technology Development Co., 

Ltd. dba Eyxformula is a Chinese entity with listed offices at: 202, Building 9, 

Dongwu Industrial Plant, Shenzhen, Songhe Community Guangdong 518109 CN. 

Exyformula has disclosed 2226109773@qq.com, 2850712070@qq.com, and 

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COMPLAINT FOR PATENT INFRINGEMENT PAGE 14

2853277606@qq.com as correspondence emails with the USPTO and, on 

information and belief, would thus receive electronic notice at these addresses. 

mm. Defendant Guangzhou Dixian Garment Co., Ltd dba Latibell is 

a Chinese entity with listed offices at: Room506, No. 8, Jiangxiabeizhong Road, 

Huangshijie, Baiyun District, Guangzhou, Guangdong 510000 CN. Latibell has 

disclosed ip@afnlegal.com as a correspondence email with the USPTO and, on 

information and belief, would thus receive electronic notice at this address. 

nn. Defendant GuTeng technology Co,Ltd dba Angnya Nails is a 

Chinese entity with listed offices at: Hong Gu Tan New World Trade Road 168, 

Riverside Villa 6 # underground commercial buildings Room 02, Nanchang 

Jiangxi 330038 CN. 

oo. Defendant Shenzhen Shi Hongbisheng Ke Ji You Xian Gong Si

dba TEOYALL is a Chinese entity with listed offices at: Fu Tian Qu Nan Yuan 

Jie Dao, Fu Xing Lu Da Men Fang 55 Dong 604, Shenzhen, Guangdong, 518033 

CN. TEOYALL has disclosed memorytechcenter@hotmail.com as a 

correspondence email with the USPTO and, on information and belief, would thus 

receive electronic notice at this address. 

pp. Defendant Dongguanshijieshimeidianzikejiyouxiangongsi dba

COSITTE is a Chinese entity with listed offices at: Room 486, No. 8, Hongyuan 

Road, Dongguan city, Nancheng Jiedao, Guangdong Province 523087 CN. 

COSITTE has disclosed liu.trademarks@gmail.com and zxy_ip@outlook.com as 

correspondence emails with the USPTO and, on information and belief, would 

thus receive electronic notice at these addresses. 

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COMPLAINT FOR PATENT INFRINGEMENT PAGE 15

qq. Defendant Liaocheng Kangyue Trading Co., Ltd. dba Kang Yue 

Trading0 is a Chinese entity with listed offices at: 

xiangjiangguangcaidashichangjinhaidongsanjie54hao, jinhaidongsanjie54hao, 

dongchangfuquguloujiedaobanshichu, shandongshengliaochengshi 252000 CN. 

rr. Defendant Hefei hongteng wangluo keji you xian gong si dba

Mooerca US is a Chinese entity with listed offices at: shushanqu wang jiang xi lu 

yin xiang xi hu hua yuan, xi zu tuan 2-2127shi, He Fei, An Hui 230000 CN. 

Mooerca US has disclosed trademarks@branding-law.com as a correspondence 

email with the USPTO and, on information and belief, would thus receive 

electronic notice at this address. 

ss. Defendant Shenzhenshi Fuheng E-commerce Co., Ltd dba

Shenzhenshi Fuheng Dian Zi Shangwu Youxian Gongsi and dba Noverlife is a 

Chinese entity with listed offices at: Longgangqu Bujijiedao Nansanshequ, 

Jiezhenglu 23 Hao Zhanjiangyijian Sushelou 506, Shenzhenshi, Guangdong 

510000 CN. Noverlife has disclosed memorytechcenter@hotmail.com as a 

correspondence email with the USPTO and, on information and belief, would thus 

receive electronic notice at this address. 

tt. Defendant Yiwu Jingqiao Technology Co., Ltd. dba JQiao is a 

Chinese entity with listed offices at: Room 510, Building A9, No. 588, Chunhua 

Road, Yiwu City, Beiyuan Jiedao Zhejiang Province 322000 CN. 

uu. Defendant Pujiang Ruiyi Hardware Tools Co., Ltd. dba AILIPU 

is a Chinese entity with listed offices at: No. 8 Wanning Road, Lantang Industrial 

Zone, Baima Town, Jinhua, Zhejiang 322205 CN. AILIPU has disclosed 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 15 of 55 PageID 15
COMPLAINT FOR PATENT INFRINGEMENT PAGE 16

memorytechcenter@hotmail.com as a correspondence email with the USPTO 

and, on information and belief, would thus receive electronic notice at this 

address.

vv. Defendant Shenzhen Yingshihong Electronic Technology Co., 

Ltd. dba Henry & Helen is a Chinese entity with listed offices at: 801, Floor 8, 

Jinxiang Dushi Huayuan, Qingshuihe Street, Luohu District, ShenZhen City, 

Guangdong Province 518000 CN. 

ww. Defendant Shenzhenshi Peiyun Keji Youxiangongsi dba Yuntop 

is a Chinese entity with listed offices at: Room 406, 4th Floor, Building A, 

Freetech Park, 393 Jihua Road, Shenzhen, Longgang District, Guangdong 

Province, 518129 CN. Yuntop has disclosed jmlawchina@gmail.com, 

zhangariel69@gmail.com, and trademarks@126.com as correspondence emails 

with the USPTO and, on information and belief, would thus receive electronic 

notice at these addresses. 

xx. Defendant Zhengding Xian Giaoling Shang Mao You Xian 

Gong Si dba Qiaoling Trade Co., Ltd. is a Chinese entity with listed offices at: 

102, Unit 4, Building 21, Qingxin Garden, Quyang Bridge, Shijiazhuang, 

Zhengding County, Hebei 050800 CN. 

yy. Defendant Zhongshanshi Xiaomiao Dianzi Shangwu 

Youxiangongsi dba Afantti US is a Chinese entity with listed offices at: 

Dongfengzhen Xiaoli Shequ Jiangfenglu, 3 Hao Erlou Zhier, Zhongshan, 

Guangdong 528425 CN. Afantti has disclosed sirenate@outlook.com as a 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 16 of 55 PageID 16
COMPLAINT FOR PATENT INFRINGEMENT PAGE 17

correspondence email with the USPTO and, on information and belief, would thus 

receive electronic notice at this address. 

zz. Defendant Dong Guan Shi Jia Sheng Dian Zi Shang Wu You 

Xian Gong si dba Jiasheng Direct and dba Jiasheng Store is a Chinese entity with 

listed offices at: dao jiao zhen xin chong bian lu er xiang, 6hao 303fang, 

Dongguan, Guangdong 523321 CN. 

aaa. Defendant Huizhou YLTD Logistics Technology Co., Ltd. dba

Love Lifes is a Chinese entity with listed offices at: 1st floor,building 

e,haiyanyulan garden,dashihu,henan bank, Dashihu, Henanan,Huicheng, Huizhou, 

Guangdong 516001 CN. 

bbb. Defendant yiwushioumeidianzishangwuyouxiangongsi dba Nail 

SF is a Chinese entity with listed offices at: 5th Floor, Block D, True Love 

Science and Technology Park, No. 8 Liuhe Road, Yiwu City, Beiyuan Jiedao, 

Zhejiang Province 322000 CN. 

ccc. Defendant Nanjingqianroubuliaoyouxiangongsi dba Yinglong 

US is a Chinese entity with listed offices at: Shenzhen Shiluohuqudongmenjiedao, 

Wenjingzhonglulianxingdashananzuo809, Shenzhen, Guangdong 518000 CN.

5. Does 1-50 are fictitious designations for unauthorized manufacturers, 

distributors, suppliers, wholesalers, retailers, and vendors infringing on Plaintiff’s 

patents whose true names are currently unknown to the Plaintiff.

NATURE OF THE ACTION

6. This is a civil action for infringement under the patent laws of the United States, 

35 U.S.C. § 1 et seq. 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 17 of 55 PageID 17
COMPLAINT FOR PATENT INFRINGEMENT PAGE 18

7. Defendants have and continue to infringe Plaintiff’s U.S. Patent No. 10/308,005, 

U.S. Patent No. 10/675,852, U.S. Patent No. 10/967,625, U.S. Patent No. D867,838, and U.S. 

Patent No. D867,839 (collectively, “the Asserted Patents”). Ms. DeFries is the legal owner of the 

Asserted Patents, which were duly and legally issued by the United States Patent and Trademark 

Office. Plainitff seeks injunctive relief and monetary damages.

JURISDICTION AND VENUE

8. This Court has subject matter jurisdiction over the subject matter of this action 

pursuant to 28 U.S.C. §§ 1331 and 1338(a).

9. Upon information and belief, this Court has personal jurisdiction over each of the 

Defendants in this action because they have each committed acts within this District giving rise 

to this action and have established minimum contacts with this forum such that the exercise of 

jurisdiction over each Defendant would not offend traditional notions of fair play and substantial 

justice. The Defendants have each committed acts of patent infringement and have regularly and 

systematically conducted and solicited business in this District by and through at least several 

theaters in this District.

10. Venue is proper in this District under 28 U.S.C. § 1391 since the Defendants

conduct business in this District and a substantial portion of the events or omissions giving rise 

to this action occurred in this District.

FACTUAL BACKGROUND

A. Plaintiff’s Asserted Patents

11. On June 4, 2019, Plaintiff registered patent no. 10/308,005, titled “Double Ended 

Hand Tool” comprising 11 claims embodying a tool for picking up and manipulating small items 

such as flatback crystals or gems, and visualized as follows:

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 18 of 55 PageID 18
COMPLAINT FOR PATENT INFRINGEMENT PAGE 19

12. On November 26, 2019, Plaintiff registered patent no. D867,838 titled “Double 

Ended Hand Tool” 1 claim for the following design:

13. On November 26, 2019, Plaintiff registered patent no. D867,839 titled “Double 

Ended Hand Tool” 1 claim for the following design:

14. On June 9, 2020, Plaintiff registered patent no. 10/675,852, titled “Double Ended 

Hand Tool” comprising 3 claims embodying a tool for picking up and manipulating small items 

such as flatback crystals or gems, and visualized as follows:

15. On April 6, 2021, Plaintiff registered patent no. 10/967,625, titled “Double Ended 

Hand Tool” comprising 9 claims embodying a tool for picking up and manipulating small items 

such as flatback crystals or gems, and visualized as follows:

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 19 of 55 PageID 19
COMPLAINT FOR PATENT INFRINGEMENT PAGE 20

B. Defendants’ Infringing Products

16. On information and belief, each of the Defendants, individually and collectively, 

sell infringing products by utilizing the platform(s) of Amazon.com, Inc. via one or more of the 

following ASIN Numbers:

B076M1F81T

B07796TC9F

B077GNC8FT

B077RT9DXL

B078W6DMZT

B079GQR1SS

B07BK1TMH4

B07BXFSC87

B07BXGBV5L

B07C2TCZHH

B07CC9HZH9

B07CNF6FB1

B07CWB7YFX

B07D6HQDXX

B07DTB2CBR

B07F1KTLRH

B07GSPX1HL

B07HQ5NXC9

B07JLHZJDS

B07KCRGZBN

B07L2RGPSW

B07M6FSQLG

B07MDRVFD3

B07NPBM1JN

B07NW9QD9Q

B07P5NG3HP

B07P6G7356

B07PC1GCD4

B07PF3VR79

B07PH6GN8C

B07PKBLWT4

B07PVHGTPP

B07PWC7VK3

B07PXHLNQ4

B07PXN5HQ2

B07QR976Z9

B07R6GFT2V

B07RBSRJG2

B07SGXC3NM

B07T47PXZC

B07T58RX7T

B07T5CRGHR

B07T65M5S5

B07T7DJ1FV

B07T7FNB9J

B07TVCRLSB

B07WNT6SDW

B07WNT7K73

B07WNT7LDS

B07WRNSHD3

B07WTSP2WH

B07WVRWMHN

B07X632YLD

B07XHJC2M8

B07YD25H1F

B07Z37PPBV

B081CTMWX5

B0827VWDS9

B082V4QG5H

B0833TGBQ2

B08521M3QM

B08521W3G5

B08522HBBZ

B08522TSDN

B085RQKWNF

B0872QYJGX

B087BSTQ7J

B087QMK895

B088NTNLT1

B08B34P513

B08B37BVLC

B08BC8RJHW

B08BCQ4PGZ

B08BLRZVBV

B08CXKJ7TQ

B08CZJD4T9

B08CZTBWLN

B08D67VZYC

B08F3PBK73

B08FC4WPSV

B08FSJSLFG

B08FTBZG36

B08G8Q56DD

B08GJZBPZK

B08HLS49D5

B08HLSKZM5

B08HLSYQ4T

B08HLTZKN1

B08HLV796T

B08HLW4HZJ

B08HVG6XW9

B08LBL4JMG

B08LPR3JKS

B08P5GRW7Y

B08QSBC7PS

B08RBLFH17

B08SJ1GNNC

B08XXZL83D

B08Z8GSSMT

B08Z8JQ16X

B08Z8KW164

B08Z9K7WGW

B08ZHJG3P2

B0912H7RB2

B091KWY4NB

B091KZPD17

B091L2MM53

B092ZTXX7X

B092ZWDVVJ

B092ZX12MR

B093FD2KV1

B093H1LCTH

B093WXZD3F

B094CYDMSC

B09CFRDB91

17. Only jurisdictional discovery to Amazon.com, Inc. can reasonably identify the 

proper identities and contact information for each seller of the above referenced ASIN Nos. 

Accordingly, Plaintiff files with this petition a motion for jurisdictional discovery of the same.

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 20 of 55 PageID 20
COMPLAINT FOR PATENT INFRINGEMENT PAGE 21

18. Further, to the extent any Defendant herein challenges personal jurisdiction, only 

jurisdictional discovery to Amazon.com, Inc. can reasonably identify the amount of that 

Defendant’s sales in Texas for the purpose of determining this Court’s personal jurisdiction over 

that Defendant. Plaintiff reserves any motion to discovery such information pending a 

jurisdictional challenge.

19. Nevertheless, Plaintiff hereby summarizes its business records––attached herein 

as Exhibit F––as to the above referenced ASIN Nos., as follows:

Defendant / Entity ASIN Price 

Estimated 

Monthly 

Volume

Estimated 

Monthly Cost of 

Infringement

Subay Direct B0827VWDS9 $ 8.98 7409 $ 66,532.82 

B08XBG4Z46 $ 14.28 15 $ 214.20 

B08V5MNQR7 $ 40.99 30 $ 1,229.70 

HiMo Direct B07NPBM1JN $ 5.99 3117 $ 22,567.08 

B08CZJD4T9 $ 9.99 

B094CZ4F3Z $ 6.99 

B094CYDMSC $ 5.99 

Onwon B07WVRWMHN $ 5.98 256 $ 1,530.88 

B07WTSP2WH $ 5.98 20 $ 119.60 

B07WRNSHD3 $ 5.78 381 $ 2,202.18 

B07WNT7K73 $ 5.98 30 $ 179.40 

B07WNT7LDS $ 7.98 30 $ 239.40 

B07WNT6SDW $ 5.98 0 $ - 

B07PH6GN8C $ 5.98 99 $ 592.02 

B07PKBLWT4 $ 5.98 

B07PF3VR79 $ 5.98 

Winsocool B07CWB7YFX $ 12.99 201 $ 2,610.99 

Honey Joy Beauty & Health B076M1F81T $ 7.99 Unknown Unknown

B07C2TCZHH $ 5.99 

Honoson B07T47PXZC $ 8.99 33 $ 296.67 

UNIQUE2U B07MDRVFD3 $ 4.58 120 $ 591.90 

B07M6FSQLG $ 4.58 

B082V4QG5H $ 4.58 

B08B34P513 $ 5.99 

NMKL38 B07D6HQDXX $ 13.56 47 $ 351.18 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 21 of 55 PageID 21
COMPLAINT FOR PATENT INFRINGEMENT PAGE 22

Defendant / Entity ASIN Price 

Estimated 

Monthly 

Volume

Estimated 

Monthly Cost of 

Infringement

B07F1KTLRH $ 5.95 

B07GSPX1HL $ 5.95 

B07796TC9F $ 5.95 

B078W6DMZT $ 5.95 

ANGNYA-US B079GQR1SS $ 6.69 165 $ 1,128.60 

B09JRPMJDS $ 6.99 

Tatuo US B091L2MM53 $ 8.59 3874 $ 33,999.19 

B091KWY4NB $ 8.59 

B091KZPD17 $ 9.59 

Deskoti B07T7FNB9J $ 7.99 

B07T7DJ1FV $ 8.75 

B07HQ5NXC9 $ 8.72 

B07PC1GCD4 $ 7.99 

B07T58RX7T $ 9.99 

B07T5CRGHR $ 8.99 15 $ 134.85 

ECLEAR B08FC4WPSV $ 7.99 250 $ 1,997.50 

Audab Store B07QR976Z9 $ 13.99 179 $ 2,504.21 

Aoshang B08F3PBK73 $ 4.49 977 $ 4,386.73 

Vikerer B08CZTBWLN $ 8.99 3571 $ 34,781.54 

B098S47LTN $ 9.99 

B08D3RWNZ7 $ 9.99 

B098RY8S18 $ 9.99 

wishes ins B07PXN5HQ2 $ 5.98 97 $ 580.06 

B08D67VZYC $ 5.98 

B088NTNLT1 $ 5.98 

B08HVG6XW9 $ 5.98 

TCsupply B08G8Q56DD $ 8.99 710 $ 6,382.90 

B09CFRDB91 $ 8.99 408 $ 3,667.92 

B09CFRDB91 $ 8.99 141 $ 1,267.59 

MuOu B081CTMWX5 $ 6.99 Unknown Unknown 

FVFGB B08BCQ4PGZ $ 5.99 133 $ 796.67 

Vikerer-US B07X632YLD $ 13.99 189 $ 2,644.11 

Tophoolink B07SGXC3NM $ 10.99 544 $ 5,978.56 

SEI Boutique B08GJZBPZK $ 8.89 2325 $ 20,669.25 

zhouyanghao B08QSBC7PS $ 8.14 45 $ 366.30 

SKD-US B08BC8RJHW $ 6.59 183 $ 1,205.97 

B08BC8RJHW $ 6.99 171 $ 1,195.29 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 22 of 55 PageID 22
COMPLAINT FOR PATENT INFRINGEMENT PAGE 23

Defendant / Entity ASIN Price 

Estimated 

Monthly 

Volume

Estimated 

Monthly Cost of 

Infringement

Queek B08FTBZG36 $ 5.98 214 $ 1,387.79 

B08FSJSLFG $ 6.99 

CHAOYUES B08521W3G5 $ 6.10 Unknown Unknown 

B08521M3QM $ 6.10 

B08522TSDN $ 6.10 

B08522HBBZ $ 6.10 

Amaoz B07P6G7356 $ 17.99 1744 $ 31,374.56 

Beuniar B08BL6GP47 $ 9.99 30 $ 299.70 

eyxformula B07NW9QD9Q $ 9.99 244 $ 2,437.56 

wall funny B08C7WNNGT $ 7.99 90 $ 719.10

LATIBELL B093FHVY8G $ 38.98 48 $ 1,871.04 

Ownsig B07JQ81HM2 $ 6.23 86 $ 535.78 

ANGNYA NAILS B07V42WKQZ $ 8.99 21 $ 188.79 

TEOYALL B08P5GRW7Y $ 5.49 681 $ 3,568.44 

B092ZWDVVJ $ 5.49 

B092ZTXX7X $ 5.49 

B092ZX12MR $ 4.49 

Yokilly Beauty B08LPR3JKS $ 7.99 836 $ 6,679.64 

COSITTE B0953JYF7Y $ 11.98 679 $ 8,134.42 

Kang Yue Trading0 B08LBL4JMG $ 9.59 266 $ 2,550.94 

Mooerca US B093H1LCTH $ 7.99 231 $ 1,845.69 

Noverlife B09JP1SX6C $ 23.99 115 $ 2,854.68 

B09FXSC3B3 $ 23.99 

B09FXV1R6L $ 25.99 

B09JVHNBMJ $ 24.99 

B09FXS9H8D $ 25.99 

B09FXSH9Z6 $ 23.99 

JQiao B09NPGM4W5 $ 35.99 390 $ 14,036.10 

B09NPJ8NTN $ 35.99 

B09NPHRYHC $ 35.99 

B09NPJN9BB $ 35.99 

B09NPHRMRJ $ 35.99 

AILIPU B096L2DKCV $ 24.99 1758 $ 43,932.42 

Henry & Helen B084KM9LP7 $ 8.79 287 $ 2,522.73 

yuntop B092M3YTPZ $ 6.47 34 $ 219.98 

Qiaoling Trade Co.,Ltd B08M9SMFYP $ 4.99 243 $ 1,212.57 

B08MX6MLTB $ 4.99 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 23 of 55 PageID 23
COMPLAINT FOR PATENT INFRINGEMENT PAGE 24

Defendant / Entity ASIN Price 

Estimated 

Monthly 

Volume

Estimated 

Monthly Cost of 

Infringement

Afantti US B0912H7RB2 $ 11.99 109 $ 1,306.91 

Jiasheng Direct B08CXKJ7TQ $ 5.99 154 $ 922.46 

Love Lifes B095BYWGM6 $ 32.99 156 $ 5,146.44 

Nail SF B09G2RTJVK $ 6.89 956 $ 6,650.57 

B09DFYBG57 $ 6.99 

B09DFZ1PPM $ 6.99 

B09HBBM1GK $ 6.99 

B09HB8BBHW $ 6.99 

B09HBRZ8HN $ 6.99 

B09HBFN7KZ $ 6.99 

B09JBJTFR4 $ 6.89 

B09JBJC6G8 $ 6.89 

nanjingqianroubuliaoyouxiangongsi B07L2RGPSW $ 6.99 124 $ 866.76 

DOES 1-50 B07DTB2CBR Unknown Unknown Unknown 

B07R6GFT2V

B0833TGBQ2

B07BK1TMH4

B07T65M5S5

B077RT9DXL

B07Z37PPBV

B07P5NG3HP

B07PXHLNQ4

B07PVHGTPP

B07PWC7VK3

B085RQKWNF

B077GNC8FT

B07XHJC2M8

B087QMK895

B08SJ1GNNC

B07CNF6FB1

B07KCRGZBN

B07RWB3JR7

B08G4LGVJZ

B07CC9HZH9

TOTALS: 35,261 $ 364,210.34 

per month per month

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COMPLAINT FOR PATENT INFRINGEMENT PAGE 25

20. Exhibit G to this Complaint comprises internet evidence establishing the 

Amazon.com listings of all named Defendants, from which Plaintiff specifically alleges the 

following:

a. On information and belief, Defendant MSB Trade Inc. currently 

sells approximately 46 infringing units per month for approximately 

$872.62 via Amazon ASIN No. B08B37BVLC. On information and 

belief, MSB Trade Inc. has been selling infringing units in Texas since 

approximately June 2020. The following screenshot from Exhibit G shows 

the Defendant’s infringing product:

b. On information and belief, Defendant JIARUI_US currently sells 

approximately 2589 infringing units per month for approximately 

$22,135.95 via Amazon ASIN Nos. B08CZJD4T9, B094CYDMSC, 

B07NPBM1JN, and B08CZJD4T9. The following screenshot from 

Exhibit G shows the Defendant’s infringing product:

c. On information and belief, Defendant Shenzhen Xiruiya 

Technology Inc. currently sells approximately 8 infringing units per 

month for approximately $55.60 via Amazon ASIN Nos. B07CNF6FB1 

and B07KCRGZBN. On information and belief, Xiruiya Technology Inc. 

has been selling infringing units in Texas since approximately June 2018.

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 25 of 55 PageID 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE 26

The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

d. On information and belief, Defendant Guangzhou Yun He 

Trading Ltd. currently sells infringing units via Amazon ASIN Nos. 

B076M1F81T and B07C2TCZHH. On information and belief, Guangzhou 

Yun He Trading Ltd. has been selling infringing units in Texas since 

approximately November 2017. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

e. On information and belief, Defendant SEI Boutique LLC

currently sells approximately 904 infringing units per month for 

approximately $8,126.96 via Amazon ASIN No. B08GJZBPZK. On 

information and belief, SEI Boutique, LLC. has been selling infringing 

units in Texas since approximately October 2020. The following 

screenshot from Exhibit G shows the Defendant’s infringing product:

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 26 of 55 PageID 26
COMPLAINT FOR PATENT INFRINGEMENT PAGE 27

f. On information and belief, Defendant Qingdao Haifusheng 

Commercial and Trading Co., Ltd. currently sells infringing units via 

Amazon. On information and belief, SEI Boutique, LLC. has been selling 

infringing units in Texas since approximately October 2020.

g. On information and belief, Defendant 

Hefeinenxiongshangmaoyouxiangongsi currently sells infringing units 

via Amazon ASIN No. B08QSBC7PS. On information and belief, 

Zhouyanghao has been selling infringing units in Texas since 

approximately May 2021. The following screenshot from Exhibit G shows 

the Defendant’s infringing product:

h. On information and belief, Defendant 

Shenzhenshixinqitongdianzishangwuyouxianggongsi currently sells 

approximately 63 infringing units per month for approximately $415.17 

via Amazon ASIN No. B08QSBC7PS. The following screenshot from 

Exhibit G shows the Defendant’s infringing product:

i. On information and belief, Defendant 

Liaochengshichaoyueshangmaoyouxiangongsi currently sells infringing 

units via Amazon ASIN No. B08521W3G5, B08521M3QM, 

B08522TSDN, and B08522HBBZ. On information and belief, 

CHAOYUES has been selling infringing units in Texas since 

approximately May 2021. The following screenshot from Exhibit G shows 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 27 of 55 PageID 27
COMPLAINT FOR PATENT INFRINGEMENT PAGE 28

the Defendant’s infringing product:

j. On information and belief, Defendant Jiangxi Pengxian Shiye Co.

currently sells approximately 30 infringing units for approximately 

$200.70 per month via Amazon ASIN No. B07XHJC2M8 and 

B093FD2KV1. On information and belief, Jiangxi Pengxian Shiye Co. has 

been selling infringing units in Texas since approximately May 2021. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

k. On information and belief, Defendant Pujiang Qiaoqiao Crystal 

Ltd. currently sells approximately 223 infringing units for approximately 

$1,781.77 per month via Amazon ASIN No. B093WXZD3F. On 

information and belief, Pujiang Qiaoqiao Crystal Ltd. has been selling 

infringing units in Texas since approximately July 2021. The following 

screenshot from Exhibit G shows the Defendant’s infringing product:

l. On information and belief, Defendant Nanjing Good Stone Sink 

Decoration Engineering Co. currently sells approximately 202 infringing 

units for approximately $1,613.98 per month via Amazon ASIN No. 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 28 of 55 PageID 28
COMPLAINT FOR PATENT INFRINGEMENT PAGE 29

B08ZHJG3P2. On information and belief, Nanjing Good Stone Sink 

Decoration Engineering Co. has been selling infringing units in Texas

since approximately July 2021.

m. On information and belief, Defendant 

Shenzhenbaishenghongchangmaoyiyouxiangongsi currently sells 

approximately 45 infringing units per month for approximately $582.75 

per month via Amazon ASIN No. B08BLRZVBV. On information and 

belief, MissDeer-US has been selling infringing units in Texas since 

approximately March 2021.

n. On information and belief, Defendant Shenzhen Baisite Network 

Technology Co. Ltd. currently sells approximately 15 infringing units for 

approximately $104.85 per month via Amazon ASIN No. B07JLHZJDS. 

On information and belief, Shenzhen Baisite Network Technology Co. 

Ltd. has been selling infringing units in Texas since approximately 

November 2018. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

o. On information and belief, Defendant Shenzhenshi 

Honghaodianzishangwuyouxiangongsi currently sells approximately 447 

infringing units per month for approximately $7.99 per month via Amazon 

ASIN No. B08LPR3JKS. On information and belief, Yokilly Beauty has 

been selling infringing units in Texas since approximately November 

2020. The following screenshot from Exhibit G shows the Defendant’s 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 29 of 55 PageID 29
COMPLAINT FOR PATENT INFRINGEMENT PAGE 30

infringing product:

p. On information and belief, Defendant 

ShenZhenShiJiHengDianZiShangWu Co. Ltd. currently sells 

approximately 30 infringing units for approximately $943.95 per month 

via Amazon ASIN No. B09CFRDB91. On information and belief, 

ShenZhenShiJiHengDianZiShangWu Co. Ltd. has been selling infringing 

units in Texas since approximately August 2021. The following screenshot 

from Exhibit G shows the Defendant’s infringing product:

q. On information and belief, Defendant Xuqian Xu currently sells 

infringing units via Amazon ASIN No. B07YD25H1F. On information 

and belief, Xuqian Xu has been selling infringing units in Texas since 

approximately October 2019. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

r. On information and belief, Defendant SHEN ZHEN SHI XIN JI 

HONG KE JI YOU XIAN GONG SI currently sells approximately 40 

infringing units for approximately $399.60 per month via Amazon ASIN 

No. B08XXZL83D. On information and belief, Ultevy has been selling 

infringing units in Texas since approximately March 2021. The following 

Case 3:22-cv-00549-M Document 1 Filed 03/08/22 Page 30 of 55 PageID 30
COMPLAINT FOR PATENT INFRINGEMENT PAGE 31

screenshot from Exhibit G shows the Defendant’s infringing product:

s. On information and belief, Defendant Shenzhen YOUZEN 

Commerce Co. Ltd. currently sells approximately 45 infringing units for 

approximately $269.55 per month via Amazon ASIN No. B07TVCRLSB. 

On information and belief, Shenzhen YOUZEN Commerce Co. Ltd. has 

been selling infringing units in Texas since approximately February 2020.

The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

t. On information and belief, Defendant Jiu Quan Lan Xin Shang 

Mao You Xian Gong Si currently sells approximately 19 infringing units 

for approximately $189.81 per month via Amazon ASIN No. 

B08RBLFH17. On information and belief, Jiu Quan Lan Xin Shang Mao 

You Xian Gong Si has been selling infringing units in Texas since 

approximately July 2019. The following screenshot from Exhibit G shows 

the Defendant’s infringing product:

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COMPLAINT FOR PATENT INFRINGEMENT PAGE 32

u. On information and belief, HE SIYING currently sells 

approximately 30 infringing units for approximately $239.4 per month via 

Amazon ASIN No. B08RBLFH17. On information and belief, HE 

SIYING has been selling infringing units in Texas since approximately 

March 2021. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

v. On information and belief, Defendant Gao YongXue currently 

sells approximately 30 infringing units for approximately $239.7 per 

month via Amazon ASIN No. B08HLTZKN1, B08HLSKZM5, 

B08HLS49D5, B08HLV796T, B08HLW4HZJ, B08HLSYQ4T. On 

information and belief, Gao YongXue has been selling infringing units in 

Texas since approximately November 2020. The following screenshot 

from Exhibit G shows the Defendant’s infringing product:

w. On information and belief, Defendant Yueqing Ogry 

International Trade Co. Ltd. currently sells infringing units via Amazon 

ASIN No. B087BSTQ7J. On information and belief, Yueqing Ogry 

International Trade Co. Ltd. has been selling infringing units in Texas

since approximately October 2021.

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On information and belief, Defendant HiMo Direct sells approximately 

12,468 infringing units per month for approximately $90,268.32 via 

Amazon ASIN Nos. B07NPBM1JN, B08CZJD4T9, B094CZ4F3Z, and 

B094CYDMSC. On information and belief, HiMo Direct has been selling 

infringing units in Texas since approximately August 2019. The following 

screenshot from Exhibit G shows the Defendant’s infringing product:

x. On information and belief, Defendant Onwon sells approximately 

758 infringing units per month for approximately $72,570.24 via Amazon 

ASIN Nos. B07WVRWMHN, B07WTSP2WH, B07WRNSHD3, 

B07WNT7K73, B07WNT7LDS, B07WNT6SDW, B07PH6GN8C, 

B07PKBLWT4, and B07PF3VR79. On information and belief, Onwon 

has been selling infringing units in Texas since approximately October 

2019. The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

y. On information and belief, Defendant Winskysea has been selling 

infringing units in Texas since approximately June 2020. The following 

screenshot from Exhibit G shows the Defendant’s infringing product:

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z. On information and belief, Defendant Honey Joy Beauty & 

Health has sold infringing units via Amazon ASIN Nos. B076M1F81T 

and B07C2TCZHH. On information and belief, Defendant Honey Joy 

Beauty & Health has been selling infringing units in Texas since 

approximately November 2017. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

aa. On information and belief, Defendant Honoson sells 

approximately 33 infringing units per month for approximately $296.67 

via Amazon ASIN Nos.B07T47PXZC ASINs. On information and belief, 

Honoson has been selling infringing units in Texas since approximately 

July 2019. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

bb. On information and belief, Defendant UNIQUE2U sells 

approximately 480 infringing units per month for approximately $2367.60 

via Amazon ASIN Nos. B07MDRVFD, B07M6FSQLG, B082V4QG5H, 

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and B08B34P513. On information and belief, UNIQUE2U has been

selling infringing units in Texas since approximately February 2019. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

cc. On information and belief, Defendant NMKL38 sells 

approximately 235 infringing units per month for approximately $1,755.92 

via Amazon ASIN Nos. B07D6HQDXX, B07F1KTLRH, B07GSPX1HL, 

B07796TC9F, and B078W6DMZT. On information and belief, NMKL38 

has been selling infringing units in Texas since approximately July 2018. 

The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

dd. On information and belief, Defendant Tatuo US sells 

approximately 58,125 infringing units per month for approximately 

$272128.39 via Amazon ASIN Nos. B07T7FNB9J, B07T7DJ1FV, 

B07HQ5NXC9, B091L2MM53, B091KWY4NB, B091KZPD17, 

B07PC1GCD4, B07T58RX7T, and B07T5CRGHR. On information and 

belief, Tatuo US has been selling infringing units in Texas since 

approximately October 2019. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

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ee. On information and belief, Defendant ECLEAR sells 

approximately 250 infringing units per month for approximately $1997.50 

via Amazon ASIN Nos. B08FC4WPSV. On information and belief, 

ECLEAR has been selling infringing units in Texas since approximately 

February 2021. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

ff. On information and belief, Defendant Audab Store sells 

approximately 250 infringing units per month for approximately $2,504.21 

via Amazon ASIN Nos. B07QR976Z9. On information and belief, Audab 

Store has been selling infringing units in Texas since approximately May 

2020. The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

gg. On information and belief, Defendant Aoshang sells 

approximately 977 infringing units per month for approximately $4,386.73 

via Amazon ASIN Nos. B08F3PBK73. On information and belief, 

Aoshang has been selling infringing units in Texas since approximately 

August 2020. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

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hh. On information and belief, Defendant Vikerer sells approximately 

14,473 infringing units per month for approximately $141,770.27 via 

Amazon ASIN Nos. B08CZTBWLN, B098S47LTN, B08D3RWNZ7, 

B098RY8S18, and B07X632YLD. On information and belief, Vikerer has 

been selling infringing units in Texas since approximately August 2020. 

The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

ii. On information and belief, Defendant MuOu has sold infringing 

units via Amazon ASIN No. B081CTMWX5. On information and belief, 

MuOu has been selling infringing units in Texas since approximately 

September 2020. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

jj. On information and belief, Defendant FVFGB sells approximately 

133 infringing units per month for approximately $796.67 via Amazon 

ASIN Nos. B08BCQ4PGZ. On information and belief, FVFGB has been 

selling infringing units in Texas since approximately July 2020. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

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kk. On information and belief, Defendant Tophoolink sells 

approximately 544 infringing units per month for approximately $5,978.56 

via Amazon ASIN Nos. B07SGXC3NM. On information and belief, 

Tophoolink has been selling infringing units in Texas since approximately 

June 2019. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

ll. On information and belief, Defendant Amaoz sells approximately 

1744 infringing units per month for approximately $31,374/56 via 

Amazon ASIN Nos. B07P6G7356. On information and belief, Amaoz has 

been selling infringing units in Texas since approximately April 2019. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

mm. On information and belief, Defendant Beuniar sells approximately 

30 infringing units per month for approximately $299.70 via Amazon 

ASIN Nos B08BL6GP47. On information and belief, Beuniar has been 

selling infringing units in Texas since approximately September 2020. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

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nn. On information and belief, Defendant Exyformula sells 

approximately 244 infringing units per month for approximately $2437.56 

via Amazon ASIN Nos. B07NW9QD9Q. On information and belief, 

Exyformula has been selling infringing units in Texas since approximately 

April 2019. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

oo. On information and belief, Defendant Latibell sells approximately 

48 infringing units per month for approximately $1871.04 via Amazon 

ASIN Nos. B093FHVY8G. On information and belief, Latibell has been 

selling infringing units in Texas since approximately October 2021. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

pp. On information and belief, Defendant Angnya Nails sells 

approximately 330 infringing units per month for approximately $188.79 

via Amazon ASIN Nos. B07V42WKQZ. On information and belief, 

Angnya Nails has been selling infringing units in Texas since 

approximately February October 2019. The following screenshot from 

Exhibit G shows the Defendant’s infringing product:

qq. On information and belief, Defendant TEOYALL sells 

approximately 2,724 infringing units per month for approximately 

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$14,273.76 via Amazon ASIN Nos. B08P5GRW7Y, B092ZWDVVJ, 

B092ZTXX7X, and B092ZX12MR. On information and belief, 

TEOYALL has been selling infringing units in Texas since approximately 

October 2021. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

rr. On information and belief, Defendant COSITTE sells 

approximately 679 infringing units per month for approximately $8134.42 

via Amazon ASIN Nos B0953JYF7Y. On information and belief, 

COSITTE has been selling infringing units in Texas since approximately 

October 2021. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

ss. On information and belief, Defendant Kang Yue Trading0 sells 

approximately 266 infringing units per month for approximately $2550.94 

via Amazon ASIN Nos B08LBL4JMG. On information and belief, Kang 

Yue Trading0 has been selling infringing units in Texas since 

approximately April 2021. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

tt. On information and belief, Defendant Mooerca US sells 

approximately 231 infringing units per month for approximately $1845.69 

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via Amazon ASIN Nos. B093H1LCTH. On information and belief, 

Mooerca US has been selling infringing units in Texas since 

approximately October 2021. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

uu. On information and belief, Defendant Noverlife sells 

approximately 690 infringing units per month for approximately 

$17,1288.10 via Amazon ASIN Nos. B09JP1SX6C, B09FXSC3B3, 

B09FXV1R6L, B09JVHNBMJ, B09FXS9H8D, and B09FXSH9Z6. On 

information and belief, Noverlife has been selling infringing units in 

Texas since approximately October 2021. The following screenshot from 

Exhibit G shows the Defendant’s infringing product:

vv. On information and belief,Defendant JQiao sells approximately 

1950 infringing units per month for approximately $70,180.50 via 

Amazon ASIN Nos. B09NPGM4W5, B09NPJ8NTN, B09NPHRYHC, 

B09NPJN9BB, and B09NPHRMRJ. On information and belief, JQiao has 

been selling infringing units in Texas since approximately December 

2021. The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

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ww. On information and belief, Defendant AILIPU sells approximately 

1758 infringing units per month for approximately $43,932.42 via 

Amazon ASIN Nos. B096L2DKCV. On information and belief, AILIPU 

has been selling infringing units in Texas since approximately October 

2021. The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

xx. On information and belief, Defendant Henry & Helen sells 

approximately 287 infringing units per month for approximately $2522.73 

via Amazon ASIN Nos. B084KM9LP7. On information and belief, Henry 

& Helen has been selling infringing units in Texas since approximately 

October 2021. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

yy. On information and belief, Defendant Yuntop sells approximately 

34 infringing units per month for approximately $219.98 via Amazon 

ASIN Nos. B092M3YTPZ. On information and belief, Yuntop has been 

selling infringing units in Texas since approximately October 2021. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

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zz. On information and belief, Defendant Qiaoling Trade Co., Ltd.

sells approximately 486 infringing units per month for approximately 

$2425.14 via Amazon ASIN Nos. B08M9SMFYP, and B08MX6MLTB. 

On information and belief, Qiaoling Trade Co., Ltd. has been selling 

infringing units in Texas since approximately October 2021. The 

following screenshot from Exhibit G shows the Defendant’s infringing 

product:

aaa. On information and belief, Defendant Afantti US sells 

approximately 109 infringing units per month for approximately $1306.91 

via Amazon ASIN Nos. B0912H7RB2. On information and belief, Afantti 

US has been selling infringing units in Texas since approximately October 

2021. The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

bbb. On information and belief, Defendant Jiasheng Direct sells 

approximately 154 infringing units per month for approximately $922.46 

via Amazon ASIN Nos. B08CXKJ7TQ. On information and belief, 

Jiasheng Direct has been selling infringing units in Texas since 

approximately October 2021. The following screenshot from Exhibit G 

shows the Defendant’s infringing product:

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ccc. On information and belief, Defendant Love Lifes sells 

approximately 486 infringing units per month for approximately $5146.44 

via Amazon ASIN Nos. B095BYWGM6 On information and belief, Love 

Lifes has been selling infringing units in Texas since approximately 

October 2021. The following screenshot from Exhibit G shows the 

Defendant’s infringing product:

ddd. On information and belief, Defendant Nail SF sells approximately 

8.604 infringing units per month for approximately $59855.16 via 

Amazon ASIN Nos. B09G2RTJVK, B09DFYBG57, B09DFZ1PPM, 

B09HBBM1GK, B09HB8BBHW, B09HBRZ8HN, B09HBFN7KZ, 

B09JBJTFR4, and B09JBJC6G8 On information and belief, Nail SF has 

been selling infringing units in Texas since approximately October 2021. 

The following screenshot from Exhibit G shows the Defendant’s 

infringing product:

eee. On information and belief, Defendant Yinglong US sells 

approximately 124 infringing units per month for approximately $866.76 

via Amazon ASIN Nos. B07L2RGPSW. On information and belief, 

Yinglong US has been selling infringing units in Texas since 

approximately October 2021. The following screenshot from Exhibit G 

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shows the Defendant’s infringing product:

FIRST CAUSE OF ACTION

Infringement of Patent No. 10/308,005

21. Plaintiff re-alleges and incorporates by reference each of the allegations in the 

foregoing paragraphs as though fully set forth herein. 

22. Ms. DeFries is the current exclusive owner and assignee of all right, title, and 

interest in and to U.S. Patent No. 10/308,005 (“the ‘005 patent”), duly and legally issued by the 

United States Patent and Trademark Office, including the right to bring this suit for damages. A 

true and correct copy of the '005 patent is attached hereto as Exhibit A.

23. The ‘005 patent is valid and enforceable.

24. Defendants have each directly infringed the '005 patent by making, using, selling, 

offering for sale, and/or importing into the United States, without authority, products, methods 

performed by and/or attributable to equipment, and or services that practice one or more claims 

of the '005 patent, including but not limited to double ended hand tools, and components thereof 

(herein the "Infringing Products "). 

25. As a non-limiting example, Defendants have each infringed claim 1 of the '005

patent. Claim 1 claims as follows––

“A tool for applying items, said tool comprising: a wax tip, and wherein said wax tip is 

connected to a tubular portion, and wherein said wax tip comprises a conical shape;

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a. wherein said tubular portion is coupled to a first end of a hollow connector, 

and wherein an applicator is adjacent to a second end of said hollow 

connector, wherein said applicator comprises a conical extended portion;

b. wherein said conical extended portion is hollow;

c. wherein said hollow connector is located inside of a hollow shaft;

d. an applicator cover which is coupled to said second end of said hollow 

connector, wherein said applicator cover surrounds said applicator and 

comprises a hole through which said conical extended portion extends;

e. wherein said applicator is adjacent to said hollow shaft;

f. wherein said tool comprises a first distal end opposite a second distal end, and 

wherein said wax tip is on a first distal end, and wherein conical extended 

portion is on said second distal end; and

g. wherein said applicator cover and said conical extended portion are visible 

when said tool is properly assembled.”

26. On information and belief each Defendant has infringed at least claim 1 of the 

‘005 patent through its use of an application tool comprising each element of the claim.

27. On information and belief each Defendant has had actual knowledge of both the 

Plaintiff’s rights in the ‘005 patent and details of their infringement before the filing date of this 

Complaint.

28. By reason of each Defendant’s activities, Plaintiff has suffered substantial 

damages in an amount to be proven at trial. But for each Defendant’s infringement of the ‘005 

patent, Plaintiff would either licensed the ‘005 patent to the Defendants or sold them products

defined by the ‘005 patent for resale. As a result of each Defendant’s infringement, Plaintiff has 

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been damaged in an amount equal to the loss of profits that would otherwise have accrued to the 

Plaintiff from providing its parented product to the Defendants, but in no event less than a 

reasonable royalty.

SECOND CAUSE OF ACTION

Infringement of Patent No. D867,838

29. Plaintiff re-alleges and incorporates by reference each of the allegations in the 

foregoing paragraphs as though fully set forth herein. 

30. Ms. DeFries is the current exclusive owner and assignee of all right, title, and 

interest in and to U.S. Patent No. D867,838 (“the ‘838 patent”), duly and legally issued by the 

United States Patent and Trademark Office, including the right to bring this suit for damages. A 

true and correct copy of the '838 patent is attached hereto as Exhibit D.

31. The ‘838 patent is valid and enforceable.

32. Defendants have each directly infringed the '838 patent by making, using, selling, 

offering for sale, and/or importing into the United States, without authority, products, methods 

performed by and/or attributable to equipment, and or services that practice one or more claims 

of the '838 patent, including but not limited to double ended hand tools, and components thereof 

(herein the "Infringing Products "). 

33. As a non-limiting example, Defendants have each infringed claim 1 of the '838

patent. Claim 1 claims as follows––

“The ornamental design for a double ended hand tool, as shown and described.”

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34. On information and belief each Defendant has infringed at least claim 1 of the 

‘838 patent through its use of an application tool comprising the ornamental design shown in the 

claim.

35. On information and belief each Defendant has had actual knowledge of both the 

Plaintiff’s rights in the ‘838 patent and details of their infringement before the filing date of this 

Complaint.

36. By reason of each Defendant’s activities, Plaintiff has suffered substantial 

damages in an amount to be proven at trial. But for each Defendant’s infringement of the ‘838

patent, Plaintiff would either licensed the ‘838 patent to the Defendants or sold them products 

defined by the ‘838 patent for resale. As a result of each Defendant’s infringement, Plaintiff has 

been damaged in an amount equal to the loss of profits that would otherwise have accrued to the 

Plaintiff from providing its parented product to the Defendants, but in no event less than a 

reasonable royalty.

THIRD CAUSE OF ACTION

Infringement of Patent No. D867,839

37. Plaintiff re-alleges and incorporates by reference each of the allegations in the 

foregoing paragraphs as though fully set forth herein. 

38. Ms. DeFries is the current exclusive owner and assignee of all right, title, and 

interest in and to U.S. Patent No. D867,839 (“the ‘839 patent”), duly and legally issued by the 

United States Patent and Trademark Office, including the right to bring this suit for damages. A 

true and correct copy of the '839 patent is attached hereto as Exhibit E.

39. The ‘839 patent is valid and enforceable.

40. Defendants have each directly infringed the '839 patent by making, using, selling, 

offering for sale, and/or importing into the United States, without authority, products, methods 

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performed by and/or attributable to equipment, and or services that practice one or more claims 

of the '839 patent, including but not limited to double ended hand tools, and components thereof 

(herein the "Infringing Products "). 

41. As a non-limiting example, Defendants have each infringed claim 1 of the '839 

patent. Claim 1 claims as follows––

“The ornamental design for a double ended hand tool, as shown and described.”

42. On information and belief each Defendant has infringed at least claim 1 of the 

‘839 patent through its use of an application tool comprising the ornamental design shown in the 

claim.

43. On information and belief each Defendant has had actual knowledge of both the 

Plaintiff’s rights in the ‘839 patent and details of their infringement before the filing date of this 

Complaint.

44. By reason of each Defendant’s activities, Plaintiff has suffered substantial 

damages in an amount to be proven at trial. But for each Defendant’s infringement of the ‘839 

patent, Plaintiff would either licensed the ‘839 patent to the Defendants or sold them products 

defined by the ‘839 patent for resale. As a result of each Defendant’s infringement, Plaintiff has 

been damaged in an amount equal to the loss of profits that would otherwise have accrued to the 

Plaintiff from providing its parented product to the Defendants, but in no event less than a 

reasonable royalty.

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FOURTH CAUSE OF ACTION

Infringement of Patent No. 10/675,852

45. Plaintiff re-alleges and incorporates by reference each of the allegations in the 

foregoing paragraphs as though fully set forth herein. 

46. Ms. DeFries is the current exclusive owner and assignee of all right, title, and 

interest in and to U.S. Patent No. 10/675,852 (“the ‘852 patent”), duly and legally issued by the 

United States Patent and Trademark Office, including the right to bring this suit for damages. A 

true and correct copy of the '852 patent is attached hereto as Exhibit B.

47. The ‘852 patent is valid and enforceable.

48. Defendants have each directly infringed the '852 patent by making, using, selling, 

offering for sale, and/or importing into the United States, without authority, products, methods 

performed by and/or attributable to equipment, and or services that practice one or more claims 

of the '852 patent, including but not limited to double ended hand tools, and components thereof 

(herein the "Infringing Products "). 

49. As a non-limiting example, Defendants have each infringed claim 1 of the '852 

patent. Claim 1 claims as follows––

“A method for making a tool, said method comprising the steps of:

a. preparing a wax;

b. melting the wax;

c. injecting the melted wax into a mold to form a wax portion;

d. inserting a tubular portion into said wax portion to form a wax tip;

e. inserting said wax tip into a connector located on the tool

wherein said wax tip is connected to said tubular portion, and wherein said wax tip 

comprises a conical shape;

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wherein said tubular portion is coupled to a first end of said connector, and wherein an 

applicator is adjacent to a second end of said connector, wherein said applicator 

comprises a conical extended portion;

wherein said conical extended portion is hollow;

wherein said connector is located inside of a hollow shaft, and wherein said connector is 

hollow.”

50. On information and belief each Defendant has infringed at least claim 1 of the 

‘852 patent through its use of an application tool comprising each element of the claim.

51. On information and belief each Defendant has had actual knowledge of both the 

Plaintiff’s rights in the ‘852 patent and details of their infringement before the filing date of this 

Complaint.

52. By reason of each Defendant’s activities, Plaintiff has suffered substantial 

damages in an amount to be proven at trial. But for each Defendant’s infringement of the ‘852 

patent, Plaintiff would either licensed the ‘852 patent to the Defendants or sold them products 

defined by the ‘852 patent for resale. As a result of each Defendant’s infringement, Plaintiff has 

been damaged in an amount equal to the loss of profits that would otherwise have accrued to the 

Plaintiff from providing its parented product to the Defendants, but in no event less than a 

reasonable royalty.

FIFTH CAUSE OF ACTION

Infringement of Patent No. 10/967,625

53. Plaintiff re-alleges and incorporates by reference each of the allegations in the 

foregoing paragraphs as though fully set forth herein. 

54. Ms. DeFries is the current exclusive owner and assignee of all right, title, and 

interest in and to U.S. Patent No. 10/975,625 (“the ‘625 patent”), duly and legally issued by the 

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United States Patent and Trademark Office, including the right to bring this suit for damages. A 

true and correct copy of the ‘625 patent is attached hereto as Exhibit B.

55. The ‘625 patent is valid and enforceable.

56. Defendants have each directly infringed the '625 patent by making, using, selling, 

offering for sale, and/or importing into the United States, without authority, products, methods 

performed by and/or attributable to equipment, and or services that practice one or more claims 

of the '625 patent, including but not limited to double ended hand tools, and components thereof 

(herein the "Infringing Products "). 

57. As a non-limiting example, Defendants have each infringed claim 1 of the '625 

patent. Claim 1 claims as follows––

“A tool for applying items, said tool comprising:

a first end and a second end, said first and second ends coupled by a shaft;

wherein said first end comprises a wax tip, and wherein said second end comprises a 

hollow extended portion which is narrower than the shaft, and wherein said tool 

further comprises a connector located within said shaft, and wherein said hollow 

extended portion comprises a hollow tube, and further comprising an adapter, 

wherein said hollow extended portion which is narrower than the first end is coupled 

to said adapter, and wherein said connector couples said wax tip and said adapter.”

58. On information and belief each Defendant has infringed at least claim 1 of the 

‘625 patent through its use of an application tool comprising each element of the claim.

59. On information and belief each Defendant has had actual knowledge of both the 

Plaintiff’s rights in the ‘625 patent and details of their infringement before the filing date of this 

Complaint.

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60. By reason of each Defendant’s activities, Plaintiff has suffered substantial 

damages in an amount to be proven at trial. But for each Defendant’s infringement of the ‘625 

patent, Plaintiff would either licensed the ‘625 patent to the Defendants or sold them products 

defined by the ‘625 patent for resale. As a result of each Defendant’s infringement, Plaintiff has 

been damaged in an amount equal to the loss of profits that would otherwise have accrued to the 

Plaintiff from providing its parented product to the Defendants, but in no event less than a 

reasonable royalty.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests the following relief: 

A. A judgment that each Defendant has infringed and is infringing each and every 

one of the Asserted Patents; 

B. A preliminary and permanent injunction against Defendants, its respective 

officers, agents, servants, employees, attorneys, parent and subsidiary corporations, assigns and 

successors in interest, and those persons in active concert or participation with them, 

enjoining them from infringement, inducement of infringement, and contributory infringement of 

each and every one of the Asserted Patents, including but not limited to an injunction against 

making, using, selling, distributing, and/or offering for sale within the United States, and/or 

importing into the United States, any products and/or services that infringe the Asserted Patents;

C. Lost profit damages resulting from each Defendant’s infringement of the Asserted 

Patents; 

D. A reasonable royalty for each Defendant’s use of Plaintiff’s patent product, as 

alleged herein;

E. Prejudgment interest;

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COMPLAINT FOR PATENT INFRINGEMENT PAGE 54

F. Post-judgment interest;

G. A judgment holding each Defendant’s infringement of the Asserted Patents to be 

willful, and a trebling of damages pursuant to 35 U.S.C. § 284;

H. A declaration that this Action is exceptional pursuant to 35 U.S.C. § 285, and an 

award to Plaintiff of its attorney’s fees, costs, and expenses incurred in connection with this 

Action; and

I. Such other relief as the Court deems just and equitable. 

DEMAND FOR JURY TRIAL

Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of 

any issues so triable by right.

Dated this 8

th day of March, 2022.

Respectfully Submitted,

Leavitt Eldredge Law Firm

/Brandon J. Leavitt/____________

Brandon James Leavitt

Tx Bar No. 24078841

4204 SW Green Oaks Blvd., Suite 140

Arlington, TX 76107

(214) 727-2055

brandon@uslawpros.com

ATTORNEYS FOR PLAINTIFF

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COMPLAINT FOR PATENT INFRINGEMENT PAGE 55

VERIFICATION STATEMENT

I, Kellie DeFries, hereby state under oath that I am the Plaintiff in this dispute, that I have 

read the foregoing complaint, and that it is are true and accurate to the best of my knowledge and 

belief, except as to matters stated on information and belief, and that as to those matters I believe 

to be true.

I declare under penalty of perjury that the foregoing verification is true and correct to the 

best of my knowledge and belief, and as to any matter stated on belief, I believe such to be true.

Dated this 8

th day of March 2022.

/Kellie DeFries/

Kellie DeFries

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