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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

TORSHARE LTD.,

Plaintiff,

 v.

Case No.: 4:22-cv-00482

VERIFIED COMPLAINT

IGLO, LLC; SUNEEL MENON; AND DOES 

1-10, 

Defendants.

Case No.: 4:22-cv-00482

AMENDED COMPLAINT

INTRODUCTION

1. Plaintiff TORSHARE LTD. (“Plaintiff”), by and through the undersigned 

counsel, hereby bringsfiles this actionFirst Amended Complaint (“FAC”) against Defendants 

IGLO, LLC, SUNEEL MENON, and DOES 1-10 (collectively referred hereto as “Defendants”). 

The FAC is filed with the consent of the counsel for Defendants pursuant to a Joint Status Report 

filed by both parties on July 25, 2022, whereby both parties agreed that each party may amend 

their pleadings without obtaining leave of Court within 10 weeks after the Scheduling 

Conference. The Scheduling Conference was conducted on July 11, 2022.

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

2

INTRODUCTION

”), inclusive, 1. Plaintiff brings this action against Defendants and alleges as follows based 

upon personal knowledge, information, and belief.

2. This action arises from Defendants’ failure to pay for goods received, whereby 

Plaintiff now seeks recovery of damages as a result of Defendants’ failure and continued refusal 

to tender payments.

3. As set forth below, the parties entered into two agreements. One agreement was

for sale of 6500 pieces of LED panel lights at the price of $35.20 each on or around June 12, 2017.

The other was for sale of 2300 pieces of UFO Highbay lights at the price of $65.00 each on or 

around December 19, 2017. Plaintiff has performed all its obligations by shipping the goods and 

Defendants have failed to make payments for the goods received.

4. Despite having made multiple attempts to resolve this matter, Defendants have 

continued to ignore and avoid Plaintiff’s repeated attempts to obtain the payment. 

THE PARTIES

5. Plaintiff is, and at all relevant times has been, a corporation incorporated and having 

its principal place of business in the People’s Republic of China.

6. Defendant IGLO, LLC (“IGLO”) is a Texas entity established and having its 

principal place of business in the State of Texas with address at 4924 Cambridge Road, Fort Worth, 

TX 76155.

7. Defendant Suneel Menon is a Texas resident, who on information and belief, owns 

and manages IGLO. 

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

3

8. Plaintiff is presently unaware of the true names and capacities, whether individual, 

corporate, partnership, associate, or otherwise, of Defendants Does 1 through 10, inclusive, and 

accordingly sues said Defendants by such fictitious names. 

9. Plaintiff alleges on information and belief that each of the Defendants designated 

herein as Does 1 through 10, inclusive, is in some manner responsible for the events and 

happenings referred to herein and/or that such Defendants are liable in some manner for the 

obligation described herein. Plaintiff will amend this complaint to set forth the true names and 

capacities of said Defendants when ascertained and if necessary.

10. Upon information and belief, each Defendant is, and at all relevant times has been, 

the agent and representative of the other Defendants; and each Defendant at all relevant times acted, 

and each continues to act, with the knowledge and consent of all other Defendants; and each 

Defendant is liable for the acts and omissions of the other Defendants.

JURISDICTION AND VENUE

11. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 

§1332 because the parties are diverse and the amount in controversy exceeds $75,000.00, exclusive 

of interest and court costs. Plaintiff is a citizen of People’s Republic of China. Defendants IGLO

and Suneel Menon are citizens of Texas.

12. This Court has personal jurisdiction over IGLO because IGLO was established and 

has its principal place of business in this district. This Court has personal jurisdiction over each 

Defendant because each Defendant has purposefully availed itself of the privilege of transacting 

business in this District.

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

4

13. Venue is proper in this District under 28 U.S.C. § 1391(b)(1) because each of the 

Defendants is a resident of this judicial district of the State of Texas, and under 28 U.S.C. § 

1391(b)(2) because a substantial part of the events giving rise to the claims asserted, infra, occurred 

in this judicial district.

FACTUAL BACKGROUND

14. Plaintiff is a high-tech company carrying out the business of manufacturing and 

sale of various LED products. Over the years prior to 2017, the parties were engaged in series of 

business transactions where Plaintiff supplied LED products to IGLO in return for payments by 

IGLO. The parties conducted the transactions through emails and phone calls for quote and 

quantity, providing proforma invoice and bill of lading by Plaintiff and tendering payments by 

IGLO upon receipt of goods.

15. On or around June 12, 2017, IGLO emailed Plaintiff asking for quote on 6500 

pieces of LED panel lights and Plaintiff responded with a proforma invoice providing a unit price 

of $35.20 each. The proforma invoice also provided for the deliver term as FOB and payment 

terms. A true copy of the proforma invoice is attached hereto as Exhibit 1.

16. From August 22July 26, 2017 to November 20, 2017, Plaintiff arranged for 

fourseven shipments of LED panel lights for the total amount of 40266500 pieces1 through a third 

1

(1) BillsBill of lading No. LT201700011LT201700030 issued on August 22November 20, 2017 contains 70042

pieces of LED panel lights; (2) bill of lading No. LT201700012LT201700011 issued on August 22, 2017 contains

7001400 pieces of LED panel lights; (3) bill of lading No. LT201700016LT201700012 issued on September 

5August 22, 2017 contains 6871400 pieces of LED panel lights; (4) bill of lading No. LT201700030LT201700016

issued on November 20September 5, 2017 contains 1939866 pieces of LED panel lights.; (5) bill of lading No. 

CSSZCC170932 issued on September 27, 2017 contains 10 pieces of LED panel lights; (6) bill of lading No. 

LT2017005 issued on July 26, 2017 contains 1388 pieces of LED panel lights; and (7) bill of lading No. LT2017006 

issued on July 26, 2017 contains 1394 pieces of LED panel lights.

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

5

party carriercarriers and obtained bills of lading for the shipments (the “LED Contract”). The 

address for consignee, IGLO, LLC, is at 4924 Cambridge Road, Fort Worth, TX 76155, the 

principal place of business of Defendant IGLO. The person to contact for the delivery is Sonny 

Menon that, upon information and belief, is Defendant Soneel Menon. The total contract price for 

the 40266500 pieces of LED panel lights is $141,715.20228,800. A true copy of the fourseven

bills of lading is attached hereto as Exhibit 2.

17. On or around December 19, 2017, IGLO emailed Plaintiff asking for quote on 2300 

pieces of UFO Highbay lights and Plaintiff responded with a proforma invoice providing a unit 

price of $65.00 each. The proforma invoice also provided for the deliver term as FOB and payment 

terms. A true copy of the proforma invoice is attached hereto as Exhibit 3.

18. Plaintiff arranged for two shipments of UFO Highbay lights for the total amount of

///

23002355 pieces2 through a third party carriercarriers and obtained bills of lading for the 

shipments on May 28, 2018 and March 14, 2018, respectively (the “UFO Contract”). The address 

for consignee, IGLO, LLC, is at 4924 Cambridge Road, Fort Worth, TX 76155, the principal place 

of business of Defendant IGLO. The person to contact for the delivery is Sonny Menon that, upon 

information and belief, is Defendant Soneel Menon. The total contract price for the 23002355

pieces of UFO Highbay lights is $149,500.00153,075. A true copy of the two bills of lading is 

attached hereto as Exhibit 4.

2 (1) Bill of lading No. WYTN8050428 issued on May 28, 2018 contains 1448895 pieces of UFO Highbay lights,; 

and (2) bill of lading No. WYTN8020372 issued on March 14, 2018 contains 15161460 pieces of UFO lights, 

among the total 2964 pieces, there were 2300 pieces UFO Highbay lights.

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

6

19. Both of the LED Contract and UFO Contract asked for payment after the receipt 

of goods, but Defendants never made the payments. Plaintiff tried to request for payments of the 

total amount of $291,215.20381,875 ($228,800 + $153,075) by reaching out to Defendant Soneel 

Menon on WeChat, but Soneel Menon indicated that he wanted to return the lights and refused to 

pay.

20. Plaintiff offered to pick up the lights at IGLO’s location but Defendant Soneel 

Menon asked for $100,000.00 labor fee without any legal basis. Defendant Soneel Menon also 

indicated that the lights had been sold and delivered to his customers.

21. After Plaintiff requested for accounting of the $100,000.00 labor fee, Defendants 

stopped responding and disappeared without ever tendering payments or returning the lights.

FIRST CAUSE OF ACTION

(Breach of Contract)

22. Plaintiff realleges and incorporates by reference each and every allegation set forth 

in the forgoing Paragraphs as though fully set forth herein and further alleges as follows.

23. The parties, for valuable consideration, entered into two separate valid and 

enforceable contracts on August 2017 and February 2018, respectively, providing for the 

shipments of 6500 pieces of LED panel lights and 23002355 pieces of UFO Highbay lights by 

Plaintiff in return for money payment by Defendants. Plaintiff performed but Defendants breached 

the duty to pay.

24. The essential elements in a breach of contract claim are: (1) the existence of a valid 

contract; (2) that the plaintiff performed or tendered performance; (3) that the defendant breached 

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

7

the contract; and (4) that the plaintiff was damages as a result of the breach. Frost Nat'l Bank v. 

Burge (Tex.Ct.App. 2000) 29 S.W.3d 580, 593.

25. The essential elements of a valid contract are: (1) an offer; (2) acceptance in strict 

compliance with the terms of the offer; (3) consideration; (4) mutual assent (meeting of minds) 

regarding material terms; (5) execution and delivery of the contract with the intent that it be mutual 

and binding. Sameera Arshad & Almorfa, LLC v. Am. Express Bank, FSB (Tex.Ct.App. 2019) 580 

S.W.3d 798, 804.

26. Defendants made an offer to purchase 6500 pieces of LED panel lights and 

23002355 pieces of UFO Highbay lights after receipt of quote from Plaintiff.

27. Plaintiff tendered the shipments with strict compliance with the offer in return for 

a total contract price of $291,215.20381,875. 

28. The determination of whether there is a meeting of minds is based on upon 

objective standards of what the parties said and did and not on their subjective state or mind. 

determined by the objective manifestations of the parties. City of The Colony v. N. Tex. Mun. 

Water Dist. (Tex.Ct.App. 2008) 272 S.W.3d 699, 720. “Meeting of minds” describes the mutual 

understanding and assent to the agreement regarding the subject matter and the essential terms of 

the contract. Id.

29. The parties had meeting of mind because they agreed to the quantity and price of 

the goods purchased, as well as the delivery and payment terms.

30. The contract was formed and Plaintiff finished performance when Plaintiff 

arranged for the shipments through third party carrier. 

31. Defendants neither made payment for the lights nor returned the lights. 

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

8

32. Defendants’ breach caused damages to Plaintiff in an amount exceeding 

$291,215.20381,875.

SECOND CAUSE OF ACTION

(Account Stated)

33. Plaintiff realleges and incorporates by reference each and every allegation set forth 

in the forgoing Paragraphs as though fully set forth herein and further alleges as follows.

34. Plaintiff is entitled to the payments for lights received by Defendants under account 

stated. 

35. A party is entitled to relief under the common law cause of action for account stated 

where (1) transactions between the parties which give rise to an indebtedness of one to the other; 

(2) an agreement, express or implied, between the parties fixes an amount due; and (3) the one to 

be charged makes a promise, express or implied, to pay the indebtedness. Dulong v. Citibank 

(S.D.), N.A. (Tex. Ct. App. 2008) 261 S.W.3d 890, 893. Arnold D. Kamen & Co. v. Young, (Tex.

Ct. App. 1971) 466 S.W.2d 381, 388.

36. [All] authorities agree that proof of plaintiff's delivery of goods or rendition of 

services to defendant and defendant's acknowledgment of a certain sum as due to plaintiff is 

sufficient for a prima facie case, without other proof of price, value, quantity, or specific items. 

Magic Carpet Co. v. Pharr (Tex. Civ. App. 1974) 508 S.W.2d 696, 697.

37. Because an agreement on which an account stated claim was based could be 

express or implied, the creditor did not have to produce a written contract as long as it was able 

to produce other evidence of the agreement between the parties to meet its burden of proof. 

Dulong supra, at 892. 

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

9

38. Defendants owe Plaintiff the payments for the LED and UFO lights delivered and 

received. Plaintiff has established a prima facie case for account stated by having provided the 

proof of four shipments of LED lights and two shipments of UFO lights with bills of lading. 

Defendants acknowledged the sum due to Plaintiff as the quote was given to Defendants prior to 

the shipments and the total value of lights shipped was stated on the bills of lading.

39. Defendant made a promise to pay for the lights by having failed to object for 

months and even years after receipt of the lights along with bills of lading stating the amount 

due. The court has, upon sufficient testimony, found that such statements and invoices were 

retained without objections an unreasonable length of time. Peurifoy v. Hood Rubber Products 

Co. (Tex.Civ.App. 1933) 59 S.W.2d 428, 430. The testimony supports the conclusion of the trial 

court that the defendants assented to the correctness of the accounts as submitted. Id. Express or 

implied assent is sufficient. Id.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment in its favor and against Defendants, as follows:

A. For money damages against Defendants for breach of contract in the sum of no less 

than $291,215.20381,875;

B. For an award to Plaintiff against Defendants for pre-judgment and post-judgment 

interest;

C. For an award of attorney’s fees pursuant to §38.001 of the Texas Civil Practice and 

Remedies Code;

D. For an award of costs to Plaintiff against Defendants; and

E. For such other relief as this Court may deem just and equitable.

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VERIFIED COMPLAINT YK LAW LLP 

445 S. FIGUEROA ST.

STE 2280

LOS ANGELES, CA 90071

(213) 401-0970

10

Dated: June 2September 16, 2022 YK LAW LLPRespectfully 

submitted,

By: /s/ Faye Deng 

Faye (Yifei) Deng (Cal. Bar No. 339284)

(pro hac vice admission pendingadmitted)

fdeng@yklaw.us

YK Law LLP

445 S. Figueroa St. Suite 2280

Los Angeles, CA 90071

fdeng@yklaw.us

Telephone: (213) 401-0970

Attorneys for Plaintiff Torshare Ltd

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VERIFICATION

I, [•], am the [•] of Torshare Ltd. in the foregoing matter captioned Torshare Ltd. v. 

IGLO, LLC et. al., filed in the United States District Court for the Northern District of Texas, 

and have authorized the filing of the complaint. I have reviewed the allegations made in the 

complaint and have personal knowledge of the allegations thereto, and if called upon to testify I 

could and would competently testify as to the matters stated therein.

I hereby declare and verify under penalty of perjury under the laws of the United States 

of America that the factual statements in the Verified Complaint are true and correct.

Executed on May 6, 2022 at Shenzhen, People’s Republic of China.

________________________.

CERTIFICATE OF SERVICE

I certified that on September 16, 2022, a true and correct copy of this pleading was served 

on all counsel of record by electronic service in accordance with the Federal Rules of Civil 

Procedure.

/s/ Faye Deng . 

Faye (Yifei) Deng

Case 4:22-cv-00482-BP Document 19-5 Filed 09/16/22 Page 11 of 11 PageID 132