Exhibit 2

Case: 1:20-cv-03542 Document #: 52-3 Filed: 09/02/20 Page 1 of 8 PageID #:3470
IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

OAKLEY, INC., 

 Plaintiff, 

 v. 

ALL-INBIKE, et al., 

 

 Defendants. 

Case No. 20-cv-03542 

Judge Robert W. Gettleman 

Magistrate Judge Young B. Kim 

PLAINTIFF’S FIRST SET OF REQUESTS FOR ADMISSIONS TO DEFENDANTS 

Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, Plaintiff Oakley, Inc. 

(“Oakley” or “Plaintiff”), by and through its counsel, hereby requests each of the Defendants 

identified herein to answer the following Requests for Admissions, separately and fully in writing 

under oath three (3) business days of receipt hereof pursuant to paragraph 6 of the Preliminary 

Injunction Order. [43] at ¶ 6. 

. 

 

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REQUESTS FOR ADMISSION 

Request for Admission 1. Admit that You own the Defendants’ Online Marketplaces. 

Request for Admission 2. Admit that You operate the Defendants’ Online 

Marketplaces. 

Request for Admission 3. Admit that You offered for sale and sold products infringing 

at least one of the Plaintiff’s patented designs. 

Request for Admission 4. Admit that You are not authorized to sell goods under the 

Oakley Design. 

Request for Admission 5. Admit that Your supplier is not authorized to sell goods 

under the Oakley Design. 

Request for Admission 6. Admit that You did not obtain an opinion from United States 

counsel about the legality of offering for sale each of the Infringing Products. 

Request for Admission 7. Admit that Your profits from the sale of the Infringing 

Products totals more than $100,000. 

 

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DEFINITIONS AND INSTRUCTIONS 

1. In addition to the definitions and instructions set forth in Fed. R. Civ. P. 36, the 

following definitions and instructions apply to the Requests for Admissions set forth above and 

should be considered as part of each such request: 

2. As used herein, “Defendant” shall include the following e-commerce stores 

identified by the Seller Aliases and Online Marketplaces. 

No. Online Marketplaces Seller Aliases 

2 aliexpress.com/store/133112 Comaxsun Pro Store

3 aliexpress.com/store/1762739 joto

4 aliexpress.com/store/1797271 TSO Cycling Store

6 aliexpress.com/store/1933048 Z&X Outdoors 

7 aliexpress.com/store/1973118 RUISIMO Official Store

8 aliexpress.com/store/3018204 BESTGIA Store 

9 aliexpress.com/store/3612004 Outdoor WH 

10 aliexpress.com/store/4050087 HonTuo Yundong

11 aliexpress.com/store/4248014 Gusenke Trading Store

12 aliexpress.com/store/4677043 moxilyn cycling store

14 aliexpress.com/store/4987311 ESHIHAN Store 

15 aliexpress.com/store/5108020 Mazatlan men glasses

16 aliexpress.com/store/5633311

My Protector Outdoor 

Store 

18 amazon.com/sp?seller=A1RA7T522XTPI1 LeCat 

20 ebay.com/usr/astorion astorion

21 ebay.com/usr/bikein-sport bikein-sport 

23 ebay.com/usr/crazybottle2-4 crazybottle2-4 

24 ebay.com/usr/cyclehk cyclehk

25 ebay.com/usr/goodjob2016 goodjob2016 

27 ebay.com/usr/meng_2018 meng_2018 

29 ebay.com/usr/mldzstore mldzstore 

30 ebay.com/usr/mmhuanghuiling1981 mmhuanghuiling1981

31 ebay.com/usr/omeibuyeu2019 omeibuyeu2019 

32 ebay.com/usr/wireless.expert wireless.expert 

33 wish.com/merchant/53d212534497c5724bb02e9e Pandoras Gearbox

34 wish.com/merchant/56322a08583ea10fe4aeeae2 Creative culture co LTD

35 wish.com/merchant/572f0cb4fbbec05936904483 rosemary.wedding

36 wish.com/merchant/5874f663838c484d5fbf3349 Happy day man

37 wish.com/merchant/58d08f09cc7101505ef4f233 Xu Xiugen shop 

38 wish.com/merchant/58e734388ee9e81057915a63 lisating1 

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39 wish.com/merchant/591c4c8950216c6281ad6e97 PINGUAN TRADING

40 wish.com/merchant/59535e512eac110e97ed8011

Ningbo Tuo Yu Trading 

Co., Ltd. 

41 wish.com/merchant/5a47606a0c47f3670666bca9 ChuhengElectronics

43 wish.com/merchant/5ae543991c256d2b06d490ff Eqwea 

44 wish.com/merchant/5aed24791c25001bd4fbee69 SireckSport 

45 wish.com/merchant/5b4446cc86152a5a179076b8 Green Night Story

46 wish.com/merchant/5d3afbe770327a55f1b53a64 ranxiaobai 

47 wish.com/merchant/5d40500172b0c9295c765ba5 yaxifei 

48 wish.com/merchant/5d467cc372b0c91446ffbb4b HJY Discount store

49 wish.com/merchant/5d4d5f268388976b46e6b6af Yaya Boutique Jewelry

3. These requests are addressed to each Defendant listed in Paragraph 2 and (a) its 

present or former directors, officers, employees, agents, representatives, accountants, 

investigators, consultants, attorneys, and predecessors or successors in interest and any parent, 

subsidiary, or affiliated entities; (b) any other person acting on Defendants’ behalf or on whose 

behalf Defendants acted; and (c) any other person otherwise controlled by Defendants, or which 

controls Defendants, or which is under common control with Defendants. 

4. As used herein, “Plaintiff” shall mean, unless otherwise indicated, Oakley, Inc., any 

of Plaintiff’s officers, directors, employees, agents and representatives, and all persons acting on 

Plaintiff’s behalf. 

5. As used herein, “Defendant” or “Defendants” or “You” or “Your” or “Yourself” 

shall be deemed to include the named owner(s) and/or operator(s) of Defendants’ Online 

Marketplaces and Defendants’ Financial Accounts, and (a) its present or former directors, officers, 

employees, agents, representatives, accountants, investigators, consultants, contractors, attorneys, 

and predecessors or successors in interest and any parent, subsidiary, or affiliated entities; (b) any 

other person acting on Defendants’ behalf or on whose behalf Defendants acted; and (c) any other 

person otherwise controlled by Defendants, or which controls Defendants, or which is under 

common control with Defendants. 

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6. As used herein, “Defendants’ Online Marketplaces” shall be deemed to include the 

online marketplaces listed in Paragraph 2. 

7. “Lawsuit” or “Litigation” shall mean the lawsuit captioned Oakley, Inc. v. AllInbike, et al., Case No. 20-cv-03542, filed on June 17, 2020, in the U.S. District Court for the 

Northern District of Illinois. 

8. “Complaint” shall mean the Complaint and Amended Complaint filed by Plaintiff 

in the Lawsuit. 

9. As used herein, the “Oakley Design” shall refer to Plaintiff’s registered patented 

design, as shown in the Lawsuit Complaint. 

10. As used herein, “Plaintiff’s Products” shall mean any product offered for sale or 

sold using, relating to, featuring or bearing the Oakley Design and/or designs identical with, or 

substantially similar to, the Oakley Design as defined in Paragraph 9. 

11. As used herein, “Infringing Products” shall mean products offered for sale or sold 

using, relating to, featuring or bearing a third-party patented design on the product regardless of 

when it became known or was alleged You were using a third-party patented design. 

12. The singular form of a word should be interpreted in the plural, as well. Any 

pronoun shall be construed to refer to the masculine, feminine, or neuter gender as in each case is 

most appropriate. The words “and” and “or” shall be construed conjunctively or disjunctively, 

whichever makes the request most inclusive. 

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Dated this 27th day of August 2020. Respectfully submitted, 

/s/ Justin R. Gaudio 

Amy Ziegler 

Justin R. Gaudio 

Jake M. Christensen 

Thomas J. Juettner 

Greer, Burns & Crain, Ltd. 

300 South Wacker Drive, Suite 2500 

Chicago, Illinois 60606 

312.360.0080 

312.360.9315 (facsimile) 

aziegler@gbc.law 

jgaudio@gbc.law 

jchristensen@gbc.law 

tjjuettner@gbc.law 

Counsel for Plaintiff Oakley, Inc.

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CERTIFICATE OF SERVICE 

 I hereby certify that on this 27th day of August 2020, a copy of the foregoing was served 

via electronic mail on the e-mail addresses identified in Exhibit 2 to the Declaration of Jason 

Groppe and any e-mail addresses provided for Defendants by third parties. 

/s/ Justin R. Gaudio 

Amy Ziegler 

Justin R. Gaudio 

Jake M. Christensen 

Thomas J. Juettner 

Greer, Burns & Crain, Ltd. 

300 South Wacker Drive, Suite 2500 

Chicago, Illinois 60606 

312.360.0080 

312.360.9315 (facsimile) 

aziegler@gbc.law 

jgaudio@gbc.law 

jchristensen@gbc.law 

tjjuettner@gbc.law 

Counsel for Plaintiff Oakley, Inc.

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