IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF 

ILLINOIS EASTERN DIVISION

Case No. 20 cv 3490

MOTION TO ALTER OR AMEND JUDGMENT 

FROM COURT’S ORDER ON MAY 14, 2021

NOW COMES Plaintiff, Ouyeinc Ltd., by and through its attorneys, Barney & 

Karamanis, LLP, and respectfully moves this Honorable Court to reconsider, amend, and/or 

alter its Order of May 14, 2021, pursuant to Federal Rule of Civil Procedure 59(e).

ARGUMENT

1. On May 14, 2021, this Court entered its memorandum opinion & order ruling 

on Defendant’s Motion to Set Aside the Default Order. [Dkt# 134]. 

2. This Court denied the motion to set aside on basis of improper service, but 

granted the motion by reasoning that it lacked personal jurisdiction over the Defendants, 

Hailitech and Hxl_tech, thereby dismissing them from the suit. [Dkt# 133]. 

3. In light of this order, Plaintiff now moves this Court to reconsider its ruling to 

dismiss these Defendants. 

4. New facts have come to light that definitively show that these Defendants have 

sufficient minimum contacts within Illinois, and that this Court holds personal jurisdiction over 

OUYEINC LTD.,

Plaintiff,

v.

Alucy and et al.,

Defendants.

Case: 1:20-cv-03490 Document #: 135 Filed: 05/24/21 Page 1 of 4 PageID #:664
those Defendants. 

5. Plaintiff further believes that this Court’s ruling was in error when it did not 

account for the procedural basis for the Defendants’ motion, which only requested to set aside 

the judgment. 

6. Additionally, Plaintiff argues that the Court did not account for all relevant facts 

surrounding the action. 

7. As a result, Plaintiff respectfully requests that this Court amend and/or alter its 

ruling to dismiss Defendants Hailitech and Hxl_tech from the suit and to reinstate them as 

defendants to this action pursuant to Rule 59(e).

8. Plaintiff has attached its memorandum of law in support of this Motion to Alter 

and Amend along with the corresponding exhibits, which Plaintiff fully incorporates herein.

CONCLUSION

9. For the aforementioned reasons and argument, Plaintiff respectfully requests 

that this Honorable Court reconsider its May 14, 2021, ruling, and to revise that order to 

reinstate the Defendants Hailitech and Hxl_tech, find that this Court has personal jurisdiction 

over Defendants, or in the alternative permit jurisdictional discovery, evidentiary hearings, or 

grant other relief for Plaintiff as this Court deems just and proper.

Dated: May 24, 2021

Respectfully submitted,

/s/ Kenneth A. Nazarian______________

James A. Karamanis (Atty No. 6203479)

Kenneth A. Nazarian (Atty No. 6309765)

Trevor R. Jenkins (Atty No. 6329867)

Barney & Karamanis, LLP

Case: 1:20-cv-03490 Document #: 135 Filed: 05/24/21 Page 2 of 4 PageID #:665
180 N. Stetson, Ste 3050

Chicago, IL 60601

Tel.: 312/553-5300

James@bkchicagolaw.com

ken@bkchicagolaw.com

trevor@bkchicagolaw.com

ATTORNEY FOR PLAINTIFF Ouyeinc

Ltd.

Case: 1:20-cv-03490 Document #: 135 Filed: 05/24/21 Page 3 of 4 PageID #:666
CERTIFICATE OF SERVICE

I hereby certify that on May 24, 2021 a copy of the foregoing Motion to Alter or Amend 

Judgment from Court’s Order on May 14, 2021 was filed electronically. Notice of this filing 

will be sent by operation of the Court’s electronic filing system to all parties indicated on the 

electronic filing receipt. Parties may access this filing through the Court’s system. Under 

penalties of perjury, I certify that the above statements set forth herein are true and correct.

Respectfully submitted,

/s/ Kenneth A. Nazarian___________

 Counsel for Plaintiff

Barney & Karamanis, LLP

180 N. Stetson, Ste 3050

Chicago, IL 60601

Tel.: 312/553-5300

James@bkchicagolaw.com

ken@bkchicagolaw.com

trevor@bkchicagolaw.com

Case: 1:20-cv-03490 Document #: 135 Filed: 05/24/21 Page 4 of 4 PageID #:667