IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO. and UNICORN 

GLOBAL, INC., 

Plaintiffs, 

v. 

THE PARTNERSHIPS AND 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE A, 

Defendants. 

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Case No. 20-cv-4806 

Judge Thomas M. Durkin 

Magistrate Judge Jeffrey Cole 

MOTION FOR 

AN ORDER TO SHOW CAUSE 

Under Federal Rule of Civil Procedure 37 and Local Rule 37.1 Plaintiffs Hangzhou Chic 

Intelligent Technology Co. and Unicorn Global, Inc. move this Court to enter an Order for 

Defendants Gyroor-US, Gyroor, Urbanmax, Fengchi-US, hgsm Storefront, Gaodeshang-US, 

Jiangyou-US, and Gyroshoes (“Gyroor Defendants”)1 to Show Cause as to why they should not 

be held in contempt of court under 18 U.S.C. § 401(3) for violation of the Preliminary Injunction 

order entered on December 23, 2020 (“PI”). 

 Counsel for the Gyroor Defendants have requested 21 days to respond to this motion. 

Plaintiffs believe that any responsive briefing should wait until issuance of any Order to Show 

 

1

 Gyroor-US (Dkt. 209), Urbanmax (Dkt. 225), Fengchi-US (Dkt. 296), Gaodeshang (Dkt. 254), 

and Gyroor (Dkt. 266) have appeared in this matter through counsel. Plaintiffs interpret Local 

Rule 37.1(a) as requiring personal service of an order to show cause on defendants who have not 

yet appeared. Therefore, Plaintiffs intend to wait until the issuance of an order to show cause, if 

any, before serving the non-appearing defendants, unless otherwise ordered by the Court. That is 

to say, unless otherwise ordered by the Court, Plaintiffs do not intend to serve these motion papers 

on non-appearing defendants. 

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Cause, as the opposition brief should effectively be the brief showing cause as to why the Gyroor 

Defendants should not be held in contempt under 18 U.S.C. § 401(3). If the Court believes 

briefing on this motion itself would be appropriate, Plaintiffs request no more than 7 days for the 

Gyroor Defendants’ opposition brief, due to ongoing infringement and irreparable harm. 

1. The PI order prohibits all Defendants, their affiliates, confederates, and those 

acting in active concert or participation with them from selling hoverboards that the Court 

determined were infringing on Plaintiffs’ design patents. See Dkt. 147, ¶ 1(a). The PI is explicit 

that defendants may not “effect[] assignments or transfers” or “form[] new entities or 

associations” to circumvent these prohibitions. Id., ¶ 1(c). 

2. Since the PI was entered, at least eighteen new stores have opened that 

exclusively sell the Gyroor Defendants’ enjoined products, rely on the Gyroor Defendants’ 

Amazon Standard Identification Numbers (ASIN), and even link back to the “Gyroor Store.” 

These stores typically close down a week after opening, so as to evade any enforcement action. 

3. Despite being on notice regarding these stores since March 2021, and despite 

having been alerted to the continued flow of new stores multiple times, new stores continue to 

emerge. The available evidence indicates that these stores are indeed affiliated with the Gyroor 

Defendants and sell enjoined products using Gyroor ASINs. 

4. Further, Gyroor Defendants have directly sold or offered to sell products, 

including from gyroorboard.com and the Gyroor-US Amazon storefront. 

5. Finally, the PI prohibits the Defendants and those acting in concert and 

participation with them from “from transferring or disposing of money or other Defendants’ 

assets until further ordered by this court.” Id., ¶ 3. 

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6. Yet, since entry of the PI, the Gyroor Defendants have collectively disposed of 

over $175,000 in assets from their restrained Amazon accounts. 

WHEREFORE, on the basis of the declarations of Jing Cui, Arthur Yuan, and Neil 

Nandi and accompanying exhibits, and Plaintiffs’ memorandum of law in support of this Motion, 

the Court should enter an order: 

1. Requiring the Non-Compliant Defendants to Show Cause as to why they should 

not be held in contempt of Court for violations of the PI order. Such an order should require 

each of the Gyroor Defendants to provide proof of: 

(a) Their connections to each of the temporary Amazon storefronts identified 

in the Declaration of Arthur Yuan; 

(b) Their connections to the “Gyroor Store” on Amazon; 

(c) Their connections to the gyroorboard.com website; 

(d) Their connections to one another; 

(e) The amounts in their Amazon accounts in October 2020, January 2021, 

March 2021, and at the present; and 

(f) A record of all sales of and profits from Infringing Products (as defined in 

the PI) from October 2020 to the present. 

2. If the Court ultimately determines that the Gyroor Defendants are in contempt of 

Court, the Court should impose one or more of the following sanctions on Gyroor Defendants: 

(a) Pay to Plaintiffs the full amount transferred from Amazon accounts since 

entry of the PI. 

(b) Pay to Plaintiffs the full amount of profits from infringing sales since this 

Court entered the Temporary Restraining Order. 

(c) Pay to Plaintiffs their cost and fees in filing this Motion and otherwise 

policing Gyroor Defendants’ conduct. 

(d) Pay to Plaintiffs a going-forward penalty of $1,000 for each day of noncompliance following entry of any contempt order. 

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Date: July 13, 2021 Respectfully Submitted, 

LOEB & LOEB LLP 

By: /s/ Adam Kelly 

Adam Kelly 

Doug Masters 

Arthur Yuan 

Neil Nandi 

321 North Clark Street, Suite 2300 

Chicago, Illinois 60654 

Tel.: (312) 464-3100 

Fax: (312) 464-3111 

Email: akelly@loeb.com 

Email: dmasters@loeb.com 

Email: ayuan@loeb.com 

Email: nnandi@loeb.com 

Marwa Abdelazuz (admitted pro hac vice) 

345 Park Avenue 

New York, New York 10154 

Tel.: (212) 407-4000 

Fax: (212) 407-4990 

Email: mabdelaziz@loeb.com 

Attorneys for Plaintiffs

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