HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO., LTD. and UNICORN 

GLOBAL, INC.,

Plaintiffs, 

v. 

THE PARTNERSHIPS AND 

UNINCORPORATED 

ASSOCIATIONS IDENTIFIED ON 

SCHEDULE A, ET AL., 

Defendants. 

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Case No. 20-cv-4806 

Judge Thomas M. Durkin 

Magistrate Judge Jeffrey Cole 

DECLARATION OF JING CUI IN SUPPORT OF A DECLARATION OF RICHARD F. 

BERO

I, Jing Cui, declare as follows: 

1. This declaration is based upon my personal knowledge of the facts stated herein 

or based on review of business records or documents prepared for declaration or in the regular 

course of business. If called as a witness, I could and would testify to the statements made 

herein. 

2. I am the vice president of Unicorn Global, Inc. (“Unicorn”). 

3. As Unicorn Global is a licensee of U.S. patents of Hangzhou Chic Intelligent Co., 

Ltd. (“Chic”), I am familiar with manufacturers of hoverboard parts, designers of hoverboards, 

and businesses supporting the hoverboard products in the city of Shenzhen in Guangdong 

Province of China. 

4. Jinyuan Lei, the manager of Unicorn, previously offered declarations dated 

August 14, 2020 and October 23, 2020 in support of a Declaration of Richard F. Bero. 

5. Mr. Lei previously provided sales information for the Patented Hoverboards from

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January 1, 2019 through December 11, 2019 and from January 1, 2020 through September 30, 

2020. Since September 30, 2020, average monthly sales of the Patented Hoverboards have been 

approximately 50% less than they were in the comparable months in 2019 and 2020. 

6. We believe reasons that the sales Patented Hoverboard decrease may include sales from 

Amazon stores such as Gyroor, Gyroor US, Jiangyou-US, Gyroshoes, Fengchi-US, HGSM, 

Gaodeshang-US, Urbanmax and their affiliated stores; and independent websites 

Gyroorboard.com, Gyroor.com, collectively (“the Gyroor Defendants”) that continue1 to sell 

infringing products during the pendency of the preliminary injunction. 

7. Unicorn considers the Gyroor Defendants to be direct competitors in the U.S. hoverboard 

market. 

8. We also believe the decreased Patented Hoverboard sales since September 2020 may be 

due in part to the unexpectedly high 2020 sales through September 2020, as described in Jinyuan 

Lei’s declaration dated October 23, 2020, which would have been a difficult sales pace to 

maintain based on Unicorn’s experience in and understanding of the U.S. hoverboard market. In 

other words, it is possible that the U.S. hoverboard market may have become oversaturated and 

demand for hoverboards may have decreased because so many hoverboards were sold in 2020 

through September. 

9. We further believe that supply chain issues with products imported from China and the 

significant increases in shipping costs for products imported from China may also be 

contributing to the decrease in hoverboard sales since September 2020. 

10. Since September 30, 2020, the average sales price per Patented Hoverboard has stayed 

approximately the same. 

11. During the pendency of this matter, Plaintiffs have reached settlement agreements with a 

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