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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

ABC CORPORATION I, ABC 

CORPORATION II., 

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 

DECLARATION OF ARTHUR TAN-CHI YUAN 

IN SUPPORT OF AN OPPOSITION TO JIANGYOU-US’S LACK OF PERSONAL 

JURISDICTION 

I, Arthur Tan-Chi Yuan, declare as follows: 

1. I am one of the attorneys for Plaintiffs Hangzhou Chic Intelligent Technology Co. 

and Unicorn Global, Inc. and am an attorney licensed in Illinois. 

2. I am a native speaker of Chinese and have personally reviewed all materials 

provided in the attached Exhibits and have firsthand knowledge of the statements below. If 

called as a witness, I could and would testify to the statements made herein. 

3. Jiangyou identifies its business name on its Amazon registration page as 

Shenzhen Jiangyou Jinchukou Youxian Gongsi. This is consistent with Jiangyou-US’s 

interrogatory response, which identified its business name as “Shenzhen Jiangyou Jinchukou 

Youxiangongsi.” “Jinchukou Youxian Gongsi” is phonetic translation of “Import Export Co., 

Ltd.” 

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4. In its Amazon registration page, the named defendant “Gyroor” (hereinafter, 

“Defendant Gyroor”) identifies its business name as “Shenzhen Chetaidou Keji Youxian 

Gongsi.” This is consistent with Defendant Gyroor’s interrogatory response, which identified its 

business name as “Shenzhen Chetadou Keji (Technology) Youxian Gongsi (Co., Ltd.).” “Keji 

Youxian Gongsi” is phonetic translation of “Technology Co., Ltd.” in Chinese. Exhibit 1 is a 

true and accurate reproduction of web capture that identifies the merchant information on 

Amazon.com. 

5. The US mark is also displayed on Defendant Gyroor’s 

Amazon merchant page and all infringing products associated with the eight Gyroor Defendants. 

6. The registered owner of US mark is Shenzhen Chitado 

Technology Co., Ltd. (“Chitado”). Exhibit 2 is a true and accurate reproduction of United States 

Trademark Certificate of trademark . The spelling of “Chitado” in the 

Trademark Certificate is slightly different from that of “Chetaidou” on Defendant Gyroor’s 

Amazon merchant page.. Slight spelling differences with similar phonetic pronunciations are not 

uncommon when translating the same word from Chinese script to the Latin alphabet. 

7. As a native Chinese speaker, I understand “Shenzhen Chitado Technology Co., 

Ltd.” to be the official English translation of the Chinese characters . 

Therefore, these Chinese characters refer to Defendant Gyroor. 

8. These Chinese characters are prominently displayed in 

the “about us” page on Gyroor.cn. Exhibit 3 is a true and accurate web capture of 

http://gyroor.cn/about. I added the English annotations to certain texts in Exhibit 3 to create 

Exhibit 4. 

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9. In Exhibit 4, annotations 1, 2 and 3 show where that the name 

appears on pages 1, 4, and 5. 

10. In Exhibit 3, the Chinese characters “ ” are also prominently 

displayed next to “GYROOR” in the header. 

11. The English phonetic translation of is “Jiangyou.” I have 

identified these characters in annotations on pages 4 and 5 in Exhibit 4. 

12. Exhibit 5 is a true and accurate reproduction of a web capture from the Chinese 

trademark office that lists classes of goods where is used as a trademark. I 

added the English translation to the heading (shown in red boxes) in pages 1 and 3 of Exhibit 5 

to create Exhibit 6. 

13. In particular, Exhibits 5-6 show that (i.e., Shenzhen 

Chitado Technology Co., Ltd.) owns the mark in about 49 different entries in 

various classes of goods and services. 

14. Exhibit 7 is a true and accurate reproduction of a web capture from the Chinese 

trademark office that lists classes of goods where GYROOR is used as a trademark. I added the 

English translation to the heading (shown in red boxes) on pages 1 and 3 of Exhibit 7 to create 

Exhibit 8. 

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15. In particular, Exhibit 7 shows that (i.e., Shenzhen 

Chitado Technology Co., Ltd.) owns the mark GYROOR in about 49 different entries in classes 

of goods and services. 

16. In addition, in an enterprise credit report from tianyancha.com, a newly created 

Chinese entity also bears the mark in its company name, 

. The English translation of that longer string of 

Chinese characters is “Shenzhen Jiangyou Business Management Partnership (Limited 

Partnership)” (emphasis added). 

17. The names of the shareholders of Shenzhen Jiangyou Business Management 

Partnership (Limited Partnership) match the names of the shareholders of Shenzhen Chitado 

Technology Co., Ltd (a/k/a Defendant Gyroor). Exhibit 9 is a true and accurate reproduction of 

a professional enterprise credit report generated on October 27, 2021 from tianyancha.com for 

“Shenzhen Jiangyou Business Management Partnership (Limited Partnership)” and Exhibit 11 is 

a true and accurate reproduction of a professional enterprise credit report generated on October 

27, 2021 from tianyancha.com for Shenzhen Chitado Technology Co., Ltd. I added the English 

translations to various texts (shown in red boxes) and identified these shareholders’ names in 

Exhibit 10 and Exhibit 12. 

18. The shareholders of Shenzhen Jiangyou Business Management Partnership 

(Limited Partnership) are and , as indicated on page 9. The 

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legal representative is , as noted on pages 9-10 of the PDF document. These 

names are marked by orange boxes throughout Exhibit 10. 

19. These two individuals are also noted in the corporate structure of Shenzhen 

Chitado Technology Co., Ltd (a/k/a Defendant Gyroor). I have marked these names with orange 

boxes on pages 12-15 of Exhibit 12. In fact, is also the legal representative of 

Shenzhen Chitado Technology Co., Ltd (a/k/a Defendant Gyroor). 

I declare under penalty of perjury that the foregoing is a true and correct. 

Executed on October 29, 2021, Chicago, IL. 

 /s/ Arthur Tan-Chi Yuan 

 Arthur T. Yuan. 

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