EXHIBIT 7

Case: 1:20-cv-04806 Document #: 317-7 Filed: 07/02/21 Page 1 of 3 PageID #:7229
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From: robin.cheng@glacier.law <robin.cheng@glacier.law>

Sent: Tuesday, May 25, 2021 10:54 PM

To: Neil Nandi <nnandi@loeb.com>

Cc: Adam Kelly <akelly@loeb.com>; Tao聽Liu <tao.liu@glacier.law>; Tom.聽M <ruoting.men@glacier.law>

Subject: Re: RE: 20-cv-4806 - Meet and Confer re Urbanmax

This email originated from outside of Loeb's Networ k. Subject to FRE 40 8Neil,Urbanmax is no t interested in resubmitting an affidavit at this poin t.Urbanmax will appeal the preliminary injunction order and seek damage accordingly .Regards, Robin Cheng | Attorney Glacier Law PLL 

This email originated from outside of Loeb's Network.

Subject to FRE 408

Neil,

Urbanmax is not interested in resubmitting an affidavit at this point.

Urbanmax will appeal the preliminary injunction order and seek damage accordingly.

Regards,

Robin Cheng | Attorney

Glacier Law PLLC

200 Park Avenue, Suite1703 

New York, NY 10166

www.glacier.law

Tel: +1 (332) 208-8882

Fax: +1 (312) 801-4587

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----

 

From: Neil Nandi

Date: 2021-05-25 17:15 

To: robin.cheng@glacier.law

CC: Adam Kelly; Tao Liu; Tom. M

Subject: RE: RE: 20-cv-4806 - Meet and Confer re Urbanmax

Robin,

We reviewed the affidavit that Urbanmax filed this morning. It differs in several material ways from the

affidavit we had discussed. Specifically, in Paragraph 3 of the joint status report filed by Plaintiffs and

Urbanmax (Dkt. 237), the parties state that the affidavit would state that Urbanmax is not “related to or

affiliated with Gyroor-US in any way” and “not acting in concert or participation with Gyroor-US or a related or

affiliated entity.”

Case: 1:20-cv-04806 Document #: 317-7 Filed: 07/02/21 Page 2 of 3 PageID #:7230
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The affidavit Urbanmax filed however, does not address: (1) being “related to” Gyroor-US “in any way”; (2) 

“acting in concert or participation”; and (3) any interactions or affiliations with entities that are “related or 

affiliated” with Gyroor-US. Instead, the affidavit Urbanmax filed is narrowly focused on Urbanmax’s 

“affiliat[ion]” with the specific “Gyroor-US” entity and its specific corporate owner (as stated in the affidavit). 

We respectfully request that Urbanmax submit a new affidavit that covers everything the parties had agreed 

to. Please let us know if you would like us to provide proposed language for the affidavit, to avoid any further 

issues. We have not yet served Urbanmax and, as a courtesy, we can refrain from doing so for the time being 

to permit Urbanmax the opportunity to correct. Plaintiffs do not require that the affidavit be filed with the 

Court (simply emailing us the signed affidavit is fine), though we respectfully request that the certification line 

also be updated to reflect the language from 28 U.S.C. 1746: “I declare under penalty of perjury under the laws 

of the United States of America that the foregoing is true and correct.” That is to say, we request that the 

knowledge qualifier be removed. 

Thank you very much. We are happy to discuss if needed. 

Best,

Neil

Case: 1:20-cv-04806 Document #: 317-7 Filed: 07/02/21 Page 3 of 3 PageID #:7231