EXHIBIT 3

Case: 1:20-cv-04806 Document #: 317-3 Filed: 07/02/21 Page 1 of 5 PageID #:7195
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Attachments: Hangzhou+(20-4806)+Amazon+Defendants+II (1).XLSX

From: Novak, Teri <TeriNovak@dwt.com> 

Sent: Wednesday, February 17, 2021 6:25 PM 

To: Christopher Binns <cbinns@loeb.com> 

Subject: RE: Hangzhou Chic et al. v. P'ships: 20-cv-4806 

This email originate d from outside of Loeb's Network. Here is the stores bala nce and e mail addresses. The accounts are frozen. T hank you, Teri Novak | Davis Wright Tremaine LLP Paralegal 920 Fifth Avenue, Suite 330 0 | Seattle, WA 98104 Tel: (206) 75 7-8729 

This email originated from outside of Loeb's Network.

Here is the stores balance and email addresses. The accounts are frozen.

Thank you,

Teri Novak | Davis Wright Tremaine LLP

Paralegal

920 Fifth Avenue, Suite 3300 | Seattle, WA 98104

Tel: (206) 757-8729 | Fax: (206) 757-7700 

Email: terinovak@dwt.com | Website: www.dwt.com

Anchorage | Bellevue | Los Angeles | New York | Portland | San Francisco | Seattle | Washington, D.C.

From: Christopher Binns

Sent: Tuesday, February 9, 2021 2:40 PM

To: Novak, Teri

Subject: RE: Hangzhou Chic et al. v. P'ships: 20-cv-4806

[EXTERNAL]

Thank you, and my apologies for being such a pest!

Christopher Binns

LOEB & LOEB LLP | ATTORNEY AT LAW

345 PARK AVENUE | NY, NY 10154

(212) 407-4213 |cbinns@loeb.com

From: Novak, Teri <TeriNovak@dwt.com> 

Sent: Tuesday, February 9, 2021 5:37 PM

To: Christopher Binns <cbinns@loeb.com> 

Subject: RE: Hangzhou Chic et al. v. P'ships: 20-cv-4806

Hi Chris,

The stores are in the process of being taken down as your request is in process.

Thank you,

Teri Novak | Davis Wright TremaineLLP

Paralegal

920 Fifth Avenue, Suite 3300 | Seattle, WA 98104

Tel: (206) 757-8729 | Fax: (206) 757-7700 

Email: terinovak@dwt.com | Website: www.dwt.com

Anchorage | Bellevue | Los Angeles | New York | Portland | San Francisco | Seattle | Washington, D.C.

From: Christopher Binns <cbinns@loeb.com> 

Sent: Tuesday, February 9, 2021 2:36 PM

Case: 1:20-cv-04806 Document #: 317-3 Filed: 07/02/21 Page 2 of 5 PageID #:7196
2

[EXTERNAL]

Hi Teri, 

Following up regarding the Tomoloo and Gyroor stores that are still selling infringing products on Amazon in violation of 

the preliminary injunction. 

We are renewing our request to have these stores taken down. 

All the best, 

CB

Christopher Binns 

LOEB & LOEB LLP | ATTORNEY AT LAW

345 PARK AVENUE | NY, NY 10154

(212) 407-4213 |cbinns@loeb.com

Christopher Binns

Attorney At Law 

345 Park Avenue | New York, NY 10154 

Direct Dial:212.407.4213 | Fax:646.349.1805 | E-mail:cbinns@loeb.com

Los Angeles | New York | Chicago | Nashville | Washington, DC | San Francisco | Beijing | Hong Kong | 

www.loeb.com

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may 

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immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any 

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From: Christopher Binns 

Sent: Wednesday, February 3, 2021 11:00 AM 

To: 'Novak, Teri' <TeriNovak@dwt.com> 

Subject: FW: Hangzhou Chic et al. v. P'ships: 20-cv-4806

Hi Teri, 

Following up on my email below regarding the Tomoloo and Gyroor stores, which are covered by the preliminary 

injunction order, but are still selling infringing products. I’ve also attached a spreadsheet identifying new stores that are 

selling these same infringing products. 

We are renewing our request per the Order that these stores be taken down. 

Thank you, 

CB

Christopher Binns 

LOEB & LOEB LLP | ATTORNEY AT LAW

345 PARK AVENUE | NY, NY 10154

(212) 407-4213 |cbinns@loeb.com

From: Christopher Binns 

Sent: Friday, January 29, 2021 10:33 AM 

To: Novak, Teri <TeriNovak@dwt.com> 

Subject: RE: Hangzhou Chic et al. v. P'ships: 20-cv-4806

Hi Teri, 

Case: 1:20-cv-04806 Document #: 317-3 Filed: 07/02/21 Page 3 of 5 PageID #:7197
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I hope all is well. Following up on my email below. 

1. Please take these ASINs/listings down. 

Listing link

https://www.amazon.com/dp/B08NDZ5HMV?aaxitk=L7Ceus5xDMAlKUn00v1nRw&pd_rd_plhdr=t&ref=dacx_dp_323768709010

https://www.amazon.com/dp/B08RYMXRWM

https://www.amazon.com/dp/B08NF4CYNQ

https://www.amazon.com/dp/B08KXWSTP1

https://www.amazon.com/dp/B07CZGSDX3

https://www.amazon.com/dp/B078H1YQPG

https://www.amazon.com/dp/B0798NC7VJ

https://www.amazon.com/dp/B07FFRSYCX

https://www.amazon.com/dp/B07JM6FT3H

https://www.amazon.com/dp/B08545YSM1

https://www.amazon.com/dp/B078JVPSP1

https://www.amazon.com/dp/B08SQ769Y2

https://www.amazon.com/dp/B079N86FZW

2. These stores are still selling infringing products in violation of the preliminary injunction.

Store Name Merchant ID Date Found

JIANGYOU-US A2WDDE8MIQH0TE Part of the PI

GYROOR AHGEGWXX7DCPQ Part of the PI

Lison ET A2NLQKWD7CGXGK Part of the PI

TOMOLOO AID3SH3YPRL1E Part of the PI

TOMOLOO-NX AK2XZM4Y8NUHN Part of the PI

TOMOLOO INE A2A3MNSAIX1437 Part of the PI

BETTER TOMOLOO A2UBVN107UWO9C Part of the PI

URBANMAX A2YJ4WYCO1L51J Part of the PI

AOXTECH A31C20NDSHBEPV Part of the PI

ShopCheapUniversal A3ABTK72L3LWCN Part of the PI

Fengchi-US A11ZZ2BGHTDJWC on or about 1/28/2021

Gyroor US A57BIIPQ5F3FT resurfaces on 1/28/2021

GaodeshangUS AYN6OZNVZ6M1Q on or about 1/28/2021

hgsm A18SI7S9NCFNDA on or about 1/28/2021

Smavt A15KLREW50H5QW on or about 1/28/2021

TOMOLOO-AOX or TOMOLOOAXAXGAWQK8OGS24 on or about 1/28/2021

3. These stores appear to have moved assets, please provide sales record:

Store Name Merchant ID Date Found

TOMOLOO FRANCHISE A345B08PGN8LUO Part of the PI

TOMOLOO-US A2FO3ELK9A4COF Part of the PI

Tomoloo Flagship A1ZP3NP8NRL3DB Part of the PI

TOMOLOO TC A1DXERU83AK4IX Part of the PI

TOMOLOO DX A23EA08Y88EE4M& Part of the PI

TOMOLOO INT A35351AV5611LB Part of the PI

Thank you and I look forward to hearing from you. 

All the best, 

CB

From: Christopher Binns 

Sent: Wednesday, January 27, 2021 9:41 AM 

Case: 1:20-cv-04806 Document #: 317-3 Filed: 07/02/21 Page 4 of 5 PageID #:7198
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To: 'Novak, Teri' <TeriNovak@dwt.com> 

Subject: RE: Hangzhou Chic et al. v. P'ships: 20-cv-4806

Hi Teri, 

Do you have a moment to discuss the Gyroor and Tomoloo related pages? I am available to discuss this at any time 

today. 

Thanks,

CB

Case: 1:20-cv-04806 Document #: 317-3 Filed: 07/02/21 Page 5 of 5 PageID #:7199