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, 

Defendants. 

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Case No. 20-cv-4806 

Judge Thomas M. Durkin 

Magistrate Judge Jeffrey Cole 

JOINT STATUS REPORT 

 Plaintiffs Hangzhou Chic Intelligent Technology Co., Ltd (“Chic”) and Unicorn Global, 

Inc. (“Unicorn”) (“Plaintiffs”) file this Joint Status Report, as ordered by the Court (Dkt. 89), on 

behalf of all parties and eBay, Inc. The substantive1 motions currently pending before the Court 

are as follows: 

 Plaintiffs’ Motion for Preliminary Injunction (Dkt. 80), as well as the related Plaintiffs’ 

Motions to Seal (Dkt. 83) and for Leave to File an Oversized Brief (Dkt. 84) 

 eBay, Inc.’s Motion to Stay the TRO (Dkt. 59) 

 eBay, Inc.’s Motion to Dissolve the TRO (Dkt. 56) 

As part of the continuing discussions between Plaintiffs and the parties and non-parties, 

Plaintiffs recently received discovery that may require Plaintiffs to withdraw the pending Motion 

for Preliminary Injunction (and related motions) and to seek leave to file a Third Amended 

 

1

 This list does not include pending motions to appear pro hac vice (Dkt. 86–88, 90) and a pending 

motion to continue (Dkt. 91), all of which are unopposed. 

Case: 1:20-cv-04806 Document #: 93 Filed: 10/28/20 Page 1 of 3 PageID #:3111
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Complaint. Specifically, discovery has raised questions as to whether venue is proper as to some 

of the Defendants, whom Plaintiffs contend they believed in good faith were based outside of the 

United States, but who may, in fact, be based in the United States, in districts outside of the 

Northern District of Illinois. Plaintiffs are expeditiously evaluating this discovery and the proper 

course of action in light of the new information. 

As to eBay, Inc.’s motions, Plaintiffs and eBay, Inc. are continuing discussions and, 

without waiving any rights or arguments, Plaintiffs do not intend to enforce the TRO as to eBay, 

at least until after a hearing on a preliminary injunction motion has occurred. 

Therefore, at this time, no ruling is necessary on the pending motions, and the motions may 

be resolved cooperatively, without Court action, within a few days. Plaintiffs will submit an 

additional Joint Status Report by November 4, 2020. 

 

Case: 1:20-cv-04806 Document #: 93 Filed: 10/28/20 Page 2 of 3 PageID #:3112
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Date: October 28, 2020 Respectfully Submitted, 

LOEB & LOEB LLP 

By: /s/ Adam Kelly 

Adam Kelly 

Douglas 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 

Christopher Binns (admitted pro hac vice) 

LOEB & LOEB LLP 

345 Park Avenue 

New York, New York 10154 

Tel.: (212) 407-4000 

Fax: (212) 407-4990 

Email: cbinns@loeb.com 

Attorneys for Plaintiffs

Case: 1:20-cv-04806 Document #: 93 Filed: 10/28/20 Page 3 of 3 PageID #:3113