EXHIBIT 6

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 1 of 8 PageID #:7221
1

Attachments: Chic - 4806 - Plaintiffs-Urbanmax Status Report(1) - signed.docx

From: robin.cheng@glacier.law <robin.cheng@glacier.law>

Sent: Thursday, May 13, 2021 12:36 PM

To: Neil Nandi <nnandi@loeb.com>

Cc: Adam Kelly <akelly@loeb.com>; Tao Liu <tao.liu@glacier.law>; Tom. 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. Neil,I've signed the status report, please see attached. I'll forward you the affidavit this evening New Yor k time / morning Beijing time. Regards, Rob in Cheng | Attorney Glacier Law PLLC200 Park Avenue, Suite1703&nbs 

This email originated from outside of Loeb's Network.

Neil,

I've signed the status report, please see attached.

I'll forward you the affidavit this evening New York time / morning Beijing time. 

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

*Privilege and Confidentiality Notice*

This email is intended for the sole use of the intended recipient(s) and may contain confidential, proprietary, or

privileged information. If you are not the intended recipient, you are notified that any use, review,

dissemination, copying or action taken based on this message or its attachments, if any, prohibited. If you are

not the intended recipient, please immediately notify the sender by replying this email and destroy or delete all 

copies of the original message and any attachment. Thank you.

----

 

From: Neil Nandi

Date: 2021-05-13 12:22 

To: robin.cheng@glacier.law

CC: Adam Kelly; Tao Liu; Tom. M

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

Robin,

As discussed on Tuesday, Urbanmax is not a named defendant in this case. I have updated Paragraph 2 of the

proposed status report to reflect that Urbanmax is not included in Schedule B or C. As discussed, I do not think

we can dismiss Urbanmax if they are not a named defendant, though we believe the proposed draft offers to

fully remove Urbanmax from any connection to this litigation, upon receipt of the discussed affidavit. I have

added the second to last sentence in paragraph 4 to reflect that.

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 2 of 8 PageID #:7222
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Neil 

From: robin.cheng@glacier.law <robin.cheng@glacier.law> 

Sent: Thursday, May 13, 2021 10:47 AM 

To: Neil Nandi <nnandi@loeb.com> 

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

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

 

 

Neil, 

 

The complaint is against Defendants identified in Schedule A, and B, and C. 

The status report only stipulates that Urbanmax will be removed from the Proposed Amended Shcedule 

A. 

 

There is no way we can be certain that Urbanmax is not listed in Schedule B or C. 

Will Plaintiffs agree to dismiss Urbanmax from the case with prejudice? 

 

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

*Privilege and Confidentiality Notice*

This email is intended for the sole use of the intended recipient(s) and may contain confidential, 

proprietary, or privileged information. If you are not the intended recipient, you are notified that any 

use, review, dissemination, copying or action taken based on this message or its attachments, if any, 

prohibited. If you are not the intended recipient, please immediately notify the sender by replying this 

email and destroy or delete all copies of the original message and any attachment. Thank you.

----

 

From: Neil Nandi

Date: 2021-05-13 10:02

To: robin.cheng@glacier.law

CC: Adam Kelly

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

Robin,

We can certainly discuss providing those schedules, though the defendants in those schedules sit in a 

very different position to those in Schedule A. We therefore don’t see how they relate to Urbanmax 

or to the status report that is due today. Can you please let us know how you believe those schedules 

are relevant to Urbanmax or to the status report?

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 3 of 8 PageID #:7223
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We have not received any comments to the proposed status report we sent yesterday morning. We 

would like to have that on file by mid-day today. Please let us know if you agree with the proposed 

report so that we can file. If you do not agree, please promptly provide proposed edits.

Best,

Neil

From:robin.cheng@glacier.law <robin.cheng@glacier.law> 

Sent: Thursday, May 13, 2021 1:36 AM 

To: Neil Nandi <nnandi@loeb.com> 

Cc: Adam Kelly <akelly@loeb.com> 

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

 

 

Neil, 

 

While the affidavit is being prepared, please send us a copy of unredacted Schedule B and 

Schedule C. 

 

Regards, 

Robin 

 

From: Neil Nandi

Date: 2021-05-12 10:58

To: robin.cheng@glacier.law

CC: Adam Kelly

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

Robin,

Please see attached for a proposed status report, for filing tomorrow. If this is acceptable, 

please add your signature block. 

Best,

Neil

From: Neil Nandi 

Sent: Tuesday, May 11, 2021 10:45 AM 

To: 'robin.cheng@glacier.law' <robin.cheng@glacier.law> 

Cc: Adam Kelly <akelly@loeb.com> 

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

 

Robin,

Thank you for discussing. Per our conversation, if Urbanmax provides an affidavit stating 

that Urbanmax has no affiliation with or relation to Gyroor-US and that Urbanmax is not 

acting in concert or participation with Gyroor-US, Plaintiffs will: (1) request that Amazon 

unfreeze any frozen Urbanmax assets; and (2) include in the draft status report a request 

that Urbanmax no longer be included in the proposed amendment to Schedule A. In the 

event the Court grants the motion to amend, we will therefore remove Urbanmax from the 

new Schedule A before formally filing it. 

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 4 of 8 PageID #:7224
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Best,

Neil

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 5 of 8 PageID #:7225
IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO. and UNICORN 

GLOBAL, INC., 

Plaintiffs, 

v. 

THE PARTNERSHIPS AND 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE A, 

Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Case No. 20-cv-4806 

Judge Thomas M. Durkin 

Magistrate Judge Jeffrey Cole 

STATUS REPORT: PLAINTIFFS AND URBANMAX 

 In compliance with the Court’s order of May 10, 2021, Plaintiffs and Urbanmax met and 

conferred regarding Urbanmax’s status in the case. 

1. Urbanmax is not listed in the operative Schedule A of defendants. See Dkt. 101. 

Urbanmax has not been served. 

2. As discussed in the recently-filed declaration of Arthur Yuan, Plaintiffs had previously 

sought the restraint of Amazon assets of Urbanmax, due to Plaintiffs’ understanding that 

Urbanmax is related to Gyroor-US, which is a defendant named on the operative 

Schedule A. See Dkt. 227-1, ¶¶ 3, 13. For this reason, Plaintiffs have proposed adding 

Urbanmax to the proposed Amended Schedule A. See id.¶ 3. Urbanmax is not included 

on Schedule B or C. 

3. Counsel for Urbanmax has represented to Plaintiffs’ counsel that Urbanmax is not 

actually related to or affiliated with Gyroor-US in any way, and Urbanmax is not acting 

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 6 of 8 PageID #:7226
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in concert or participation with Gyroor-US or a related or affiliated entity. Plaintiffs have 

requested an affidavit from Urbanmax attesting to these facts. 

4. In the event Plaintiffs receive such an affidavit, Plaintiffs will: (1) promptly request that 

Amazon remove any restraint on Urbanmax’s assets; (2) no longer seek to include 

Urbanmax in the proposed Amended Schedule A; and (3) remove Urbanmax from the 

proposed Amended Schedule A at the time of formally filing it, if the pending motion to 

amend Schedule A is granted. These steps will end Urbanmax’s connection with this 

case and Plaintiffs will not seek to add Urbanmax to this case in the future. Because 

Plaintiffs have agreed to these steps, no motion practice with regards to Urbanmax is 

necessary at this time. 

Date: May __, 2021 Respectfully Submitted, 

LOEB & LOEB LLP 

By: /s/ 

Adam Kelly 

Doug 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 

Marwa Abdelazuz (admitted pro hac 

vice) 

345 Park Avenue 

New York, New York 10154 

Tel.: (212) 407-4000 

Fax: (212) 407-4990 

Email: mabdelaziz@loeb.com 

Glacier Law PLLC 

/s/ He Cheng 

He Cheng 

Tao Liu 

Tianyu Ju 

Glacier Law PLLC 

200 Park Avenue, Suite1703 

New York, NY 10166 

www.glacier.law

Tel: +1 (332) 208-8882 

Fax: +1 (312) 801-4587 

Email: Robin.Cheng@glaicer.law

Email: Tao.Liu@glacier.law

Email: Iris.Ju@glacier.law

Attorney for Urbanmax

Case: 1:20-cv-04806 Document #: 317-6 Filed: 07/02/21 Page 7 of 8 PageID #:7227
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Attorneys for Plaintiff 

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