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.

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Case No. 20-cv-4806

Judge Thomas M. Durkin

Magistrate Judge Jeffrey Cole

DECLARATION OF ARTHUR TAN-CHI YUAN

IN OPPOSITION TO MOVING DEFENDANTS MOTION TO DISMISS

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

1. I am an attorney at law, duly admitted to practice before the Courts of the States of 

Illinois. I have been admitted to practice before this Court in the instant action. 

2. I am one of the attorneys representing Plaintiffs, and except otherwise stated to the 

contrary, I have personal knowledge of the following facts and if called as a witness, could and 

would testify as follows:

3. On or about January 5, 2021, Plaintiffs purchased one infringing hoverboard from 

Tomoloo.com. 

4. In the order receipt, the merchant, identified by Chinese characters only along with 

an email address service@tomoloo.com (“Tomoloo email address”), and a phone number based in 

China due to the country code: +86 755 x29586605, fails to provide a ship-from address.

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5. On or about January 6, 2021, Plaintiffs received a confirmation email titled “Thank 

you for your purchase” from the sender “Tomoloo Official service@tomoloo.com.” No address 

is identified in the confirmation email that is associated with the sender “Tomoloo Official.”

6. On or about January 7, 2021, Plaintiffs received an email titled “Details about your 

shipment.” In addition to the shipping information provided, the seller is again identified by 

Chinese only. In addition, the email address associated with the seller has now changed to 

tomoloo2018@gmail.com. Again, no physical address is provided associated with the seller.

7. On or about February 24, 2021, Plaintiffs reviewed the Exchanges and Return 

policy posted on Tomoloo.com’s website at https://www.tomolooscooter.com/products/tomolooq2c-q3c-hoverboard?variant=29421522714733. Again, no physical return address is provided on 

that web page. 

8. On or about February 24, 2021, Plaintiffs emailed the Tomoloo email address

requesting a Return Merchandise Authorization (RMA) to initiate a return. In response, a 

representative, “Roxie” of “Tomoloo,” sent from the Tomoloo email address requested reasons for 

the return.

9. On or about February 26, 2021, Plaintiffs responded to “Roxie” by indicating a 

desire to change the color of the hoverboard. Another representative, “Vivian,” wrote back to 

explain the return policy and after indicating that the returned item needed to be unused, “Vivian”

provided a warehouse address in 100 John Hay Avenue, Kearny, NJ 07302 to receive the return.

10. A Google maps search of 100 John Hay Avenue, Kearney, NJ indicates that no such 

address exists. Upon entering the address, Google directed me to a Campy’s Express at 60 John 

Hay Avenue. An analysis of the John Hay Avenue revealed that 100 John Hay Avenue does not 

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exists, as it is a small dead-end street with no thru way with addresses ranging from 2 to 60 John 

Hay Avenue. 

11. Similarly, on or about January 4, 2021, Plaintiffs purchased one infringing 

hoverboard from gyroorboard.com.

12. In the order receipt, the merchant, identified by Chinese characters only along with 

an email address info@gyroorboard.com (“seller email address”). No ship-from address is 

provided.

13. On or about January 4, 2021, Plaintiffs received a confirmation email titled “Thank 

you for your purchase” from the sender “GYROOR.” No address is identified in the confirmation 

email. Another email address of service@gyroor.com (“Gyroor email address”) is provided for 

inquiries.

14. On or about January 27, 2021, a shipping confirmation email titled “A shipment 

from order . . . is on the way” again promptly identified the sender as “GYROOR” with the Gyroor 

email address as the sender address.

15. On or about February 24, 2021, Plaintiffs could not identify any physical address 

for returns. As a result, Plaintiffs emailed the Gyroor email address, along with other email 

addresses identified on the gyroorboard.com, to initiate a return. 

16. On or about February 26, 2021, after receiving an initial response from 

vicky@gyroor.com asking for the reasons for the return, Plaintiffs provided the reasons to 

vicky@gyroor.com and requested a return. 

17. Since then, Plaintiffs have not received any response.

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I declare under penalty of perjury under the laws of the United States of America that the 

foregoing are true and correct. 

Date: March 3, 2021 /s/ Arthur Tan-Chi Yuan

Hong Kong, S.A.R. Arthur T. Yuan

Attorney for Plaintiffs

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