UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO. and UNICORN 

GLOBAL, INC.,

Plaintiffs,

v.

CHEAPAANZEE, et al., 

Defendants.

)

)

)

)

)

)

)

)

)

)

)

)

Case No. 20-cv-4806

Hon. Steven C. Seeger

Magistrate Judge Jeffrey Cole

FILED UNDER SEAL

SEALED TEMPORARY RESTRAINING ORDER

Plaintiffs Hangzhou Chic Intelligent Technology Co. and Unicorn Global filed an Ex 

Parte Motion for Temporary Restraining Order. This Court has reviewed Plaintiffs’ filings, 

including the summons, the Amended Complaint, the Second Amended Complaint, the 

accompanying declarations of Jinyuan Lei and Jaiwei Ying and their respective attached 

exhibits, the Ex Parte Motion for Temporary Restraining Order (“TRO”), including the request 

for a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery, and Motion 

for Electronic Service of Process Under Federal Rule of Civil Procedure 4(f)(3) (“Motions”) 

against the e-commerce stores operating under seller aliases identified in Schedule A to the 

Second Amended Complaint (collectively, “Defendant Internet Stores”). In light of the evidence 

before it, this Court hereby GRANTS Plaintiffs’ Motions as stated in this Order. 

The Court finds that, without adversarial presentation, it has personal jurisdiction over 

Defendants because they directly target their business activities toward consumers in the United 

States, including Illinois. Specifically, Plaintiffs have provided some basis to conclude that 

Defendants may have targeted sales to Illinois residents by operating one or more commercial, 

Case: 1:20-cv-04806 Document #: 42 Filed: 09/22/20 Page 1 of 6 PageID #:2541
2

interactive e-commerce stores through which Illinois residents can and have purchased products 

that infringe on U.S. Patent Nos. D737,723 (the “‘D723 patent”), D738,256 (the “‘D256 

patent”), D784,195 (the “‘D195 patent”), D785,112 (the “‘D112 patent”) (collectively, “Patentsin-Suit”). 

The Court finds that issuing this Order under Federal Rule of Civil Procedure 65(b)(1) is 

appropriate, because Plaintiffs have presented specific facts in the accompanying declarations 

and evidence that demonstrate Plaintiffs will suffer immediate and irreparable injury, loss, or 

damage if the adverse party can be heard in opposition. Specifically, in the absence of an ex 

parte TRO, Defendants could and likely would modify registration data and content, change 

hosts, redirect traffic to other websites in their control, and move any assets from accounts in 

U.S.-based financial institutions, including PayPal accounts, to offshore accounts. Proceedings 

against those who deliberately traffic in infringing merchandise are often ineffective if notice is 

given to the adverse party. Accordingly, this Court orders that: 

1. Defendants, their officers, agents, servants, employees, attorneys, and all persons 

acting for, with, by, through, under, or in active concert with them be temporarily enjoined and 

restrained from: 

a. offering for sale, selling, and importing any products not authorized by 

Plaintiffs and that include any reproduction, copy or colorable imitation of the 

design claimed in the Patents-in-Suit. 

b. aiding, abetting, contributing to, or otherwise assisting anymore in 

infringing upon the Patents-in-Suit; and

Case: 1:20-cv-04806 Document #: 42 Filed: 09/22/20 Page 2 of 6 PageID #:2542
3

c. effecting assignments or transfers, forming new entities or associations or 

utilizing any other device for the purpose of circumventing or otherwise avoiding 

the prohibitions set forth in subparagraphs (a) and (b). 

2. PayPal, Inc. (“PayPal”), Amazon Pay, Walmart Marketplace payment partner(s), 

and Payoneer.com (collectively the “Third Party Payment Providers”) that provide payment 

processing services to Defendants shall, within five (5) business days of receipt of this Order: 

a. locate all accounts and funds connected to Defendants or the Defendant 

Internet Stores, including, but not limited to, any email addresses and financial 

accounts connected to the information listed in Schedule A and any email 

addresses provided for Defendants by third parties; and

b. restrain and enjoin any such accounts or funds from transferring or 

disposing of any money or other of Defendants’ assets until further ordered by 

this Court.

3. Defendants and any persons in active concert or participation with them who have 

actual notice of this Order shall be temporarily restrained and enjoined from transferring or 

disposing of any money or other Defendants’ assets until further ordered by this Court. 

4. Plaintiffs shall work cooperatively with any third parties and make reasonable 

efforts to ease the burdens imposed by their request for expedited discovery. Upon Plaintiffs’ 

request, any third party with actual notice of this Order who is providing services for any of the 

Defendants or in connection with any of Defendant Internet Stores, including, without limitation, 

any online marketplace platforms, shall, within ten (10) business days after receipt of such 

notice, provide Plaintiffs expedited discovery, including copies of documents and records in such 

person’s or entity’s possession or control relating to: 

Case: 1:20-cv-04806 Document #: 42 Filed: 09/22/20 Page 3 of 6 PageID #:2543
4

a. the aliases, merchant tokens, identities, seller IDs, and locations of 

Defendants, their agents, servants, employees, attorneys, and any persons acting 

in concert or participation with them, including all known contact information and 

all associated e-mail addresses; 

b. the nature of Defendants’ operations and all associated sales, methods of 

payment for services and financial information, including, without limitation, 

identifying information associated with the Defendant Internet Stores and 

Defendants’ financial accounts, as well as information about Defendants’ sales 

and listing history related to their respective Defendant Internet Stores; 

c. any other online marketplace accounts registered by Defendants; and any 

financial accounts owned or controlled by Defendants, including their agents, 

servants, employees, attorneys, and any persons acting in concert or participation 

with them, including such accounts residing with or under the control of any 

banks, savings and loan associations, payment processors or other financial 

institutions, including without limitation, the Third Party Payment Providers, or 

other merchant account providers, payment providers, third party processors, and 

credit card associations, such as MasterCard and Visa. 

5. Plaintiffs are authorized to issue expedited written discovery upon Defendants 

under Federal Rules of Civil Procedure 33, 34, and 36. Plaintiffs are authorized to issue any 

such expedited discovery requests by e-mail. Defendants shall respond to any discovery requests 

within ten (10) days of being served by e-mail. The expedited discovery may relate to: 

a. the aliases, merchant tokens, identities, seller IDs, and locations of 

Defendants, their agents, servants, employees, attorneys, and any persons acting 

Case: 1:20-cv-04806 Document #: 42 Filed: 09/22/20 Page 4 of 6 PageID #:2544
5

in concert or participation with them, including all known contact information, 

including any and all associated e-mail addresses; and, 

b. the nature of Defendants’ operations and all associated sales, methods of 

payment for services and financial information, including, without limitation, 

identifying information associated with the Defendant Internet Stores and 

Defendants’ financial accounts, as well as providing a full accounting of 

Defendants’ sales and listing history related to their respective Defendant Internet 

Stores. 

6. Plaintiffs may provide notice of these proceedings to Defendants, including notice 

of the preliminary injunction hearing and service of process under Federal Rule of Civil 

Procedure 4(f)(3), and any future motions by sending an email to any email addresses provided 

for Defendants by third parties (such as online marketplace platforms, web hosts, internet search 

engines, or financial providers). The Court directs the Clerk of Court to issue a single original 

summons in the name of “CHEAPAANZEE and all other Defendants identified in the Second 

Amended Complaint” that shall apply to all Defendants. The combination of providing notice 

via electronic publication and e-mail, along with any notice that Defendants receive from 

payment processors, shall constitute notice reasonably calculated under all circumstances to 

apprise Defendants of the pendency of the action and afford them the opportunity to present their 

objections. 

7. Exhibits 1 and 2 of the Complaint; the Amended Complaint and the Second 

Amended Complaint and Exhibits 1, 2, 3, 4, and 5; Schedule A attached to the Complaint, the 

Amended Complaint, and the Second Amended Complaint; Plaintiffs’ Motion for entry of a 

Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, 

Case: 1:20-cv-04806 Document #: 42 Filed: 09/22/20 Page 5 of 6 PageID #:2545
6

and Expedited Discovery, and accompanying supporting memorandum, declarations of Jiawei 

Ying and Jinyuan Lei, and Plaintiffs’ Motion for Electronic Service of Process Under Fed. R. 

Civ. P. 4(f)(3), and accompanying supporting memorandum, declaration of Arthur Tan-Chi 

Yuan, and accompanying exhibits; Plaintiffs’ Notification of Affiliates; and Plaintiffs’ Notice of 

Claims Involving Patents, and this Order shall remain sealed until further ordered by this Court. 

8. Plaintiffs shall deposit with the Court ninety-four thousand dollars ($94,000) (that 

is, $10,000 per Defendant), either cash or surety bond, as security, which amount was 

determined adequate for the payment of such damages as any person may be entitled to recover 

as a result of a wrongful restraint hereunder, such bond to be deposited with the Court once inperson civil case hearings resume. 

9. Any Defendants that are subject to this Order may appear and move to dissolve or 

modify the Order as permitted by and in compliance with the Federal Rules of Civil Procedure 

and Northern District of Illinois Local Rules. Any third party impacted by this Order may move 

for appropriate relief. 

10. This TRO without notice is entered at 5:00 p.m. on September 22, 2020, and shall 

remain in effect for fourteen (14) days. 

Date: September 22, 2020 

Steven C. Seeger

United States District Judge

Case: 1:20-cv-04806 Document #: 42 Filed: 09/22/20 Page 6 of 6 PageID #:2546