EXHIBIT 7

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 1 of 11 PageID #:7830
1

From: Iris Tianyu Ju <iris.ju@glacier.law>

Sent: Monday, May 3, 2021 6:20 PM

To: Neil Nandi; Adam Kelly; Arthur Yuan; Marwa Abdelaziz

Cc: tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

This email originated from outside of Loeb's Network.

Neil,

Thanks for the information. 

Just to be clear the account Gyroor-US (a.k.a. Dongguan Saibotan Nengyuan Keji Co. Ltd.) has complied 

with the Court's PI order.

We need to verify the information you provided. We will get back to you once we have more information 

regarding your allegation.

Regards,

Iris Ju | Attorney

Glacier Law PLLC

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 

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----

From: Neil Nandi <nnandi@loeb.com>

Date: Monday, May 3, 2021 at 7:35 AM

To: Iris Tianyu Ju <iris.ju@glacier.law>, Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>,

Marwa Abdelaziz <mabdelaziz@loeb.com>

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law>

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 2 of 11 PageID #:7831
2

Iris,

Following up on the issue of Gyroor’s non-compliance with the PI order, another Amazon storefront has been “just 

launched” as a platform for selling infringing Gyroor products, replacing the last such storefront. This continues the 

pattern we raised before: a storefront is launched that links to the main Gyroor Store on Amazon and exists exclusively 

to sell Gyroor products, including accused products. That store ceases sales after approximately one week, and a new 

“just launched” store takes its place. We respectfully request that Gyroor cease this practice, which is in violation of 

Section 1(c) of the PI order. 

Neil

From: Neil Nandi 

Sent: Friday, April 30, 2021 5:33 PM 

To: 'Iris Tianyu Ju' <iris.ju@glacier.law>; Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa 

Abdelaziz <mabdelaziz@loeb.com> 

Cc: tao.liu@glacier.law; robin.cheng@glacier.law 

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Iris,

We have raised Gyroor’s non-compliance with the PI order to Mr. Vegh multiple times. At the current time, we are 

aware of two significant categories of non-compliance. 

First, new stores keep launching on Amazon solely for the purposes of selling Gyroor products, including accused 

products. The current such store is kangjuxin-us 

(https://www.amazon.com/sp?_encoding=UTF8&asin=&isAmazonFulfilled=&isCBA=&marketplaceID=ATVPDKIKX0DER&

orderID=&protocol=current&seller=A3FGA3GPJLAIIE&sshmPath=). These stores all link back to the Gyroor Store on 

Amazon (https://www.amazon.com/stores/Gyroor/page/F7856CFC-6A58-4C64-8580-

51FFCB019EA1?ref_=ast_bln). Every time such a store closes, a new one emerges to take its place. These stores are in 

violation of Section 1(a) and 1(c) of the PI order. 

Second, Gyroor continues to offer for sale various accused products directly from Gyroor’s own websites (examples are 

shown in the attached screen captures). US customers may still view the products, the product details, and sign up for 

notifications regarding availability to purchase. Such offering for sale violates Section 1(a) of the PI order. 

As I have mentioned before, we had been discussing compliance with the PI order with Mr. Vegh. We would appreciate 

that your client address this non-compliance as soon as possible. 

Best,

Neil 

From: Iris Tianyu Ju <iris.ju@glacier.law> 

Sent: Thursday, April 29, 2021 7:44 PM 

To: Neil Nandi <nnandi@loeb.com>; Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa Abdelaziz 

<mabdelaziz@loeb.com> 

Cc:tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 3 of 11 PageID #:7832
3

Neil,

Thank you for your prompt response. 

GYROOR-US’s motion for failure to state a claim has been filed and incorporates a concurrently filed motion 

to dismiss under Rule 20 and Rule 21.

In terms of GYROOR-US’s non-compliance with the PI order, please kindly forward me the evidence. Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 <nnandi@loeb.com> 

Date: Thursday, April 29, 2021 at 2:42 PM 

To: Iris Tianyu Ju <iris.ju@glacier.law>, Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>, 

Marwa Abdelaziz <mabdelaziz@loeb.com> 

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law> 

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule 

Iris,

The proposed briefing schedule is agreeable. 

That said, we have some concerns that Gyroor’s motion practice is a dilatory tactic in violation of Rule 11. Gyroor 

previously filed and lost a motion under Rule 12(b). Gyroor’s answer was due on April 15. We permitted previous 

counsel an extension to file an answer to today. We are aware of no colorable legal basis under which a second motion 

to dismiss is timely. Additionally, as we previously stated to you, we have advised Mr. Vegh of Gyroor’s non-compliance 

with the PI order, which is continuing. What legal basis does Gyroor have for filing successive 12(b) motions? And does 

Gyroor intend to come into compliance with the PI order absent Court intervention? 

Best,

Neil

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 4 of 11 PageID #:7833
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From: Iris Tianyu Ju <iris.ju@glacier.law> 

Sent: Thursday, April 29, 2021 1:39 PM 

To: Neil Nandi <nnandi@loeb.com>; Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa Abdelaziz 

<mabdelaziz@loeb.com> 

Cc:tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Neil,

We will file a motion to dismiss based on Rule 12(b) for failure to state a claim. Please advise if the briefing 

schedule is agreeable: response due May 20, 2021; reply due June 7, 2021.

Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 <nnandi@loeb.com> 

Date: Wednesday, April 28, 2021 at 6:33 PM 

To: Iris Tianyu Ju <iris.ju@glacier.law>, Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>, 

Marwa Abdelaziz <mabdelaziz@loeb.com> 

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law> 

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule 

We agree to that schedule. 

Best,

Neil

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 5 of 11 PageID #:7834
5

From: Iris Tianyu Ju <iris.ju@glacier.law> 

Sent: Wednesday, April 28, 2021 5:33 PM 

To: Neil Nandi <nnandi@loeb.com>; Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa Abdelaziz 

<mabdelaziz@loeb.com> 

Cc:tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Neil,

Thank you for your email. We will propose the following briefing schedule: response due May 20, 2021; reply 

due June 7, 2021.

Please confirm if it is agreeable. Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 <nnandi@loeb.com> 

Date: Wednesday, April 28, 2021 at 1:27 PM 

To: Iris Tianyu Ju <iris.ju@glacier.law>, Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>, 

Marwa Abdelaziz <mabdelaziz@loeb.com> 

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law> 

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule 

We would appreciate three weeks to file a response brief. 

Best,

Neil

From: Iris Tianyu Ju <iris.ju@glacier.law> 

Sent: Wednesday, April 28, 2021 11:28 AM 

To: Neil Nandi <nnandi@loeb.com>; Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa Abdelaziz 

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 6 of 11 PageID #:7835
6

<mabdelaziz@loeb.com> 

Cc:tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Neil,

On behalf of GYROOR US, we will file motion pursuant to Rule 20, and Rule 21 and based on this motion, we 

will concurrently request the court to dissolve preliminary injunction.

Please advise the time Plaintiffs need for filing an opposition to this motion as we will have the motion filed by 

today. Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 <nnandi@loeb.com> 

Date: Wednesday, April 28, 2021 at 9:15 AM 

To: Iris Tianyu Ju <iris.ju@glacier.law>, Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>, 

Marwa Abdelaziz <mabdelaziz@loeb.com> 

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law> 

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule 

Iris,

Thank you for the confirmation of your representation. Plaintiffs would oppose any motion to dismiss on the basis of 

Rules 20 and 21, because we understand those rules not to provide dismissal as a remedy. To the extent Gyroor intends 

to file motions other than a motion to dismiss, please advise as to the relief sought and the basis for the 

relief. Depending on those considerations, we may be amenable to discussion of such other motions. 

On a separate note, we have been sending to Mr. Vegh many examples of what we understand to be Gyroor’s continued 

non-compliance with the PI order. As we told Mr. Vegh, Plaintiffs will seek relief from the Court as necessary to bring 

Gyroor into compliance. I assume Mr. Vegh has already shared those communications and discussions with you. Please 

advise as soon as possible regarding whether Gyroor will come into compliance. 

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 7 of 11 PageID #:7836
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Best,

Neil

From: Iris Tianyu Ju <iris.ju@glacier.law> 

Sent: Wednesday, April 28, 2021 10:15 AM 

To: Neil Nandi <nnandi@loeb.com>; Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa Abdelaziz 

<mabdelaziz@loeb.com> 

Cc:tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Neil,

This email is to confirm our representation of Gyroor US. Mr. Vegh and Ms. McKinley will withdraw as 

counsel for Gyroor US. 

Our proposed motion to dismiss is based on Rule 20(a) and Rule 21 of Federal Rule of Civil Procedure. I 

assume that Plaintiffs are going to oppose this motion, please advise Plaintiffs’ proposed schedule for filling 

such opposition and we can properly include the schedule in our motion. Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 <nnandi@loeb.com> 

Date: Wednesday, April 28, 2021 at 7:48 AM 

To: Iris Tianyu Ju <iris.ju@glacier.law>, Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>, 

Marwa Abdelaziz <mabdelaziz@loeb.com> 

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law> 

Subject: RE: 20-cv-04806 Joint Motion or Proposed Briefing Schedule 

Iris,

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 8 of 11 PageID #:7837
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Thank you for your email. We had been corresponding for months with Stephen Vegh and Danielle McKinley, who have 

filed appearances on behalf of Gyroor. We did not see any motions for substitution. We would appreciate clarification 

as to who represents Gyroor. We will be contacting Mr. Vegh and Ms. McKinley to ask the same question. 

Until we better understand the situation, we are not able to state our position on the proposed motions, about which 

we also have some questions. Mr. Vegh and Ms. McKinley previously filed a motion to dismiss on behalf of Gyroor, 

which the Court denied. The deadline to file Gyroor’s Answer was April 15, but we agreed to extend that deadline to 

April 29, as a courtesy. A new motion to dismiss would be inconsistent with that agreement. What is the basis for the 

new proposed motion to dismiss and how would it be timely? Similarly, what is the basis for the motion to sever and 

what specific relief is sought? As to the PI order, we had been discussing modification of the order with Mr. Vegh and 

Ms. McKinley, and we recently asked for specific proposals regarding modification. We had also been discussing 

compliance with the PI order with Mr. Vegh. Is Gyroor taking a different position now and, if so, what is the basis for its 

proposed motion to dissolve the PI order?

Thank you,

Neil

Neil Nandi

Attorney At Law 

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Thank you, Loeb & Loeb LLP.

From: Iris Tianyu Ju <iris.ju@glacier.law> 

Sent: Tuesday, April 27, 2021 11:44 PM 

To: Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Douglas Masters <dmasters@loeb.com>; Marwa 

Abdelaziz <mabdelaziz@loeb.com>; Neil Nandi <nnandi@loeb.com> 

Cc:tao.liu@glacier.law; robin.cheng@glacier.law

Subject: Re: 20-cv-04806 Joint Motion or Proposed Briefing Schedule

 

Dear Counsel, 

Please see updated case number, 20-cv-04806. Defendant GYROOR-US is going to file a motion to dismiss and 

sever under Rule 20(a) and Rule 21, and dissolve Preliminary Injunction. Please advise if you are going to 

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 9 of 11 PageID #:7838
9

oppose the motion and if any opposition is to be filed, please advise your proposed schedule for filling such 

opposition. Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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: Iris Tianyu Ju <iris.ju@glacier.law> 

Date: Tuesday, April 27, 2021 at 9:38 PM 

To: Adam Kelly <akelly@loeb.com>, Arthur Yuan <ayuan@loeb.com>, "dmasters@loeb.com" 

<dmasters@loeb.com>, Marwa Abdelaziz <mabdelaziz@loeb.com>, Neil Nandi <nnandi@loeb.com> 

Cc: "tao.liu@glacier.law" <tao.liu@glacier.law>, "robin.cheng@glacier.law" <robin.cheng@glacier.law> 

Subject: Re: 20-cv-05905 Joint Motion or Proposed Briefing Schedule 

Dear Counsel, 

Defendant GYROOR-US is going to file a motion to dismiss and sever under Rule 20(a) and Rule 21, and 

dissolve Preliminary Injunction. Please advise if you are going to oppose the motion and if any opposition is to 

be filed, please advise your proposed schedule for filling such opposition. Thanks.

Regards,

Iris Ju | Attorney

Glacier Law PLLC 

200 East Randolph, Suite 5100

Chicago, IL 60601

www.glacier.law

Tel: +1 (312) 448-7772

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 

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 10 of 11 PageID #:7839
10

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.

----

Case: 1:20-cv-04806 Document #: 329-7 Filed: 07/13/21 Page 11 of 11 PageID #:7840