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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO., LTD., and UNICORN

GLOBAL, INC.,

 Plaintiff,

 v.

THE PARTNERSHIPS AND 

UNINCORPORATED ASSOCIATIONS

IDENTIFIED ON SCHEDULE A,

 Defendants.

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Case No. 1:20-cv-04806

Hon. Thomas M. Durkin

DECLARATION OF STEPHEN Z. VEGH IN SUPPORT OF MOVING 

DEFENDANTS’ MOTION TO DISMISS PLAINTIFFS’

THIRD-AMENDED COMPLAINT WITH PREJUDICE

I, Stephen Z. Vegh, declare as follows:

1. I am an attorney duly admitted to practice law in the State of California. I 

am the owner of the law firm Vegh IP Legal, attorney of record for Dongguan Saibotan 

Nengyuan Keji Co., Ltd., doing business under Amazon Seller ID “GYROOR US” 

(hereinafter referred to as “Moving Defendant”). I have recently been admitted pro hac 

vice in this matter before the United States District Court for the Northern District of 

Illinois, Eastern division. I have personal knowledge of the facts stated herein and if 

called upon as a witness, I could and would competently testify to the below facts which 

are personally known to me.

2. On or about December 11, 2020, I spoke with Plaintiffs’ counsel 

Christopher Binns about this matter. I advised him that it was my client’s position that 

Plaintiffs needed to effectuate service of process on Moving Defendant in compliance 

with the Hague Service Convention. I then asked Mr. Binns to identify specifically what,

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if any, investigation or other effort Plaintiff or their counsel had taken to determine 

whether or not the address for my client on its “GYROOR US” Amazon storefront was 

correct or not. I advised Mr. Binns that address was my client’s address in China. Mr. 

Binns responded that Plaintiffs were authorized by the Court to effectuate service by 

email and electronic publication. I asked Mr. Binns again what Plaintiffs or their counsel 

had done to verify in some form whether the address provided on the “GYROOR US” 

Amazon store was correct, or what if any investigation had been conducted specifically 

about Moving Defendant’s address. Mr. Binns parroted the same response as before. I 

responded to Mr. Binns that in view of his refusal to answer my question, Moving 

Defendant would be left with no choice but to file a Motion to Dismiss Plaintiffs’

Complaint against Moving Defendant with prejudice for failing to comply with the 

Hague Service Convention. Mr. Binns then acknowledged my comment and the 

conversation ended. 

3. Attached hereto as Exhibit “A” is a true and correct copy of a December 

30, 2020 email from Plaintiffs’ counsel Christopher Binns sent to ctd2020@outlook.com

advising the recipient “[w]e represent the Plaintiffs in the above-referenced action. Per 

the attached Preliminary Injunction Order, please find attached the Third Amended 

Complaint, the Preliminary Injunction Order, and Plaintiffs’ expedited discovery 

requests.” The second page of Exhibit A shows what documents Mr. Binns enclosed in 

the email, namely copies of the Third Amended Complaint and in part Exs. 1-4 thereto, 

Schedule A to the Third Amended Complaint, the December 23, 2020 Modified 

Preliminary Injunction Order, as well as Requests for Expedited Discovery. The 

documents enclosed by Mr. Chen were not translated into Chinese, nor do they include a 

copy of the Court-ordered “CHEAPAANZEE” Summons required by the December 23, 

2020 Modified Preliminary Injunction Order. 

4. Attached hereto as Exhibit “B” is a true and correct copy of an email 

exchange between myself and Mr. Binns on or about December 28. Mr. Binns inquired 

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whether I would “[accept] services on behalf of [my] clients.” I responded, “No 

Christopher, as we discussed previously, it is my client’s position that Plaintiff must 

comply with the Hague Service Convention.” 

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

that the foregoing is true and correct based upon my personal knowledge. Executed this 

15th day of January, 2021, in Redondo Beach, California.

By: /s/Stephen Z. Vegh

Stephen Z. Vegh

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