EXHIBIT 8

Case: 1:20-cv-04806 Document #: 329-8 Filed: 07/13/21 Page 1 of 4 PageID #:7841
1

From: robin.cheng@glacier.law

Sent: Monday, July 12, 2021 8:50 AM

To: Neil Nandi; Tao?Liu; Tom.聽M; Iris Ju

Cc: Adam Kelly; Arthur Yuan; Marwa Abdelaziz

Subject: Re: RE: 20-cv-4806 - Motion for Order to Show Cause

This email originated from outside of Loeb's Network.

Neil,

Defendants require 21 days to file a response.

Plaintiffs can have 21 days to file a response to Defendants' motion for summary judgement. 

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: 2021-07-09 18:44 

To: robin.cheng@glacier.law; Tao聽Liu; Tom.聽M; Iris聽Ju

CC: Adam Kelly; Arthur Yuan; Marwa Abdelaziz

Subject: RE: 20-cv-4806 - Motion for Order to Show Cause

Robin,

We observe that Counsel had also previously advised us that they would be investigating or verifying 

allegations of non-compliance (see attached). We never received a response in two months, and similar noncompliance has continued as to more than a dozen additional short-term storefronts. Additionally,

Gyroorboard.com and Gyroor-US’s Amazon storefronts have been offering to sell and selling infringing

products, and Plaintiffs have been able to make purchases of Gyroor-branded products. We had previously

raised some of these issues, they were corrected, and now they have returned. Finally, as noted, your clients

have already substantially reduced the amounts in their Amazon accounts.

Case: 1:20-cv-04806 Document #: 329-8 Filed: 07/13/21 Page 2 of 4 PageID #:7842
2

If your clients seek to propose a briefing schedule, please propose one. We have already agreed to include 

such a proposal in the motion, so I do not know what there would be to discuss in a meet and confer. 

As to the motion for summary judgment, please advise on which claims which defendants will be moving. That 

affects the appropriate time for briefing. As you know, nearly no discovery has occurred in this 

matter. Therefore, denial under Rule 56(d)(1) may be appropriate. 

Best,

Neil

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

Sent: Friday, July 9, 2021 11:58 AM 

To: Neil Nandi <nnandi@loeb.com>; Tao聽Liu <tao.liu@glacier.law>; Tom.聽M <ruoting.men@glacier.law>; 

Iris聽Ju <iris.ju@glacier.law> 

Cc: Adam Kelly <akelly@loeb.com>; Arthur Yuan <ayuan@loeb.com>; Marwa Abdelaziz 

<mabdelaziz@loeb.com> 

Subject: Re: 20-cv-4806 - Motion for Order to Show Cause

 

Counsel, 

 

Please provide us with specific details regarding the alleged noncompliance, so we can investigate the 

situation further. 

I am available at 3:00 PM CT for a meet and confer session to discuss the briefing schedule. 

 

Defendants intend to file a motion for summary judgement on July 12, 2021. 

Please let us know if Plaintiffs would like to propose a briefing schedule. 

 

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: 2021-07-08 22:01

To: robin.cheng@glacier.law; Tao?Liu; Tom.聽M; Iris Ju

Case: 1:20-cv-04806 Document #: 329-8 Filed: 07/13/21 Page 3 of 4 PageID #:7843
3

CC: Adam Kelly; Arthur Yuan; Marwa Abdelaziz

Subject: 20-cv-4806 - Motion for Order to Show Cause

Counsel:

Tomorrow, Plaintiffs intend to file a motion for an order to show cause, relating to the Gyroor 

Defendants’ (Gyroor-US, Gyroor, Urbanmax, Fengchi-US, hgsm Storefront, Gaodeshang-US, JiangyouUS, and Gyroshoes) noncompliance with the preliminary injunction. We had previously raised issues 

with storefronts emerging for a week solely to sell infringing, Gyroor-branded products, before 

closing and being replaced the following week by a similar storefront. We have now identified more 

than a dozen instances of this occurring and continuing to occur. Additionally, we have identified 

direct sales or offers for sales by Gyroor-US and other Gyroor-branded stores. Finally, we have 

received evidence that Gyroor Defendants, including Gyroor-US, have already depleted over 

$100,000 in assets from Amazon accounts. Plaintiffs have raised issues with Gyroor-US’s noncompliance with the PI to Gyroor-US’s counsel on multiple occasions, yet the non-compliance has 

continued and expanded. Plaintiffs therefore believe a meet and confer would be futile. 

Plaintiffs believe that a briefing schedule is unnecessary given the nature of the motion, i.e., an 

opposition brief would effectively be the same as a response to the Court entering an order to show 

cause. If the Gyroor Defendants seek to propose a briefing schedule, however, please advise by 12 

PM CDT and we will include it in the brief. 

Best,

Neil 

Neil Nandi

Attorney At Law 

321 North Clark Street, Suite 2300 | Chicago, IL 60654 

Direct Dial:312.464.3109 | Fax:312.275.8505 | E-mail:nnandi@loeb.com

Los Angeles | New York | Chicago | Nashville | Washington, DC | San Francisco |Beijing | Hong Kong | www.loeb.com 

 

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages 

attached to it may contain confidential information that is legally privileged. If you are not the intended 

recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any 

disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is 

STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. 

Please destroy the original transmission and its attachments without reading or saving in any manner. Thank 

you, Loeb & Loeb LLP.

Case: 1:20-cv-04806 Document #: 329-8 Filed: 07/13/21 Page 4 of 4 PageID #:7844