IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

ABC CORPORATION I, 

ABC CORPORATION II, 

Plaintiffs, 

v. 

THE PARTNERSHIPS AND 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE A, 

Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

)

Case No. 20-cv-4806 

Judge Thomas M. Durkin 

Magistrate Judge Jeffrey Cole 

MEMORANDUM IN SUPPORT OF DEFENDANT AND THIRD-PARTY 

RESPONDENTS’ MOTION FOR IMPOSITION OF AN APPEAL BOND 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 1 of 16 PageID #:18168
i 

TABLE OF CONTENTS 

I. FACTUAL AND PROCEDURAL BACKGROUND .................................... 1

II. LEGAL STANDARD ....................................................................................... 2

III. ARGUMENTS .................................................................................................. 3

A. Plaintiffs Should Be Required to Post an Appeal Bond ...................................... 3

B. The Bond Amount Should be Sufficient to Cover All Appellate Costs. ............. 7

IV. CONCLUSION ............................................................................................... 10

CERTIFICATE OF SERVICE ............................................................................................. 12

 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 2 of 16 PageID #:18169
ii 

TABLE OF AUTHORITIES 

Case Page 

Adsani v. Miller, 

139 F.3d 67, 75 (2d Cir.1998)..........................................................................................2, 4 

Blessing v. Sirius XM Radio Inc., 

2011 WL 5873383, at *2 (S.D.N.Y. Nov. 22, 2011) ...........................................................3 

Egyptian Goddess, Inc. v. Swisa, Inc., 

543 F.3d 665, 678 (Fed. Cir. 2008).....................................................................................4 

Ethicon Endo–Surgery, Inc. v. U.S. Surgical Corp., 

 149 F.3d 1309, 1315, 47 USPQ2d 1272, 1275 (Fed.Cir.1998) ...........................................5 

Feingold v. Graff, 

No. 12-2999, 2013 U.S. App LEXIS 5737, at *17 (3d Cir. Mar. 22, 2013) ......................10 

Fleury v. Richemont N. Am., Inc., 

No. C–05–4525 EMC, 2008 WL 4680033, at *6 (N.D.Cal. Oct.21, 2008) ........................3 

Gorham Co. v. White, 

81 U.S. 511(1871) ................................................................................................................4 

In re Am. Invs. Life Ins. Co. Annuity Mktg. & Sales Pracs. Litig., 

 695 F. Supp. 2d 157, 166-67 (E.D. Pa. 2010) ......................................................................8 

See In re Cardizem CD Antitrust Litigation, 

 391 F.3d 812, 817–18 (6th Cir.2004) ..............................................................................3, 9 

In re Checking Acct. Overdraft Litig., 

No. 1:08-CV-23323-JLK, 2012 WL 456691, at *2 (S.D. Fla. Feb. 14, 2012) ................3, 4 

In re Gen. Elec. Co. Sec. Litig., 

998 F. Supp. 2d 145, 153 (S.D.N.Y. 2014)......................................................................3, 8 

In re Initial Pub. Offering Sec. Litig., 

 721 F. Supp. 2d 210, 212 (S.D.N.Y. 2010), opinion clarified, No. 21 MC 92 SAS, 

2010 WL 5186791 (S.D.N.Y. July 20, 2010) ..................................................................3, 6 

In re NASDAQ Market-Makers Antitrust Litig., 

187 F.R.D. 124, 128-29 (S.D.N.Y. 1999) ............................................................................4 

Miletak v. Allstate Ins. Co., 

2012 U.S. Dist. LEXIS 125426, at *2 (N.D. Cal. Aug. 27, 2012) .......................................8 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 3 of 16 PageID #:18170
iii 

O’Keefe v. Mercedes-Benz-USA, LLC, 

No. 01-cv-2902, 2003 U.S. Dist. LEXIS 9838 (E.D. Pa. 2003) ..........................................8 

Page v. AH Robins Co., 

85 F.R.D. 139, 139-40 (E.D. Va. 1980) ...............................................................................7 

Pedraza v. United Guaranty Corp., 

313 F.3d 1323, 1329–30 (11th Cir.2002) ............................................................................9

Sckolnick v. Harlow, 

820 F.2d 13, 15 (1st Cir. 1987) ........................................................................................4, 7 

Rules 

Fed. R. App. P. 7 ..............................................................................................................................2 

Wright, Miller & Cooper, Federal Practice & Procedure § 3953 (3d ed. 1999) ..............................8 

16A Charles Alan Wright, Arthur R. Miller & Edward H. Cooper, Federal Practice & 

Procedure § 3953 (3d ed.2006) .......................................................................................................9 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 4 of 16 PageID #:18171
1 

Defendant Gyroor-US (“Defendant” or “Gyroor-US”) and third-party respondents Gyroor, 

Urbanmax, GaodeshangUS, Fengchi-US, Gyroshoes, and HGSM (collectively, “Third-Party 

Respondents”) hereby submit this memorandum in support of their Motion for Imposition for an 

Appeal Bond. 

I. FACTUAL AND PROCEDURAL BACKGROUND 

On August 17, 2020, Plaintiffs Hangzhou Chic Intelligent Technology Co., Ltd. (“Chic”) 

and Unicorn Global, Inc.’s (“Unicorn”, and collectively with Chic, “Plaintiffs”) filed complaint 

against Defendant alleging that Defendant’s accused products infringe on their U.S. Design Patent 

Nos. D737,723 (“the ’D723 patent”), D738,256 (“the ’D256 patent”), D785,112 (“the ’D112 

patent”), and D784,195 (“the ’D195 patent”) (collectively, “Patents-in-Suit”). On November 19, 

2020, Plaintiffs amended their complaint. [Dkt. 101]. 

On November 20, 2020, Plaintiffs filed their first motion for preliminary injunction against 

Defendant, which was later granted by the Court. [Dkt. 105, 113]. 

On May 6, 2021, Plaintiffs filed a motion to amend their Schedule A to include Third-Party 

Respondents as defendants [Dkt. 227], which the Court granted on May 24, 2021. [Dkt. 253]. 

On May 24, 2021 and June 18, 2021, GaodeshangUS and Defendant filed an appeal to 

challenge the Court’s order granting Plaintiffs’ first motion for preliminary injunction. [Dkt.256, 

298]. 

On August 24, 2021, Plaintiffs filed a second motion for preliminary injunction against 

Third-Party Respondents. [Dkt. 384]. The Court granted Plaintiffs’ second preliminary injunction 

on October 6, 2021. [Dkt. 447, 456]. 

On October 8, 2021, Third-Party Respondents filed an appeal to challenge the Court’s order 

granting Plaintiffs’ second motion for preliminary injunction. [Dkt. 450]. 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 5 of 16 PageID #:18172
2 

On October 28, 2022, the Federal Circuit issued an opinion and vacated the Court’s order 

granting Plaintiffs’ motion to amend Schedule A and the two preliminary injunction orders issued 

by this Court. [Dkt. 587-590]. 

On November 9, 2022, Plaintiffs filed their renewed motion for temporary restraining order 

and preliminary injunction. [Dkt. 592]. This motion was denied by this Court on December 2, 

2022. [Dkt. 619]. 

On December 22, 2023, Defendant and Third-Party Respondents filed a notice of recent 

related decision informing the Court that a third-party petitioner has brought a petition in the 

United States District Southern District of New York to confirm an arbitration award and enter 

judgment against Plaintiffs for $3,057.294.79 in damages, $330,941.77 in pre-judgment interest, 

$44,298.97 in arbitral expenses, and $846.38 in post-judgment interest per day until the judgment 

is fully satisfied. [Dkt.683]. 

On January 12, 2024, Defendant and Third-Party Respondents’ motion for summary 

judgment of non-infringement was granted by the Court, and all Plaintiffs’ claims are dismissed. 

[Dkt. 686]. 

On February 8, 2024, Plaintiffs filed a notice of appeal to challenge Court’s order granting 

Defendant and Third-Party Respondents’ motion for summary judgment of non-infringement. 

[Dkt.691]. 

II. LEGAL STANDARD 

Federal Rule of Appellate Procedure 7 states: “In a civil case, the district court may require 

an appellant to file a bond or provide other security in any form and amount necessary to ensure 

payment of costs on appeal.” Fed. R. App. P. 7. Rule 7 exists to protect the rights of appellees by 

appellants who pose payment risks. See Adsani v. Miller, 139 F.3d 67, 75 (2d Cir.1998). “[T]he 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 6 of 16 PageID #:18173
3 

purpose of [an appeal bond] is to protect an appellee against the risk of nonpayment by an 

unsuccessful appellant.” Fleury v. Richemont N. Am., Inc., No. C–05–4525 EMC, 2008 WL 

4680033, at *6 (N.D.Cal. Oct.21, 2008) (quotations and citations omitted). 

The award and amount of an appeal bond is within the discretion of the district court. While 

the Seventh Circuit has not enumerated a test for when an appeal bond is appropriate, courts 

generally consider the following factors in determining whether an appeal bond is appropriate: (1) 

the appellant’s financial ability to post a bond; (2) the merits of the appeal; (3) whether the 

appellant has shown any bad faith or vexatious conduct; and (4) the risk that the appellant will not 

pay the costs if the appeal is unsuccessful. See, e.g., In re Gen. Elec. Co. Sec. Litig., 998 F. Supp. 

2d 145, 153 (S.D.N.Y. 2014); Blessing v. Sirius XM Radio Inc., 2011 WL 5873383, at *2 (S.D.N.Y. 

Nov. 22, 2011); In re Initial Pub. Offering Sec. Litig., 721 F. Supp. 2d 210, 212 (S.D.N.Y. 2010), 

opinion clarified, No. 21 MC 92 SAS, 2010 WL 5186791 (S.D.N.Y. July 20, 2010); In re Checking 

Acct. Overdraft Litig., No. 1:08-CV-23323-JLK, 2012 WL 456691, at *2 (S.D. Fla. Feb. 14, 2012). 

III. ARGUMENTS 

A. Plaintiffs Should Be Required to Post an Appeal Bond 

Plaintiffs are Presumed to Be Able to Afford a Bond 

Courts presume that appellants are financially able to post an appeal bond unless they 

demonstrate otherwise. In re Initial Pub. Offering Sec. Litig., 721 F. Supp. 2d at 213; In re 

Cardizem CD Antitrust Litigation, 391 F.3d 812, 817–18 (6th Cir.2004). Accordingly, Defendant 

and Third-Party Respondents need not prove that Plaintiffs can afford to post the bond Defendant 

and Third-Party Respondents have requested, and the burden is on Plaintiffs to come forward with 

sufficient financial information to prove that a bond is beyond their means. 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 7 of 16 PageID #:18174
4 

Regardless, Chic is a high-tech company that manufactures and licenses hoverboard 

products for sale in the United States, and Unicorn is the exclusive U.S. distributor of Plaintiffs’ 

products. [Dkt. 101]. Considered as one of the biggest hoverboard manufacturers and sellers in the 

world, Plaintiffs are liquid companies and should be financially able to post an appeal bond. 

[Dkt.399]. Further, Plaintiffs are represented by attorneys, and the appeal bond requirement should 

be an expected expense. Accordingly, this factor supports requiring Plaintiffs to post an appeal 

bond. 

Plaintiffs’ Appeal Lacks Merit and Will Likely be Unsuccessful 

Rule 7 authorizes the Court to forecast the outcome of the appeal in deciding whether to 

require a bond. See, e.g., Adsani, 139 F.3d at 79.; Sckolnick v. Harlow, 820 F.2d 13, 15 (1st Cir. 

1987); In re Checking, 2012 WL 456691, at *2; In re NASDAQ Market-Makers Antitrust Litig., 

187 F.R.D. 124, 128-29 (S.D.N.Y. 1999). The less likely it is an appeal will succeed, the stronger 

the case for a requiring a bond. Here, Plaintiffs’ appeal lacks merit and has no legitimate likelihood 

of success given the standard of review imposed on the appellate court. 

It is well settled that the “ordinary observer” is the “test for determining whether a design 

patent has been infringed.” Egyptian Goddess, Inc. v. Swisa, Inc., 543 F.3d 665, 678 (Fed. Cir. 

2008). The “ordinary observer” is a person that “gives such attention as a purchaser usually gives.” 

Id. at 670 (quoting Gorham Co. v. White, 81 U.S. 511(1871)). To prove infringement, a plaintiff 

must demonstrate by a preponderance of the evidence that “an ordinary observer, familiar with the 

prior art . . . would be deceived into believing the [accused product] is the same as the patented 

[product].” Egyptian Goddess, 543 F.3d at 681. As confirmed by the Federal Circuit and this Court 

multiple times, no reasonable juror could find that any of the accused products are substantially 

similar to any of the Patents-in-Suit in this case. 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 8 of 16 PageID #:18175
5 

First, as reversed by the Federal Circuit, Plaintiffs have failed to show a likelihood of 

success on the issue of infringement as they applied wrong legal standard, did not conduct the 

ordinary observer analysis through the lens of the prior art, and failed to apply the ordinary 

observer test on a product-by-product basis. [Dkt.587]. 

Second, Plaintiffs’ renewed motion for preliminary injunction was denied by this Court as 

Plaintiffs have failed to demonstrate a sufficient likelihood of success on the merit. [Dkt. 626]. 

The Court’s analysis demonstrates that a reasonable jury could find that the accused products are 

not substantially similar to the Patents-in-Suit, and such that an ordinary observer would not be 

deceived into believing that the accused products are the same as the Patents-in-Suit. Id. 

Third, Defendant and Third-Party Respondents’ motion for summary judgment of noninfringement was granted by this Court. [Dkt. 686]. In reaching this decision, the Court applied 

the ordinary observer test on a product-by-product basis finding that Plaintiffs and their expert 

incorrectly dismiss the significance of the details of the designs of the fenders, footpads, and lights, 

along with the style of the midpoint of the hourglass and concluded that Plaintiffs have failed to 

demonstrate a reasonable juror could find that any of the accused products are substantially similar 

to any of the Patents-in-Suit. Id. 

In conclusion, when the Federal Circuit review this Court’s grant of Defendant and ThirdParty Respondents’ summary judgment of non-infringement, there is nothing to suggest that this 

Court will be reserved on appellate review. Ethicon Endo–Surgery, Inc. v. U.S. Surgical Corp.,

149 F.3d 1309, 1315, 47 USPQ2d 1272, 1275 (Fed.Cir.1998). 

Plaintiffs Have Acted in Bad Faith and Vexatiously Throughout the Entire Case 

This case is objectively baseless and subjectively motivated by bad faith. Plaintiffs have 

filed and maintained this lawsuit not because they have a reasonable chance of prevailing on the 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 9 of 16 PageID #:18176
6 

merits, but because they hope to use this lawsuit as an anticompetitive weapon against Gyroor 

brand. 

For instance, Plaintiffs clearly knew or based on reasonable investigation should have 

known that Gyroor-brand Electric Roller Skates, also known as “hover shoes”, is not the subject 

to this action. However, one of Gyroor’s resellers, Yanjin-US, who solely sells hover shoes and 

never sold any hoverboards, was also restrained based on Plaintiffs’ preliminary injunctions. [Dkt. 

536]. 

Further, after the Federal Circuit vacated the preliminary injunction orders and determined 

that “even a cursory review of the four accused products shows that they are different from each 

other, display features not found in the asserted patents, and lack features shown in the asserted 

patents,” Plaintiffs again frivolously filed a renewed motion for temporary restraint order and 

preliminary injunction and tried to introduce a brand-new expert report to support their renewed 

preliminary injunction motion after the expert discovery closes. [Dkt. 592-598]. 

In addition, multiple facts in the current case indicate that Plaintiffs abused the judicial 

system in bad faith. First, Plaintiffs fraudulently obtained and enforced the preliminary injunction 

orders without giving Defendant and Third-Party Respondents any advance notice or opportunities 

to oppose. [Dkt. 590]. Second, Plaintiffs fraudulently added new parties in its proposed order. [Dkt. 

383, 558]. Third, Plaintiffs fraudulently added new products in its proposed order. [Dkt. 456]. 

There is no plausible explanation for these “mistakes” other than Plaintiffs’ bad faith. 

Thus, to protect Defendant and Third-Party Respondents from any further bad faith conduct, 

the Court should impose an appeal bond on Plaintiffs. 

There is a Risk Plaintiffs Will Not Pay the Costs When the Appeal is Unsuccessful 

There is a substantial risk that the costs of appeal will not be paid unless a bond is required. 

First of all, Chic is located in China outside this Court’s physical jurisdiction. [Dkt. 101]. If the 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 10 of 16 PageID #:18177
7 

costs of appeal are not voluntarily paid, Defendant and Third-Party Respondents will be forced to 

institute a collection action in a different jurisdiction. See, e.g., In re Initial Pub. Offering Sec. 

Litig., 728 F. Supp. 2d at 293 (“Courts routinely find a substantial risk of non-payment under such 

circumstances, warranting an appeal bond.”). 

Further, the risk of nonpayment is compounded as a third-party petitioner has brought a 

petition in the United States District Southern District of New York to confirm an arbitration award 

and enter judgment against Plaintiffs for $3,057.294.79 in damages, $330,941.77 in pre-judgment 

interest, $44,298.97 in arbitral expenses, and $846.38 in post-judgment interest per day until the 

judgment is fully satisfied. [Dkt.683]. According to this petition, Plaintiffs even failed to pay the 

petitioner, Plaintiffs’ former attorney in this case, for a substantial portion of the service fees it 

rendered. Id. The outcome of this petition will likely have an impact on this case as Plaintiffs have 

not offered to guarantee payment of costs. In light of this risk, Plaintiffs should be required to post 

an appeal bond. 

In conclusion, each of these factors typically considered by courts in deciding whether to 

require an appeal bond supports requiring Plaintiffs to post a bond in this case. 

B. The Bond Amount Should be Sufficient to Cover All Appellate Costs. 

“The nature and amount of the bond is a matter left to the sound discretion of the district 

court.” Sckolnick, 820 F.2d at 15. The practical reality is that “[r]equiring too small a bond, or no 

bond at all, may encourage frivolous, time-consuming, harassing appeals.” Page v. AH Robins Co., 

85 F.R.D. 139, 139-40 (E.D. Va. 1980). The costs that can be included in a Rule 7 bond are not 

limited to costs defined by Rule 39. Pedraza v. United Guaranty Corp., 313 F.3d 1323, 1323 (11th 

Cir.2002). The district court has substantial discretion to determine the amount of a bond necessary 

to ensure the payment of costs on appeal. Id. at 1327; Sckolnick, 820 F.2d at 15. 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 11 of 16 PageID #:18178
8 

Defendant and Third-Party Respondents request that the amount of the bonds in this case be 

set to at least $100,000, representing security for expected appellate costs, administrative costs and 

attorneys’ fees during the length of the appeal period. 

First, the expected appellate costs, under Rule 39, is routinely included in appeal bonds. See, 

e.g., O’Keefe v. Mercedes-Benz-USA, LLC, No. 01-cv-2902, 2003 U.S. Dist. LEXIS 9838 (E.D. 

Pa. 2003) (including Rule 39(c) costs of copying, printing, and reproducing documents in an appeal 

bond); Wright, Miller & Cooper, Federal Practice & Procedure § 3953 (3d ed. 1999). Under the 

current circumstances, it is anticipated that appellate costs will be incurred during the appeal 

period, including the estimated costs for printing and copying briefs and other submissions, docket 

fees, and fees for transcripts, in the approximate amount of $5,000. 

Second, Courts have found that costs securable by a Rule 7 appeal bond can also include 

administrative expenses. See In re Gen. Elec. Co. Sec. Litig., 998 F.Supp.2d at 151 (noting that 

“the Court of Appeals may impose an award of damages on an appellant pursuing a frivolous 

appeal, and a district court may consider that likelihood is assessing the scope and amount of a 

Rule 7 Bond.”); In re Am. Invs. Life Ins. Co. Annuity Mktg. & Sales Pracs. Litig., 695 F. Supp. 2d 

157, 166-67 (E.D. Pa. 2010); Miletak v. Allstate Ins. Co., 2012 U.S. Dist. LEXIS 125426, at *2 

(N.D. Cal. Aug. 27, 2012) (approving $60,000 bond to account for “appellate costs and 

administrative costs.”). Under the current circumstances, it is anticipated that administrative 

expenses will be incurred during the appeal period, including fees for witnesses and travel 

expenses, in the approximate amount of $10,000. 

Third, the attorney’s fees should be included as a part of “cost of appeal” under Rule 7. The 

Seventh Circuit has not yet addressed this issue. Other Circuits are split on the question whether 

attorney’s fees are part of “cost of appeal” under Rule 7. An older, minority rule, used by the D.C. 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 12 of 16 PageID #:18179
9 

and Third Circuits and endorsed by the Wright, Miller & Cooper treatise, holds that the “costs 

referred to” in Rule 7 “are simply those that may be taxed against an unsuccessful litigant under 

Federal Appellate Rule 39, and do not include attorney’s fees that may be assessed on appeal.” In 

re Am. President Lines, Inc., 779 F.2d 714, 716 (D.C.Cir.1985) (per curiam) (footnote omitted); 

see also 16A Charles Alan Wright, Arthur R. Miller & Edward H. Cooper, Federal Practice & 

Procedure § 3953 (3d ed.2006). The more recent, majority rule, adopted by the Second, Sixth, 

Nineth and Eleventh Circuits, holds that a district court may order security for appellate attorney’s 

fees in a Rule 7 bond if they would be treated as recoverable costs under an applicable fee-shifting 

statute. See In re Cardizem, 391 F.3d at 817–18; Pedraza, 313 F.3d at 1329–30; Adsani,139 F.3d 

at 71. Finally, the First Circuit has held that a district court may require a Rule 7 bond covering 

appellate attorney’s fees if it concludes that the court of appeals might award attorney’s fees as 

costs under Rule 38 because the appeal is frivolous. Sckolnick, 820 F.2d at 15 (per curiam). 

The statute 35 U.S.C. § 285 provides the applicable fee-shifting here as “[t]he court in 

exceptional cases may award reasonable attorney fees to the prevailing party.” Including 

Defendant and Third-Party Respondents’ attorney’s fees in Plaintiffs’ appeal bond is proper under 

the current circumstance as it is likely to find that this case is exceptional and Plaintiffs’ appeal on 

the merit is frivolous as illustrated before. Defending any appeal, even a frivolous one, is both 

time-consuming and expensive. It is anticipated that the attorneys of Defendant and Third-Party 

Respondents are expected to spend between 120 to 200 hours preparing appellate briefs, oral 

arguments, and other submissions. With attorneys’ average hourly rates at $350, the total attorney 

fees incurred during the appeal period are estimated to range from approximately $42,000 to 

$70,000.

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 13 of 16 PageID #:18180
10 

Last, whatever amount this Court determines to be the appropriate amount of costs to include 

in the bond, it should be doubled. Federal Rule of Appellate Procedure 38 provides that “[i]f a 

court of appeals determines that an appeal is frivolous, it may...award just damages and single or 

double costs to the appellee.” See also Feingold v. Graff, No. 12-2999, 2013 U.S. App LEXIS 

5737, at *17 (3d Cir. Mar. 22, 2013). Given the record in this case, it is clearly that Plaintiffs’ 

conduct shows a lack of respect for the judicial process and their appeal lacks merit and is 

frivolous. Thus, the appeal bond amount should be doubled. 

IV. CONCLUSION 

For the foregoing reasons, Defendant and Third-Party Respondents respectfully request the 

Court enter an order requiring Plaintiffs to post an appeal bond and the appropriate total amount 

of the bond is at least $100,000. 

Date: 3/7/2024 

 

/s/ Na Zhang 

Na Zhang, Esq. 

GLACIER LAW LLP 

506 Second Ave., Ste 1516 

Seattle, WA 98104 

queena.zhang@glacier.law

206-397-8633 

GLACIER LAW LLP 

41 Madison Avenue, Ste 2529 

New York, NY 10010 

Wei Wang, Esq. 

wei.wang@glacier.law

332-777-7315 

GLACIER LAW LLP 

200 E. Randolph Dr., Ste. 5100 

Chicago, IL 60601 

Ruoting Men, Esq. 

ruoting.men@glacier.law 

Tianyu Ju, Esq.

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 14 of 16 PageID #:18181
11 

iris.ju@glacier.law

312-270-0413 

Attorneys for Defendant and 

Third-Party Respondents

 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 15 of 16 PageID #:18182
12 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this March 7, 2024, I electronically filed the foregoing file 

with the Clerk of Court using the CM/ECF system, and service was perfected on all counsel of 

record and interested parties through this system, which will deliver a true and correct copy of the 

foregoing documents via CM/ECF. 

Date: 3/7/2024 /s/ Na Zhang 

Case: 1:20-cv-04806 Document #: 707 Filed: 03/07/24 Page 16 of 16 PageID #:18183