IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO. and UNICORN 

GLOBAL, INC., 

Plaintiffs, 

v. 

THE PARTNERSHIPS AND 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE A, 

Defendants. 

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Case No. 20-cv-4806 

Judge Thomas M. Durkin 

Magistrate Judge Jeffrey Cole 

DECLARATION OF MARWA A. ABDELAZIZ 

IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO FENGCHI AND URBANMAX’S 

MOTION TO CLARIFY OR VACATE THE PRELIMINARY INJUNCTION 

 I, Marwa Abdelaziz, declare as follows: 

1. I am an attorney at law, duly admitted to practice before the Courts of the State of 

New York. I have been admitted pro hac vice to practice before this Court in the instant action. 

2. I have personally reviewed all materials provided in the attached Exhibits. If 

called as a witness, I could and would testify to the statements made herein. 

3. On December 4, 2020, attorney Stephen Vegh contacted Plaintiffs’ counsel, 

holding himself out to represent Gyroor. On December 6, 2020, Plaintiffs’ counsel sent Mr. Vegh 

a copy the relevant moving papers and orders relating to the Third Amended Complaint (in which 

all defendant names were redacted from the schedule except Gyroor-US), the Temporary 

Restraining Order, and the first Preliminary Injunction Order (“PI Order”), including the Notice 

of Motion for the PI Order. A true and correct copy of the December 2020 correspondences 

between Mr. Vegh and Plaintiffs’ counsel is enclosed as Exhibit 1. 

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4. In January 2021, Plaintiffs discovered the storefronts for Fengchi-US and 

Urbanmax (“Affiliated Defendants”). Plaintiffs believed Affiliated Defendants to be affiliates of 

Gyroor-US because Urbanmax was selling the same Gyroor-branded products as Gyroor-US, and 

Fengchi-US was offering to sell products that had Amazon Standard Identification Numbers 

(“ASIN”) associated with Gyroor-branded products. Plaintiffs also recently discovered a 

Facebook page for an entity called “Urbanmax Gyroor” that advertises Gyroor products and 

includes the description “Gyroor Sister Brand: Urbanmax.” A true and correct copy of these online 

screenshots are included as Exhibit 2.1

5. Plaintiffs requested that Amazon take down Affiliated Defendants’ stores and 

freeze their assets in compliance with the PI Order. Amazon informed Plaintiffs on February 17, 

2021, that Affiliated Defendants’ accounts had been frozen. A true and correct copy of the 

correspondences between Plaintiffs’ counsel and Amazon is enclosed as Exhibit 3. 

6. On February 16, 2021, then-counsel for Gyroor-US Danielle McKinley contacted 

Plaintiffs’ counsel to ask whether certain “storefronts” are involved in the case, including FengchiUS and Urbanmax. Plaintiffs had not discussed Affiliated Defendants with Gyroor-US’s counsel 

prior to February 16, 2021. On February 22, 2021, Plaintiffs’ counsel told Gyroor-US’s counsel 

that Fengchi and Urbanmax’s assets were restrained because they were “stores that we believe are 

related [to Schedule A defendants] and were discovered after filing the complaint.” Ms. McKinley 

followed up two days later, stating, “We would like to discuss potentially stipulating to a 

modification of the preliminary injunction...” A true and correct copy of these correspondences 

is enclosed as Exhibit 4. 

 

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 On the screen capture of the “Urbanmax Gyroor” Facebook page, Plaintiffs redacted 

images and names of individuals who appear to be following the page. 

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7. Again on March 3, 2021, Plaintiffs’ counsel and Gyroor-US’s then-counsel 

corresponded regarding the status of several entities believed to be Gyroor-US affiliates, including 

Fengchi and Urbanmax. Mr. Vegh asked Plaintiffs’ counsel to clarify which storefronts were 

named in Schedule A and which were categorized as “affiliates” for the purpose of streamlining 

discovery and coordinating future “motions to amend/vacate injunction orders.” Plaintiffs 

provided Mr. Vegh with a complete list of stores affiliated with Gyroor, which included Urbanmax 

and Fengchi-US. A true and correct copy of this email is enclosed as Exhibit 5. 

8. On May 4, 2021, the Glacier Law Firm (“Glacier”), which had replaced Mr. Vegh 

and Ms. McKinley as Gyroor-US’s counsel, appeared on behalf of Urbanmax. On May 10, 2021, 

the Court ordered Plaintiffs and Urbanmax to meet and confer regarding a potential motion to 

dismiss and file a joint status report. On May 13, 2021, Plaintiffs sent Urbanmax a proposed joint 

status report reflecting the contents of the meet and confer, in which Plaintiffs offered to drop 

Urbanmax as a defendant and remove any restraint on its assets on the condition that it provide an 

affidavit stating that Urbanmax was not acting in concert or related in any way to Gyroor-US or 

its affiliates. Urbanmax signed off on the proposed report and agreed to provide the requested 

affidavit on the evening of May 13, 2021. A true and correct copy of the correspondences between 

Urbanmax’s counsel and Plaintiffs’ counsel is enclosed as Exhibit 6. 

9. Urbanmax did not send the aforementioned affidavit on May 13, 2021. Rather, on 

May 25, 2021, Urbanmax filed an affidavit with the Court that was materially different from what 

the parties had agreed to on May 13, 2021. Plaintiffs’ counsel emailed Urbanmax’s counsel, 

informing them that the affidavit they submitted did not address: 1) being “related or affiliated” to 

Gyroor-US in any way; 2) “acting in concert or participation with Gyroor-US”; and 3) interactions 

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or affiliations with entities that are related or affiliated with Gyroor-US. A true and correct copy 

of this email is enclosed as Exhibit 7. 

10. Plaintiffs requested that Urbanmax resubmit their affidavit to address the 

deficiencies identified. Urbanmax responded that it was “not interested in resubmitting an 

affidavit at this point. Urbanmax will appeal the preliminary injunction order and seek damage 

accordingly.” To the top of this response, Urbanmax’s counsel appended the phrase “subject to 

FRE 408.” Effectively, Urbanmax elected to remain as a defendant rather than accept voluntary 

dismissal and unfreezing of its assets. Exhibit 7. 

11. On June 3, 2021, Glacier informed Plaintiffs’ counsel that it was representing 

Fengchi-US and requested a meet and confer on a motion to vacate the PI Order. Plaintiffs 

responded that they “are willing to offer Fengchi-US the same deal we offered Urbanmax and 

Gaodeshang.” Fengchi-US did not accept Plaintiffs’ deal. A true and correct copy of this 

correspondence is enclosed as Exhibit 8. 

12. On May 24, 2021, Glacier informed Plaintiffs’ counsel that “Defendant 

Runchenyun intends to file a motion to vacate preliminary injunction.” Runchenyun has since 

been voluntarily dismissed from this case. A true and correct copy of this email is enclosed as 

Exhibit 9. 

13. On May 25, Glacier informed Plaintiffs’ counsel that “Defendant Gyroor intends 

to file a motion to dismiss and;/or vacate preliminary injunction.” A true and correct copy of this 

email is enclosed as Exhibit 10. 

14. On June 3, 2021, Glacier stated that “Preliminary injunction was improper in this 

case against multiple Defendants.” Glacier stated that these multiple defendants planned to move 

to vacate the PI Order, without specifying which defendants he was referring to. After Plaintiffs’ 

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counsel asked Glacier to clarify which defendants were planning to move to vacate, Glacier 

explained that it was referring to “all five defendants currently represented by us, Gyroor, 

Runchenyun, Urbanmax, Gaodeshang and Fengchi-US.” Glacier proposed a briefing schedule 

that afforded Plaintiffs two weeks to respond. Plaintiffs countered that a three week response 

period would be more appropriate, given their belief that the motion was being filed on behalf of 

five differently situated defendants. Exhibit 8. 

15. On June 14, 2021, Glacier informed Plaintiffs’ counsel that “Eight Defendants 

(Tomoloo Flagship, Tomoloo TC, Tomoloo DX, Tomoloo INT, Tomoloo Official, TOMOLOO 

INE, TOMOLOO Franchise, TOMOLOO-US) will file a motion to vacate preliminary injunction 

based on lack of notice under Rule 65(a).” Glacier asked Plaintiffs if they would agree to file a 

response in two weeks. Plaintiffs responded that 30 days for a response brief would be more 

appropriate, given that, at the time, Glacier had represented that a total of thirteen defendants would 

be filing the motion to vacate. A true and correct copy of this email is enclosed as Exhibit 11. 

16. On June 16, 2021, Plaintiffs’ counsel and Defense counsel met and conferred on a 

number of topics, among them being the briefing schedule for a motion to vacate the PI Order. 

Glacier again represented that the eight Tomoloo Defendants would be included in the motion to 

vacate, therefore Plaintiffs insisted on a 30 day response time. The parties could not agree to a 

briefing schedule as Glacier would not agree to more than 15 days and Plaintiffs’ counsel would 

not agree to less than 25 days. This meet and confer was memorialized in an email sent to Defense 

counsel on June 17, 2021. A true and correct copy of this email is enclosed as Exhibit 12. At no 

time prior to filing did Glacier represent to Plaintiffs that only Fengchi-US and Urbanmax would 

be moving to vacate the PI Order. 

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I declare under penalty of perjury that the foregoing is true and correct. 

Date: July 2, 2021 /s/ Marwa Abdelaziz 

 New York, NY Marwa Abdelaziz 

 

Attorney for Plaintiffs 

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