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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

JOINT STIPULATION TO EXTEND TIME TO FILE PLEADINGS

Plaintiffs Hangzhou Chic Intelligent Technology Co. and Unicorn Global, Inc. 

(“Plaintiffs”), as well as Defendants Tomoloo Official, Tomoloo INE, Tomoloo Franchise, 

Tomoloo INT, and Tomoloo-US (“Answering Tomoloo Defendants”), by and through their 

attorneys of record in this case, stipulate and agree as follows:

1. On February 10, 2021, the Answering Tomoloo Defendants asserted counterclaims against 

Plaintiffs and filed answers and affirmative defenses to Plaintiffs’ Third Amended Complaint. See

Dkt. 170–174. Plaintiffs’ deadline to respond to these pleadings under Federal Rule of Civil 

Procedure 12 was March 3, 2021. 

2. On March 1, 2021, the parties met and conferred on several topics, including Plaintiffs’ 

stated intent to file motions to dismiss the counterclaims, strike the affirmative defenses, and strike 

the answers. The parties agreed to exchange additional information. The Answering Tomoloo 

Defendants also agreed to consider voluntary amendment of their counterclaims, affirmative 

defenses, and answers. 

Case: 1:20-cv-04806 Document #: 189 Filed: 03/15/21 Page 1 of 3 PageID #:5615
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3. For the purposes of avoiding potentially unnecessary motion practice, the parties agreed to 

extend Plaintiffs’ deadline to respond to the Answering Tomoloo Defendants’ pleadings until 

March 17, 2021, while the parties compiled the information and considered the positions discussed 

at the March 1, 2021 meet and confer. 

4. On March 2, 2021, this Court entered the parties’ stipulation providing the Plaintiffs until 

March 17, 2021, to respond to the Answering Tomoloo Defendants’ pleadings. That was the only 

prior extension of Plaintiffs’ deadline to respond to the Answering Tomoloo Defendants’ 

pleadings. 

5. To promote efficiency and judicial economy by avoiding unnecessary motion practice, the 

parties have agreed to allow the Answering Tomoloo Defendants the opportunity to voluntarily 

amend their Answers, Counterclaims, and Affirmative Defenses, without the need for Plaintiffs to 

respond to the pleadings filed by the Answering Tomoloo Defendants on February 10, 2021. 

6. Because the Answering Tomoloo Defendants’ Invalidity/Non-infringement contentions 

are due on March 19, 2021, the parties have agreed to provide the Answering Tomoloo Defendants 

until March 19, 2021 to file their Amended Answers, Counterclaims, and Affirmative Defenses.

7. In addition, the parties have agreed that Plaintiffs should have 21 days from the filing of 

the Answering Tomoloo Defendants’ Amended Answers, Counterclaims, and Affirmative 

Defenses to respond to the Answering Tomoloo Defendants’ pleadings. Therefore, Plaintiffs 

should have until April 9, 2021 to respond to the Answering Tomoloo Defendants’ pleadings.

NOW THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiffs and the 

Answering Tomoloo Defendants, thorough their respective attorneys, that the Answering Tomoloo 

Defendants will file amended answers, affirmative defenses, and counterclaims on or before March 

Case: 1:20-cv-04806 Document #: 189 Filed: 03/15/21 Page 2 of 3 PageID #:5616
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19, 2021; and that Plaintiffs may have until April 9, 2021 to respond to the Answering Tomoloo 

Defendants’ pleadings. 

Dated: March 15, 2021

Respectfully Submitted,

/s/ Neil Nandi

Adam Kelly

Doug Masters

Arthur Yuan

Neil Nandi

Loeb & Loeb LLP

321 North Clark Street, Suite 2300

Chicago, Illinois 60654

Tel.: (312) 464-3100

Fax: (312) 464-3111

Email: akelly@loeb.com 

Email: dmasters@loeb.com

Email: ayuan@loeb.com

Email: nnandi@loeb.com

Christopher Binns (admitted pro hac vice)

Loeb & Loeb LLP

345 Park Avenue

New York, New York 10154

Tel.: (212) 407-4000 

Email: cbinns@loeb.com

Attorneys for Plaintiffs

/s/ Danielle S. McKinley

Danielle Sylvia McKinley

RM Partners Law LLC

305 N. Peoria Street

Suite 200

Chicago, IL 60607

Tel.: (312) 251-2292

Email: dmckinley@rmpartnerslaw.com

Stephen Z. Vegh (admitted pro hac vice)

Vegh IP Legal

1240 Rosecrans Ave., Suite 120

Manhattan Beach, CA 90266

Tel.: (310) 980-7440

Email: svegh@veghlaw.com

Attorneys for Answering Tomoloo Defendants

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