Exhibit 1 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 1 of 22 PageID #:8371
1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

HANGZHOU CHIC INTELLIGENT 

TECHNOLOGY CO., LTD. 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 ARTHUR TAN-CHI YUAN 

IN SUPPORT OF OPPOSITION TO MOTION TO VACATE 

I, Arthur Tan-Chi Yuan, declare as follows: 

1. I am an attorney licensed in Illinois and employed at the law firm Loeb & Loeb 

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

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

have firsthand knowledge of the statements below. If called as a witness, I could and would 

testify to the statements made herein. 

3. On October 20, 2020, Teri Novak, on behalf of Amazon, provided the account 

balances for various defendants in this matter, including Gyroor US. Ms. Novak also confirmed 

that day that those assets had been frozen. A true and correct copy of that correspondence is 

attached as Exhibit A. 

4. On November 25, Loeb & Loeb LLP launched a website containing the Third 

Amended Complaint, the preliminary injunction order, and contact information for Christopher 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 2 of 22 PageID #:8372
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Binns, who represented Plaintiffs. That web address is: https://www.loeb.com/en/general/20-cv4806. After the Court entered the modified preliminary injunction in December 2020, the web 

page was updated to replace the early order with the modified one. After Mr. Binns departed 

from Loeb & Loeb LLP, the contact information was removed from the web page. 

5. On December 4, Stephen Vegh left a voicemail for one of Plaintiffs’ attorneys of 

record to discuss this case. Mr. Binns subsequently communicated with Mr. Vegh. On 

December 6, Mr. Binns emailed Mr. Vegh with many case documents, including the Third 

Amended Complaint and the preliminary injunction moving papers and order. A true and correct 

copy of the transmittal email is attached as Exhibit B. Due to the large number of files in the zip 

file attached to this email, I have not included all of the attachments here. Instead, I am 

including only a true and correct copy of the version of Schedule A to the Third Amended 

Complaint that Mr. Binns sent Mr. Vegh on December 6, 2020. A true and correct copy of that 

schedule, as sent to Mr. Vegh on December 6, is attached as Exhibit C. The schedule shows that 

all defendant names, except for that of “GYROOR US,” were redacted. 

6. Mr. Binns and Mr. Vegh had subsequent correspondence, including on December 

28, 2020. On that day, Mr. Binns asked Mr. Vegh whether he would accept service on behalf of 

his clients, and Mr. Vegh stated that he would not. A true and correct copy of that 

correspondence is attached as Exhibit D. 

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

Executed on August 19, 2021 

Chicago, IL 

_/s/ Arthur Tan-Chi Yuan___________ 

Arthur T. Yuan 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 3 of 22 PageID #:8373
Exhibit A 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 4 of 22 PageID #:8374
This email originated from outside of Loeb's Network.

Christopher Binns

Attorney At Law 

345 Park Avenue | New York, NY 10154 

Direct Dial: 212.407.4213 | Fax: 646.349.1805 | E-mail: cbinns@loeb.com

Los Angeles | New York | Chicago | Nashville | Washington, DC | San Francisco | Beijing | Hong Kong | 

www.loeb.com

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 5 of 22 PageID #:8375
Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 6 of 22 PageID #:8376
Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 7 of 22 PageID #:8377
Arthur Yuan

Senior Counsel 

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

Direct Dial:312.464.3152 | Fax:312.896.9469 | E-mail:ayuan@loeb.com

Los Angeles | New York | Chicago | Nashville | Washington, DC | San Francisco |Beijing | Hong Kong | 

www.loeb.com

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 8 of 22 PageID #:8378
Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 9 of 22 PageID #:8379
Exhibit B 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 10 of 22 PageID #:8380
Christopher Binns

Attorney At Law 

345 Park Avenue | New York, NY 10154 

Direct Dial: 212.407.4213 | Fax: 646.349.1805 | E-mail: cbinns@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 #: 372-1 Filed: 08/20/21 Page 11 of 22 PageID #:8381
Exhibit C 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 12 of 22 PageID #:8382
SCHEDULE A

1

EBAY

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 13 of 22 PageID #:8383
SCHEDULE A

2

AMAZON

No. MERCHANT NAME MERCHANT SELLER ID ASIN

2. GYROOR US A57BIIPQ5F3FT B07PHFP8GB

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 14 of 22 PageID #:8384
SCHEDULE A

3

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 15 of 22 PageID #:8385
Exhibit D 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 16 of 22 PageID #:8386
No Christoper, as we discussed previously , it is my client's position that Plaintiff must comply with the Hague Service Conventio n. Quoting Christopher Binns <cbinn s@loeb.com>: 

No Christoper, as we discussed previously, it is my client's position that Plaintiff must comply with the Hague 

Service Convention. 

Quoting Christopher Binns <cbinns@loeb.com>:

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 17 of 22 PageID #:8387
Chris, please call me at this number...310-372-6191. Thanks 

----- Forwarded message from Stephen Vegh <svegh@veghlaw.com> ----- 

 Date: Thu, 10 Dec 2020 17:58:52 -0500 

 From: Stephen Vegh <svegh@veghlaw.com>

Subject: Re: Hangzhou Chic v. P'ships, Dkt. No. 20-CV-4806 

 To: Christopher Binns <cbinns@loeb.com>

 Cc: Adam Kelly <akelly@loeb.com>

Chris, 

Tomorrow at 11a works, please call me then. 

Steve 

Quoting Christopher Binns <cbinns@loeb.com>:

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 18 of 22 PageID #:8388
The inventor of the hoverboards your client manufactures or sells; 

The manufacturer (if your client is not the manufacturer); 

The importer;

Average selling price;

Sales since 1/1/2019; 

Units sold since 1/1/2019; and

The names of any other stores operated by your client. 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 19 of 22 PageID #:8389
Hi Christoper, please provide proposed license. How does 11a PST call on Thursday sound? 

Thank you, 

Stephen Vegh 

Quoting Christopher Binns <cbinns@loeb.com>:

Hi Stephen:

Per our conversation, please find attached all the relevant moving papers and orders 

relating to the Complaint, Temporary Restraining Order, and Preliminary Injunction Order.

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 20 of 22 PageID #:8390
I will send over a draft of a license agreement upon consolation with our client. Let’s touch 

base on Monday to schedule a call for later in the week.

All the best,

CB

Christopher Binns

Attorney At Law

345 Park Avenue | New York, NY 10154 

Direct Dial:212.407.4213 | Fax:646.349.1805 | E-mail:cbinns@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. 

 Stephen Z. Vegh, Esq. 

 1240 Rosecrans Ave. #120 

 Manhattan Beach, CA 90266 

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 21 of 22 PageID #:8391
 Tel: (310)980-7440 

www.veghlaw.com

svegh@veghlaw.com

 Stephen Z. Vegh, Esq. 

 1240 Rosecrans Ave. #120 

 Manhattan Beach, CA 90266 

 Tel: (310)980-7440 

www.veghlaw.com

svegh@veghlaw.com

----- End forwarded message -----

 Stephen Z. Vegh, Esq. 

 1240 Rosecrans Ave. #120 

 Manhattan Beach, CA 90266 

 Tel: (310)980-7440 

www.veghlaw.com

svegh@veghlaw.com

 Stephen Z. Vegh, Esq. 

 1240 Rosecrans Ave. #120 

 Manhattan Beach, CA 90266 

 Tel: (310)980-7440 

www.veghlaw.com

svegh@veghlaw.com

Case: 1:20-cv-04806 Document #: 372-1 Filed: 08/20/21 Page 22 of 22 PageID #:8392