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 CHRISTOPHER BINNS

IN OPPOSITION TO MOVING DEFENDANTS MOTION TO DISMISS

I, Christopher Binns, declare as follows: 

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

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

instant action. 

2. I am one of the attorneys representing Plaintiffs, and except otherwise stated to the 

contrary, I have personal knowledge of the following facts and if called as a witness, could and 

would testify as follows:

3. On or about November 25, 2020, Plaintiffs published copies of the preliminary 

injunction order, entered on November 24, 2020, and the Third Amended Complaint on a dedicated 

website (https://www.loeb.com/en/general/20-cv-4806). 

4. On or about December 28, 2020, Plaintiffs updated the dedicated website 

(https://www.loeb.com/en/general/20-cv-4806) and published copies of the modified preliminary 

injunction order, entered on December 23, 2020, and the Third Amended Complaint. 

Case: 1:20-cv-04806 Document #: 185-2 Filed: 03/03/21 Page 1 of 3 PageID #:5458
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5. On or about December 28, 2020, Plaintiffs, through counsel, served Defendant 

Gyroor US by email at ctd2020@outlook.com with the Third Amended Complaint, the modified 

preliminary injunction order, and expedited discovery requests. In response, a representative from 

Gyroor US expressly stated that the email was received but that the Hague Convention required 

service by mail. See Exhibit A (email response from Defendant Gyroor US acknowledging receipt 

of email). Due to clerical error, service to Defendant Gyroor US did not include a copy of the 

Summon issued by the Court. However, on or about January 29, 2021, Plaintiffs effectuated 

corrected service by email on Defendant Gyroor US and provided the Summons, Third Amended 

Complaint, and modified preliminary injunction order. 

6. On or about December 23, 2020, Plaintiffs, through counsel, served Defendant 

Tomoloo DX at tomoloo_online@126.com, Tomoloo TC at tchttomoloo@163.com, and Tomoloo 

Flagship at tomolooflag@126.com with the Third Amended Complaint, the modified preliminary 

injunction order, and expedited discovery requests. On or about January 29, 2021, Plaintiffs 

effectuated corrected service by email on the Tomoloo Defendants and provided the Summons, 

Third Amended Complaint, and modified preliminary injunction order. 

7. Plaintiffs were informed by counsel for eBay.com store Defendants carrie_yux-5, 

mijia_store, pauta60, smg-store, strongjennie, and 2013tankstrong001 that their supplier could be 

found at the following website: 

https://detail.1688.com/offer/558898374000.html&idx=0?spm=a312h.2018_new_sem.dh_002.1.

6bf91ff9bIR8Pj&file=558898374000.html&idx=0. See Exhibit B. Although the above webpage 

is mostly in Chinese, the following banner is displayed in English and unquestionably is related to 

Defendant Gyroor US: 

Case: 1:20-cv-04806 Document #: 185-2 Filed: 03/03/21 Page 2 of 3 PageID #:5459
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8. Attached as Exhibit C is a copy of the Volkswagen Group of America, Inc. v. 

Brandcar Store, et al., No. 20-cv-3131, (N.D. Ill Sept. 14, 2020) (Durkin, J.) decision cited to in 

the corresponding memorandum of law. 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing are true and correct. 

Date: March 3, 2021 /s/ Christopher Binns

New York, NY Christopher Binns

Attorney for Plaintiffs

Case: 1:20-cv-04806 Document #: 185-2 Filed: 03/03/21 Page 3 of 3 PageID #:5460