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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ABC Corporation I et al,

Plaintiff,

v.

THE PARTNERSHIPS and 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE “A”,

Defendants.

CASE NO. 1:20-cv-04806

Judge: Honorable Thomas M. Durkin

DEFENDANT GYROOR-US’ MOTION FOR CLARIFIACTION

Defendant Gyroor-US (“Defendant” or “Gyroor-US”), by and through its counsel, moves 

this Court for a clarification of its Order on November 15, 2022 [Dkt. 603], regarding “G-11 model” 

hoverboard and requests as follow:

On or about June 19, 2022, Defendant Gyroor filed a motion to clarify the Preliminary 

Order [Dkt. 456] with the Court. Even though this Court denied Defendant Gyroor’s motion to 

clarify [Dkt. 560] as moot, it is still unclear whether the “G-11 model” hoverboard (ASIN 

B08RYMXRWM) is considered an accused products in this case.

“An injunction ‘must not be broader than the legal justification for its entry.’” Common 

Cause Ind. v. Lawson, 978 F.3d 1036, 1041 (7th Cir. 2020) (quoting Henderson v. Box, 947 F.3d 

482, 487 (7th Cir. 2020)). This Court also recognizes that the scope of the preliminary injunction 

is limited to Plaintiffs’ motion paper. [Dkt. 558, p. 2] (“review shows that Yanjin-US was included 

in the chart in the proposed order even though it was not mentioned in the motion papers. Thus, 

Yanjin-US should not have been referenced in the preliminary injunction order entered on October 

13, 202 1, R. 456.”).

Case: 1:20-cv-04806 Document #: 625 Filed: 12/09/22 Page 1 of 4 PageID #:15743
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Plaintiffs made no allegations as to Gyroor-brand products – “G-11 model” hoverboard. 

The “G-11 model” hoverboard should not be presumably infringing. The injunction should be 

limited to the products in Plaintiffs’ motion paper [Dkt. 384, 385].

First, Plaintiffs only alleged infringement against four types of Gyroor-brand products in 

their motion paper – “Gyroor A,” “Gyroor B,” “Gyroor C,” and “Gyroor D.” [Dkt. 384, §I.A.2. , 

pp. 26-27]. The injunction should be limited to those four accused products.

Second, the “G-11 model” has a distinct design from the other four accused products 

(“Gyroor A (T581 model),” “Gyroor B (G 2 Model),” “Gyroor C (T580 model),” and “Gyroor D 

(G 5 model)”). “G-11 model” is especially distinguishable because of its LED lit standing pedals 

and wheel covers. [See Dkt. 560,p.3].

Third, ASIN for “G-11 model” hoverboard (B08RYMXRWM) was only included in the 

chart “Exhibit B” of the proposed order [Dkt. 456, p. 15], even though the “G-11 model” 

hoverboard was never mentioned in Plaintiffs’ motion papers. On October 28, 2022, the proposed

Order ,[Dkt. 456] which includes the “G-11 model”, had been vacated by the Federal Circuit. As 

a result, the “G-11 model” is no longer an accused products in this litigation. Moreover, GyroorUS has never sold any of the “G 11 model” hoverboard [Dkt. 473].

On November 9, 2022, Plaintiffs filed another motion for Temporary Restraining Order 

and Preliminary Injunction, which includes the “G-11 model” in this new motion again [Dkt. 593].

On November 15, 2022, the Court denied Defendant Gyroor’s motion to clarify as moot; however, 

it is still unclear whether “G-11 model” is part of the accused products in this litigation. 

Therefore, Defendant respectfully requests this Court for clarification as to whether “G-11 

model” hoverboard (ASIN B08RYMXRWM) is the accused products in this litigation.

Case: 1:20-cv-04806 Document #: 625 Filed: 12/09/22 Page 2 of 4 PageID #:15744
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Date: 12/09/2022 /s/ Yu Hao Yao 

Yu Hao Yao, Esq. 

GLACIER LAW LLP

9660 Flair Dr., Ste 328 

El Monte, CA 91731 

mickey.yao@glacier.law

312-448-7772 

Glacier Law LLP

506 Second Ave., Ste 1516 

Seattle, WA 98104 

Na Zhang, Esq. 

queena.zhang@glacier.law 

206-397-8633 

GLACIER LAW LLP

200 E. Randolph Dr., Ste. 5100 

Chicago, IL 60601 

Ruoting Men, Esq. 

ruoting.men@glacier.law

Tianyu Ju, Esq. 

Iris.ju@glacier.law

312-270-0413 

GLACIER LAW LLP

41 Madison Avenue, Ste 2529 

New York, NY 10010 

Tao Liu, Esq. 

Wei Wang, Esq.

He Chang, Esq. 

Tao.liu@glacier.law 

wei.wang@glacier.law 

robin.cheng@glacier.law 

332-777-7315 

Attorneys for Defendant

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this December 9, 2022, 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: 12/9/2022 /s/ Yu Hao Yao

Case: 1:20-cv-04806 Document #: 625 Filed: 12/09/22 Page 4 of 4 PageID #:15746