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 

CONSENT JUDGMENT 

Upon consent of Plaintiffs Hangzhou Chic Intelligent Technology Co. (“Chic”) and 

Unicorn Global, Inc. (“Unicorn”) (collectively, “Plaintiffs”) and Defendant eBay store 

authorized_reseller with the PayPal account email: rauthorized@gmail.com (“Defendant”), 

judgment is entered against Defendant upon Plaintiffs’ Third Amended Complaint, and it is 

ORDERED, ADJUDGED, and DECREED that: 

1. Plaintiffs commenced this action for patent infringement against Defendant, and other 

defendants, on August 17, 2020. The complaint was subsequently amended to add and 

remove certain parties. The current complaint alleges infringement of U.S. Design Patent 

Nos. D737,723, D738,256, D785,112, and D784,195 (collectively, “Patents-in-Suit”). 

Defendant has reviewed a copy of the Third Amended Complaint filed by Plaintiffs in this 

action. 

2. This Court has jurisdiction over Defendant and Plaintiffs and over the subject matter of the 

Third Amended Complaint. 

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3. Plaintiffs allege that Chic is the assignee of all rights, title, and interest in the Patents-inSuit, and that Unicorn is the exclusive U.S. distributor of Plaintiffs’ products which 

incorporate the Patents-in-Suit. 

4. Plaintiffs have alleged that Defendant has infringed the Patents-in-Suit under 35 U.S.C. § 

271 by making, using, selling, offering for sale, importing and/or otherwise distributing 

self-balancing transport devices known as hoverboards. Defendant has not answered the 

Third Amended Complaint. Defendant has agreed to stop making, using, selling, offering 

for sale, importing and otherwise distributing any products accused of infringement in the 

litigation and any colorably similar products, and have consented to entry of a permanent 

injunction. Defendant admits that all claims of the Patents-in-Suit are infringed and 

concedes that all claims of the Patents-in-Suit are valid and enforceable. 

5. Defendant, its respective officers, agents, servants, employees, and other persons who are 

in active concert or participation with Defendant (including their directors, partners, 

members, affiliates, subsidiaries, assigns, and successors-in-interest to the extent permitted 

by Fed. R. Civ. P. 65) are permanently enjoined (unless expressly permitted by Plaintiffs) 

during the terms of the Patents-in-Suit from infringing the Patents-in-Suit, including, 

without limitation, by the making, using, selling, offering for sale, importing and otherwise 

distributing in the United States any of the products referred to in paragraph 4 above. 

6. Accordingly, Defendant is dismissed from this action with prejudice. This Order does not 

affect the other defendants in this action and the action therefore will continue to proceed 

against the defendants other than Defendant. 

7. This Court shall retain jurisdiction over Defendant for purposes of enforcing this Consent 

Judgment. 

Case: 1:20-cv-04806 Document #: 352 Filed: 08/06/21 Page 2 of 3 PageID #:8170
8. The right to enforce this Consent Judgment shall transfer to any successor-in-interest to 

Chic, and/or Unicorn. 

9. Each party shall bear its own costs and attorneys’ fees. 

SO ORDERED this __ day of August 2021: 

 

Judge Thomas Durkin 

United States District Judge 

AGREED TO: 

Dated: August 5, 2021 

/s/ Adam Kelly 

LOEB & LOEB LLP 

Adam Kelly 

Doug Masters 

Arthur Yuan 

Neil Nandi 

321 North Clark Street, Ste. 2300 

Chicago, IL 60654 

(312) 464-3100 

Marwa Abdelaziz (admitted pro hac vice) 

LOEB & LOEB LLP 

345 Park Avenue 

New York, NY 10154 

(212) 407-4000 

Counsel for Plaintiffs

Dated: August 5, 2021 

/s/ Shen Wang 

Arch & Lake LLP 

Shen Wang 

203 N LaSalle Street, Suite 2100

Chicago, IL 60601

Phone: 636-236-5390

Counsel for Defendant 

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