Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 1 of 26 PageID #:1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

Huawen Chen, )
Plaintiff, )
) Case No. 1:23-cv-xxxx
v. )
)
The Individuals, Partnerships and )
Unincorporated Associations Identified on )
Schedule A, )
Defendants )

Complaint

NOW COMES Huawen Chen (“Plaintiff”), by and through his undersigned counsel, and hereby

brings this Complaint against the Individuals, Partnerships, and Unidentified Associations

identified on Schedule A attached hereto (collectively, “Defendants”) and alleges as follows:

Nature of the Action

1. This action has been filed by Plaintiff to combat e-commerce store operators who trade upon

Plaintiff’s intellectual property by making, using, offering for sale, selling and/or importing

into the United States for subsequent sale or use unauthorized and unlicensed products which

infringe Plaintiff’s patented design (the “Infringing Products”).

2. Defendants create fully-interactive, commercial Internet stores operating under at least the

online marketplace accounts identified in Schedule A, attached hereto (collectively, the

“Defendant Online Stores”) that are intentionally designed to appear to be selling genuine

Plaintiff Products, while actually making, using, offering for sale, selling, and/or importing

into the United States for subsequent sale or use Infringing Products to unknowing

consumers.
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 2 of 26 PageID #:2

3. The Defendant Online Stores share identifiers establishing a logical relationship between

them, suggesting that Defendants’ operation arises out of the same transaction, occurrence, or

series of transactions or occurrences.

4. Defendants attempt to avoid and mitigate liability by operating under one or more e-

commerce stores to conceal both their identities and the full scope and interworking of their

infringing operation. Plaintiff is forced to file this action to combat Defendants’

infringement of its patented design, as well as to protect unknowing consumers from

purchasing Infringing Products over the Internet.

5. Plaintiff has been and continues to be irreparably damaged from the loss of its lawful patent

rights to exclude others from, inter alia, making, using, selling, offering for sale, and

importing its patented designs as a result of Defendants’ actions and seeks injunctive and

monetary relief.

Parties

6. Plaintiff is an individual and Chinese citizen and is the assignee of all rights in and to the

Plaintiff Design.

7. Defendants are individuals and business entities who, upon information and belief, reside

and/or operate in the People’s Republic of China, or other foreign jurisdictions, or

redistribute products from the same or similar sources in those locations. Defendants conduct

business throughout the United States, including within the State of Illinois and this Judicial

District, through the operation of the fully interactive Defendant Online Stores which operate

on commercial online marketplaces. Each Defendant targets the United States, including

Illinois and this Judicial District, and has offered to sell, and, on information and belief, has
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 3 of 26 PageID #:3

sold and continues to sell Infringing Products to consumers within the United States,

including the State of Illinois and this Judicial District.

8. On information and belief, Defendants either individually or jointly, operate the Defendant

Online Stores. Tactics used by Defendants to conceal their identities and the full scope of

their operation make it virtually impossible for Plaintiff to learn Defendants’ true identities

and the exact interworking of their network. If Defendants provide additional credible

information regarding their identities, Plaintiff will take appropriate steps to amend the

Complaint.

Jurisdiction and Venue

9. This Court has subject matter jurisdiction over Plaintiff’s claims pursuant to 28 U.S.C. §§

1331, 1338 (for claims arising under the U.S. Patent Act).

10. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, and this Court may properly

exercise personal jurisdiction over Defendants since each of the Defendants directly targets

business activities toward consumers in the United States, including Illinois and this Judicial

District. Defendants reach out to do business with residents of Illinois and this Judicial

District by operating one or more commercial, fully-interactive Defendant Online Stores

through which residents of Illinois and this Judicial District can purchase and/or have

purchased products being offered and sold featuring Plaintiff’s patented design. Each

Defendant has targeted sales from residents of Illinois and this Judicial District by setting up

and operating one or more Defendant Online Store that accepts payment in U.S. dollars and

offers shipping to addresses within Illinois and this Judicial District, and, on information and

belief, each Defendant has offered to sell and sold products featuring Plaintiff’s patented

designs to residents of Illinois. Each Defendant has committed and is committing tortious
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 4 of 26 PageID #:4

acts in Illinois and this Judicial District, is engaging in interstate commerce, and has

wrongfully caused Plaintiff substantial injury in the State of Illinois.

Plaintiff’s Business

11. Plaintiff is engaged in the design, distribution, marketing, offering for sale, and sale of

various industrial designs and consumer products since 2019, (the “Plaintiff Products”)

including without limitation water bottle products.

12. The Plaintiff Products are distributed and sold to consumers throughout the United States,

including in Illinois and in this judicial district.

13. Plaintiff Products are known for their distinctive patented design. This design is broadly

recognized by consumers. Products tailored after this design (herein referred to as the

“Plaintiff Design”) are associated with the quality and innovation that the public has come to

expect from Plaintiff Products.

14. Plaintiff is the lawful assignee of all right, title, and interest in and to the Plaintiff Design.

Attached hereto as Exhibit 1 is a true and correct copy of the United States Patent for the

Plaintiff Design.

Defendants’ Unlawful Conduct

15. Plaintiff has identified numerous fully interactive, ecommerce stores, including the

Defendant Online Stores, which are or recently were offering for sale and/or selling

Infringing Products to consumers in this judicial district and throughout the United States.

16. Marketplaces like eBay, Walmart, and Amazon, among others, allow merchants to quickly

“set up shop” and flood the market with unauthorized goods which displace actual sales

manufacturers would otherwise enjoy.

 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 5 of 26 PageID #:5

17. It has been estimated that e-commerce intellectual property infringement costs merchants in

the U.S. alone nearly $41 billion1 with Department of Homeland Security seizures of

infringing goods increasing more than 10-fold between 2000 and 2018 2 and a street value of

seized goods increasing 246% from 2017 to 2022. 3

18. Infringing and pirated products account for billions in economic losses, resulting in tens of

thousands of lost jobs for legitimate businesses and broader economic losses, including lost

tax revenue.

19. Third party service providers like those used by Defendants do not adequately subject new

sellers to robust verification and confirmation of their identities, allowing infringers to

“routinely use false or inaccurate names and addresses when registering with these e-

commerce platforms.” 4

20. DHS has observed that “at least some e-commerce platforms, little identifying information is

necessary for [an infringer] to begin selling” and recommending that “[s]ignificantly

enhanced vetting of third-party sellers” is necessary. Infringers hedge against the risk of

being caught and having their websites taken down from an e-commerce platform by

preemptively establishing multiple virtual storefronts. 5

1
The National Bureau of Asian Research, The Report of the Commission on the Theft of American
Intellectual Property, at 9, Pub. The Commission on the Theft of American Intellectual Property 2017,
available at http://www.ipcommission.org/report/IP_Commission_Report_Update_2017.pdf.
2
U.S. Department of Homeland Security, Combating Trafficking in Counterfeit and Pirated Goods
Report to the President of the United States, January 24, 2020.
3
U.S. Customs and Border Protection Office of Trade, FY 2022 Fact Sheet Intellectual Property Rights,
available at https://www.cbp.gov/sites/default/files/assets/documents/2023-
Mar/IPR%20Fact%20Sheet%20FY2022%20Final%20Draft%20%28508%29%20%28004%29%20%282
%29.pdf
4
Daniel C.K. Chow, Alibaba, Amazon, and Counterfeiting in the Age of the Internet, 40 NW. J. INT’L L.
& BUS. 157, 186 (2020).
5
Combating Trafficking in Counterfeit and Pirated Goods Report to the President of the United States, at
p. 22.
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 6 of 26 PageID #:6

21. Since platforms generally do not require a seller on a third-party marketplace to identify the

underlying business entity, infringers can have many different profiles that can appear

unrelated even though they are commonly owned and operated. 6

22. The success of Plaintiff’s sales of the Plaintiff Products has resulted in substantial infringing

activity and other attempts to misappropriate Plaintiff’s proprietary rights. Plaintiff has

policed the use of the Plaintiff Design and has identified many online product listings on

marketplaces such as eBay, Walmart and Amazon, and other Internet locations offering for

sale and, on information and belief, selling products featuring the Plaintiff Design throughout

the United States including this Judicial District.

23. Defendants enable and facilitate the sales of their Infringing Products by setting up and

operating commercial, fully interactive, Defendant Online Stores, offering shipping to the

United States, including Illinois, accepting payment in U.S. dollars and, on information and

belief, offering to sell or selling Infringing Products to residents of Illinois and this judicial

district.

24. Defendants collectively employ and benefit from substantially similar advertising and

marketing strategies. For example, Defendants facilitate sales by designing the Defendant

Online Stores so that they appear to unknowing consumers to be authorized online retailers,

outlet stores, or wholesalers. The Defendant Online Stores appear sophisticated and accept

payment in U.S. dollars via credit cards, Alipay, Amazon Pay, Western Union and/or PayPal.

The Defendant Online Stores often include content and images which make it very difficult

for consumers to distinguish such stores from those of an authorized retailer. Plaintiff has

6
Id., at p. 39.
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 7 of 26 PageID #:7

not licensed or authorized Defendants to use the Plaintiff Design, and on information and

belief none of the Defendants are authorized retailers of genuine Plaintiff Products.

25. On information and belief, Defendants engaged in fraudulent conduct when registering the

Defendant Online Stores by providing false, misleading and/or incomplete information to

their respective ecommerce platforms. On information and belief, certain Defendants have

anonymously registered and maintained the Defendant Online Stores to prevent discovery of

their true identities and the scope of their e-commerce operation.

26. Defendants take pains to conceal their identities from the public, almost invariably using

meaningless store names and addresses which do not identify Defendants. Defendants may

operate several stores simultaneously using fictitious identities such as those listed in

Schedule A, as well as other fictitious names and addresses. Moreover, infringers like

Defendants will often register or acquire new store accounts under new fictitious names

when they receive notice that one or more stores have been subject to law suit which allows

them to avoid enforcement efforts and continue offering for sale and selling Infringing

Products. The use of these store registration schemes is one of many common tactics used by

the Defendants to conceal their identities and the full scope and interworking of their

operation, and to avoid being halted.

27. Despite Defendants operating under multiple fictitious names, the Defendant Online Stores

bear numerous similarities, such as templates with common design elements that

intentionally omit any contact information or other information for identifying Defendants or

other stores they operate or use. The Defendant Online Stores include other notable common

features, such as use of the same registration patterns, accepted payment methods, check-out

methods, keywords, illegitimate search engine optimization (SEO), advertising tactics,

 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 8 of 26 PageID #:8

similarities in price and quantities, the same incorrect grammar and misspellings, and/or the

use of the same text and product imagery.

28. Infringers like Defendants will typically ship infringing products in small quantities via

international mail to mitigate detection by U.S. Customs and Border Protection. Further,

they will typically operate multiple credit card merchant accounts or use layers of payment

gateways to forestall their cashflow being interrupted due to trademark enforcement efforts.

On information and belief, Defendants utilize offshore bank accounts and routinely move

funds from U.S.-based merchant accounts (e.g., within China) outside the jurisdiction of this

Court.

29. On information and belief, Defendants are in constant communication with each other and

regularly participate in QQ.com and WeChat chat rooms and through websites such as

sellerdefense.cn, kaidianyo.com, and kuajingvs.com regarding tactics for operating multiple

accounts, evading detection, pending litigation, and potential new lawsuits.

30. On information and belief, Defendants maintain offshore bank accounts and regularly move

funds from their financial accounts to offshore bank accounts outside the jurisdiction of this

Court and will do so to avoid payment of any monetary judgment awarded to Plaintiff by this

Court.

31. On information and belief, Defendants are an interrelated group of infringers working in

active concert to knowingly and willfully manufacture, import, distribute, offer for sale, and

sell Infringing Products in the same transaction, occurrence, or series of transactions or

occurrences. Defendants, without any authorization or license from Plaintiff, have

knowingly and willfully offered for sale, sold, and/or imported into the United States for

subsequent resale or use products that infringe directly and/or indirectly the Plaintiff
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 9 of 26 PageID #:9

Design. Each Defendant Online Store offers shipping to the United States, including Illinois

and this Judicial District, and on information and belief, each Defendant has offered to sell or

sold Infringing Products into the United States and Illinois, including this Judicial District,

over the internet.

32. Defendants’ infringement of the Plaintiff Design in the making, using, offering for sale,

selling, and/or importing into the United States for subsequent sale or use of the Infringing

Products was willful.

33. Defendants’ infringement of the Plaintiff Design in connection with the making, using,

offering for sale, selling, and/or importing into the United States for subsequent sale or use of

the Infringing Products, including the making, using, offering for sale, selling, and/or

importing into the United States for subsequent sale or use of Infringing Products into

Illinois, including this judicial district, is irreparably harming Plaintiff.

Count I - Patent Infringement (25 U.S.C. § 271)

34. Plaintiff repeats and realleges the allegations of Paragraphs 1 - 33 as if fully set forth herein.

35. Defendants are making, using, offering for sale, selling, and/or importing into the United

States for subsequent sale or use Infringing Products that infringe directly and/or indirectly

the ornamental design claimed in Plaintiff Design.

36. Defendants have infringed Plaintiff Design through the aforesaid acts and will continue to do

so unless enjoined by this Court. Defendants’ wrongful conduct has caused Plaintiff to suffer

irreparable harm resulting from the loss of its lawful patent rights to exclude others from

making, using, selling, offering for sale, and importing the patented invention. Plaintiff is

entitled to injunctive relief pursuant to 35 U.S.C. § 283.

37. Plaintiff is entitled to recover damages adequate to compensate for the infringement,
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 10 of 26 PageID #:10

including Defendants’ profits pursuant to 35 U.S.C. § 289. Plaintiff is entitled to recover any

other damages as appropriate pursuant to 35 U.S.C. § 284.

WHEREFORE, Plaintiff prays for judgment against Defendants as follows:

A. That Defendants, their affiliates, officers, agents, servants, employees, attorneys,

confederates, and all persons acting for, with, by, through, under or in active concert with

them be permanently enjoined and restrained from:

a. making, using, offering for sale, selling, and/or importing into the United States for

subsequent sale or use any products not authorized by Plaintiff and that include any

reproduction, copy or colorable imitation of the designs claimed in the Plaintiff

Design;

b. aiding, abetting, contributing to, or otherwise assisting anyone in infringing upon the

Plaintiff Design; and

c. effecting assignments or transfers, forming new entities or associations or utilizing

any other device for the purpose of circumventing or otherwise avoiding the

prohibitions set forth in Subparagraphs (a) and (b).

B. Entry of an Order that, upon Plaintiff’s request, those with notice of the injunction, including,

without limitation, any online marketplace platforms such as Amazon, Wish, eBay, and

Walmart (collectively, the “Third Party Providers”) shall disable and cease displaying any

advertisements used by or associated with Defendants in connection with the sale of goods

that infringe the ornamental designs claimed in the Plaintiff Design;

C. That Plaintiff be awarded such damages as it shall prove at trial against Defendants that are

adequate to compensate Plaintiff for Defendants’ infringement of the Plaintiff Design, but in
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 11 of 26 PageID #:11

no event less than a reasonable royalty for the use made of the inventions by the Defendants,

together with interest and costs, pursuant to 35 U.S.C. § 284;

D. That the amount of damages awarded to Plaintiff to compensate it for infringement of the

Plaintiff Design be increased by three times the amount thereof, as provided by 35 U.S.C. §

284;

E. In the alternative, that Plaintiff be awarded all profits realized by Defendants from their

infringement of the Plaintiff Design, pursuant to 35 U.S.C. § 289;

F. That Plaintiff be awarded its reasonable attorneys’ fees and costs; and

G. Award any and all other relief that this Court deems just and proper.

Dated: September 26, 2023

Respectfully,

/s/Carla Carter
Carla Carter
Michael Davis
Davis & Carter LLC
53 W. Jackson Blvd., Ste. 1560
Chicago, IL 60604
T: (312) 600-5485
[email protected]
[email protected]
Counsel for Plaintiff
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 12 of 26 PageID #:12

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

Huawen Chen, )
Plaintiff, )
) Case No. 1:23-cv-xxxx
v. )
)
The Individuals, Partnerships and )
Unincorporated Associations Identified on )
Schedule A, )
Defendants )

Schedule A

Def. No. Name Seller ID ASINs

1 ACTICO A3B5CV3Z1UEEMD www.amazon.com/dp/B0BV629T1W

www.amazon.com/dp/B0BZVQQVCD
2 AIFEIRIC A2V10PCELFA11Z www.amazon.com/dp/B0BV2B7DX2

3 AmapleL A2I0F9PI8KSJPG www.amazon.com/dp/B0BB2JXV8F

4 AnnA Store A1HPM1FSLDML3U www.amazon.com/dp/ B0BD4261GM

5 ApexOne A17WAV1481EVGO www.amazon.com/dp/B0BDDS2PQR

6 BadaStore A3KLL9YPXF6STH www.amazon.com/dp/B0B6VPZKB2

7 ChooLam A1NZKIN0HG1FSZ www.amazon.com/dp/B0BD4L47KN

www.amazon.com/dp/B0BR42V3TQ
www.amazon.com/dp/B0BR42V3TQ
www.amazon.com/dp/B0BR42V3TQ
8 dongguanshisanjias A21TP4EF1QFKUY www.amazon.com/dp/B0BLH95L4D
www.amazon.com/dp/B0BLH9WCLL
henghuoyongpinyo

uxiangongsi

9 Dtsukl APJ9UO65OQ2MU www.amazon.com/dp/B0BBR24DCS

10 HNHNYXC A3FWILI7BPES7Q www.amazon.com/dp/B0BHDGD27L

11 Huayatian A1M1M19URHU64C www.amazon.com/dp/B0BGS16H7K

12 HXGNLOMD A2I36JQM5DCLLK www.amazon.com/dp/B0BKJZGHS5

13 JJunLiM® A36NPAKZ628ENY www.amazon.com/dp/B0BKXGFZ6D

 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 13 of 26 PageID #:13

14 Koomduk US A3RCUF5AGI3C5J www.amazon.com/dp/B0BGSZ1DVP

15 Leateck A1DFM1G5Q2KS6T www.amazon.com/dp/B0BCHPJVT4

16 linchuancong A34I2TFOZ8ZSIL www.amazon.com/dp/B0C4SP9CS7

17 Olaf store A1J27WYWEK2CZ1 www.amazon.com/dp/B0B9ZWQ5L4

18 Onkuly ARSRV6Z8MCK4N www.amazon.com/dp/B0BW3QH92V

www.amazon.com/dp/B0BW3NCMF6
19 Poptel US Official A2XUUG3S5YBJFG www.amazon.com/dp/B0BDRQK2XZ

Store

20 Red Deer Express A361JZ1Q3SR81J www.amazon.com/dp/B0BBSQ5J8G

21 saiaolang A26OBPSXU1MOI8 www.amazon.com/dp/B0B86JTBDS

22 shangdianchuwei A1M60IAN4B7FR www.amazon.com/dp/B0BTP77519

23 SofiaGrace A3SITFGXOINFFJ www.amazon.com/dp/B0BBQB4HWN

24 Stomge A3TG5KE1U2W8V2 www.amazon.com/dp/B0BKGP8KBR

25 Tanwater ARUMN51GFMX3G www.amazon.com/dp/B0C37H1S7G

26 TretarUS A2XV3Q2WLRGRF www.amazon.com/dp/B0BZC6F9DR

27 Warm Mercure A3A2O87NSYKWFV www.amazon.com/dp/B0BYNNMRGN

Store

28 Wataner Store A2WRMZ42QAR7CR www.amazon.com/dp/B0C7L7YKN2

29 Wraith Companies A16FH93MNM89XU www.amazon.com/dp/B0B7GWDRTQ

30 XSFANCYFUN A2I9O5JRAF45A7 www.amazon.com/dp/B0B7RHSQWK

31 Yekui A3SGEJ0XI45V6J www.amazon.com/dp/B0BHY6HQ9S

32 Yfresh A3VDQVUH8KULY1 www.amazon.com/dp/B0BN549T2D

33 Yifanghui Store APJRJFUKMITXY www.amazon.com/dp/B0C5HWP92J

www.amazon.com/dp/B0C53GYZND
34 yifangzhuangshi A1B2HSCGR8Y52I www.amazon.com/dp/B0BHQ7GHYT

35 zhengzhouyutian A2TM8LO6DTZC5Z www.amazon.com/dp/B0BZ4G8TBL

36 zhouzesen A3OADT5C4YHXX9 www.amazon.com/dp/B0BJBFC5P4

37 一骏科技 A2AEYX06741I9L www.amazon.com/dp/B0BJW399XB

38 hairteex A15MT6K5D6OYER www.amazon.com/dp/B0CBCJ7432

 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 14 of 26 PageID #:14

39 YEEPSYS AEDID42Y4GMF7 www.amazon.com/dp/B0BBDV188G

40 Booyoo https://www.walmart.com/sel https://www.walmart.com/ip/Jygee-5-

Gallon-Water-Bottle-Jug-Cap-Plastic-
ler/101043439 Reusable-Leak-proof-Lid-Portable-
Dispenser-Replaceable-Spare-Parts-
Accessories/2230546299?from=/search
41 Cluosivey https://www.walmart.com/sel https://www.walmart.com/ip/Martokay-
5-Gallon-Water-Bottle-Jug-Cap-Plastic-
ler/101220841 Reusable-Leak-proof-Lid-Portable-
Dispenser-Replaceable-Spare-Parts-
Accessories/2777970659?from=search
Results
42 Joybuy https://www.walmart.com/sel https://www.walmart.com/ip/5-Gallon-
Water-Bottle-Jug-Cap-Plastic-
ler/18988 Reusable-Leak-proof-Lid-Portable-
Dispenser-Replaceable-Spare-Parts-
Accessories/2185443093?from=search
Results
43 Joybuy Express https://www.walmart.com/sel https://www.walmart.com/ip/KEVCHE-
5-Gallon-Water-Jug-Reusable-Cap-
ler/16214 Non-Spill-55mm-Water-Bottle-Caps-
Silicone-Replacement-Cap-Lids-Anti-
Splash-
Blue/1531398442?from=searchResults
44 Joybuy Fashion https://www.walmart.com/sel https://www.walmart.com/ip/ADVEN-
5-Gallon-Water-Bottle-Jug-Cap-Plastic-
ler/101118004 Reusable-Leak-proof-Lid-Portable-
Dispenser-Replaceable-Spare-Parts-
Accessories/1838365509?from=search
Results
45 sixwipe https://www.walmart.com/sel https://www.walmart.com/ip/sixwipe-6-
Pcs-3-5-Gallon-Water-Jug-Cap-Hole-
ler/101226298 Silicone-Reusable-Replacement-Cap-
Strong-Sealing-Spill-Top-Lid-Cover-
55mm-Bottle-Dispenser-
Caps/1906759521?adsRedirect=true
46 stay real Shop https://www.walmart.com/sel https://www.walmart.com/ip/Linyer-5-
Gallon-Water-Bottle-Jug-Cap-Plastic-
ler/101036302 Reusable-Leak-proof-Lid-Portable-
Dispenser-Replaceable-Spare-Parts-
Accessories/1065531932?from=search
Results
47 autodreams0695 https://www.ebay.com/str/aut https://www.ebay.com/itm/2758618793
22
odreams0695

48 auto-pla https://www.ebay.com/str/aut https://www.ebay.com/itm/1345385328

37
opla
 Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 15 of 26 PageID #:15

49 bestshopping2 https://www.ebay.com/str/bes https://www.ebay.com/itm/1661285319

18
tshoppingglobal

50 brannon_32456 https://www.ebay.com/str/bes https://www.ebay.com/itm/3545368502

17
tdealsbrennon

51 buryalt https://www.ebay.com/usr/bu https://www.ebay.com/itm/1953801901

72
ryalt

52 eptjknbdbd https://www.ebay.com/str/ept https://www.ebay.com/itm/3742539341

40
jknbdbd

53 expital https://www.ebay.com/str/ex https://www.ebay.com/itm/1554470088

05
pitalcanada

54 gadgetlyfe https://www.ebay.com/str/ga https://www.ebay.com/itm/1757301037

26
dgetlyfe

55 gilstore19 https://www.ebay.com/str/gil https://www.ebay.com/itm/3348108372

53
store19

56 laopde https://www.ebay.com/str/lao https://www.ebay.com/itm/3547121160

83
pde

57 nedart https://www.ebay.com/str/ne https://www.ebay.com/itm/4040945187

16
dart

58 zeprdse https://www.ebay.com/str/ze https://www.ebay.com/itm/1447279572

28
prdse
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 16 of 26 PageID #:16

Exhibit 1
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 17 of 26 PageID #:17
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 18 of 26 PageID #:18
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 19 of 26 PageID #:19
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 20 of 26 PageID #:20
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 21 of 26 PageID #:21
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 22 of 26 PageID #:22
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 23 of 26 PageID #:23
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 24 of 26 PageID #:24
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 25 of 26 PageID #:25
Case: 1:23-cv-14304 Document #: 1 Filed: 09/29/23 Page 26 of 26 PageID #:26