MATTEL, INC. v. UNICORN ELEMENT et al.

Filing 39

ORDER: For the reasons stated above, it is hereby ORDERED that the motion by plaintiff Mattel, Inc. for prejudgment attachment pursuant to Rule 64 of the Federal Rules of Civil Procedure (see Dkt. No. 22) is GRANTED as to (a) the entities doing bus iness as Unicorn Element at the URL www.unicornelement.net ("Unicorn Element"); (b) the entities doing business as the PayPal, Inc. ("PayPal") merchant: (the PayPal Merchant); (c) the entities doing business using th e email address [e-mail] ("[e-mail]"); (d) the entities doing business on amazon.com under the brand name Zita Element, under the store name Zita Element, and/or under the business name Yang Liuhui (collectively, "Zita Element"); (e) the entities doing business on amazon.com under the brand name Ecore Fun, under the store name EC2Toy, and/or under the business name Huang Qiong (collectively, "Ecore Fun"); (f) EMMS Trading GmbH ("EMMS"); (g) Zhijian Li ("Li"); (h) Yang Liuhui ("Liuhui"); and (i) Huang Qiong ("Qiong"). (Signed by Judge Victor Marrero on 6/4/2021) (js)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------X
MATTEL, INC.,
:
:
Plaintiff,
:
:
-against:
:
THE ENTITIES DOING BUSINESS AS
:
UNICORN ELEMENT AT THE URL
:
UNICORNELEMENT.NET, et al.,
:
:
Defendants.
:
---------------------------------X
VICTOR MARRERO, U.S.D.J.:

6/4/21

21 Civ. 2333(VM)
ORDER

Plaintiff Mattel, Inc. (“Mattel”) brings this action
against (a) the entities doing business as Unicorn Element at
the URL www.unicornelement.net (“Unicorn Element”); (b) the
entities
merchant
business

doing

business

as

the

PayPal,

Inc.

(“PayPal”)

(the “PayPal Merchant”); (c) the entities doing
using

the

email

address

[e-mail]

(“[e-mail]”); (d) the entities doing business
on amazon.com under the brand name Zita Element, under the
store name Zita Element, and/or under the business name Yang
Liuhui (collectively, “Zita Element”); (e) the entities doing
business on amazon.com under the brand name Ecore Fun, under
the store name EC2Toy, and/or under the business name Huang
Qiong (collectively, “Ecore Fun”); (f) EMMS Trading GmbH
(“EMMS”); (g) Zhijian Li (“Li”); (h) Yang Liuhui (“Liuhui”);
and (i) Huang Qiong (“Qiong”) (collectively, “Defendants”)
1

alleging

that

Defendants

infringed

Mattel’s

registered

trademarks and copyrighted works related to Barbie dolls.
(See “Complaint,” Dkt. No. 9.) On April 17, 2021, Mattel filed
an Amended Complaint. (See “Amended Complaint,” Dkt. No. 33.)
Mattel
Unicorn

brings

trademark

Element,

the

[e-mail],
(collectively,

the

Ecore

“Trademark

claims

against

Defendants

PayPal
Fun,

Merchant,

Li,

and

Defendants”).

(Id.

Qiong,
¶

28.)

Mattel brings copyright claims against Unicorn Element, the
PayPal Merchant, [e-mail], Zita Element, EMMS,
Li,

Liuhui,

and

Qiong

(collectively,

the

“Copyright

Defendants”). (Id. ¶ 31.) Now before the Court is Mattel’s
Motion for Attachment. (See “Motion,” Dkt. No. 22.) For the
reasons set forth below, the Motion is GRANTED.
I.
A.

BACKGROUND

FACTUAL BACKGROUND 1
Mattel manufactures consumer products including toys,

games, and other playthings. As relevant to this Motion,
Mattel manufactures and sells dolls, doll clothes, and doll
accessories, which it advertises and distributes under the
mark “BARBIE” (the “Barbie Mark”). Defendants are various

1

Except as otherwise noted, the factual background derives from the
Amended Complaint and the facts pleaded therein. Except when specifically
quoted, no further citation will be made to the Amended Complaint or the
documents referred to therein.

2

persons and/or companies engaged in the sale and distribution
of doll clothes and accessories.
The Barbie Mark is registered on the Principal Register
of the U.S. Patent & Trademark Office as No. 3,287,023 (the
(“Barbie Registration”). Mattel has used the Barbie Mark in
connection with the sale of doll clothing and accessories
since at least 1960. Mattel alleges that the Barbie Mark is
inherently distinctive and intrinsic to the goods Mattel
sells. Similarly, Mattel alleges that the Barbie Mark is
famous throughout the United States, it signals that Mattel
is

the

source

of

the

products,

and

the

general

public

associates the Barbie Mark with high-quality products.
Mattel uses collections of illustrations in connection
with the marketing and sale of certain of its Barbie products.
As relevant to this action, one such collection, “Barbie A
Fashion Fairytale Fall 2010 Entertainment Style Guide” (the
“Style Guide”) contains a unique illustration of a Barbie
doll

(the

copyright

“Barbie
in

Illustration”).

the

Style

Guide,

Mattel

registered

including

the

the

Barbie

Illustration, under Copyright Registration Number VA 1-843492.
Mattel
permission,

alleges
have

that

used

Defendants,

both

the

without

Barbie

Mark

license
and

or

Barbie

Illustration in connection with the advertising and sale of
3

products. Mattel further alleges that this infringement was
either intentional or reckless.
On March 17, 2021, Mattel filed under seal (1) the
Complaint

alleging

Counterfeiting,
Dilution,

and

Trademark

False

Infringement,

Designation

Copyright

of

Infringement;

Trademark

Origin,
(2)

Trademark

a

proposed

Temporary Restraining Order (“TRO”) restraining Defendants
from removing funds from certain accounts at Amazon and
PayPal;

and

(3)

the

present

Motion

for

prejudgment

attachment. That same day, the Court entered the TRO. (See
Dkt. No. 15.) After the temporary order of attachment was
effectuated and service on Defendants was made, the Court
unsealed this matter. 2 (See Dkt. No. 4.) On April 29, 2021,
Defendants filed an opposition to the present Motion. (See
“Opposition,” Dkt. No. 30.) On May 12, 2021, Mattel filed a
reply brief in support of the Motion. (See “Reply,” Dkt. No.
31.)
B.

THE PARTIES’ ARGUMENTS
Mattel argues that it has satisfied all the statutory

prerequisites for prejudgment attachment and that the Court
should exercise its discretion to impose such remedy. Mattel
argues it has demonstrated a likelihood of success on its
2

The Court is aware that Defendants may at some further point contest
whether proper service was made and reserves judgment on such arguments
until they are properly before the Court.

4

trademark claims because the Trademark Defendants have used
Mattel’s validly held trademark -- the Barbie Mark -- in the
promotion and sale of the Trademark Defendants’ doll clothing
and

accessories.

Similarly,

Mattel

argues

that

it

has

demonstrated a likelihood of success on its copyright claims
because the Copyright Defendants have used Mattel’s validly
held copyrighted work -- the Barbie Illustration -- in the
promotion and sale of the Coyright Defendants’ products.
Defendants respond that Mattel has not demonstrated a
likelihood of success on the merits because for both claims
Defendants have demonstrated “fair use” of the protected
intellectual
Defendants

property.
argue

that

As

to

they

trademark,
have

used

the
the

Trademark
potentially

infringing term other than as a trademark, in a descriptive
way, and in good faith. As to copyright, the Copyright
Defendants argue that they have transformed the copyrighted
work and have so minimally copied it such that they have not
inhibited the market for reproduction.
II.

LEGAL STANDARD

Under Rule 64 of the Federal Rules of Civil Procedure,
“every remedy is available that, under the law of the state
where the court is located, provides for seizing a person or
property to secure satisfaction of the potential judgment.”
Fed. R. Civ. P. 64(a). Under New York law, “[a]n order of
5

attachment may be granted in any action . . . where the
plaintiff has demanded and would be entitled . . . to a money
judgment against one or more defendants, when . . . the
defendant is a nondomiciliary residing without the state, or
is a foreign corporation not qualified to do business in the
state.” N.Y. C.P.L.R. § 6201 (“Section 6201”).
To prevail on a motion for attachment, the plaintiff
must also “show by affidavit and such other written evidence
as may be submitted, that there is a cause of action, that it
is probable that the plaintiff will succeed on the merits
. . . and that the amount demanded from the defendants exceeds
all

counter-claims

known

to

the

plaintiff.”

Id.

§

6212

(“Section 6212”). If the plaintiff can meet the requirements
under New York law, a court is permitted, but not required,
to issue an order of attachment. A court may exercise its
discretion not to issue an attachment if it concludes that an
attachment

is

not

necessary

“to

obtain

quasi

in

rem

jurisdiction of the property on non-resident defendants [or]
provide security for potential judgments.” Capital Ventures
Int’l v. Republic of Argentina, 443 F.3d 214, 221 (2d Cir.
2006).
III. DISCUSSION
The

parties

agree

that

certain

of

the

statutory

requirements for attachment under Sections 6201 and 6212 have
6

been met here. First, there is no dispute that Mattel has a
cognizable

cause

residents

of

of

New

action.
York.

Second,
Third,

Defendants
Defendants

are

not

have

no

counterclaim. Defendants also do not dispute that Mattel has
adequately demonstrated a need for prejudgment attachment to
provide security for a potential judgment. The parties do,
however, dispute whether Mattel has demonstrated a likelihood
of success on the merits of its claims.
A.

LIKELIHOOD OF SUCCESS ON THE MERITS
Probability of success on the merits for purposes of an

order

of

attachment

requires

that

the

moving

party

demonstrate that it is more likely than not that it will
succeed on its claims; the movant must show proof stronger
than that required to make a prima facie case. See Merrill
Lynch, Pierce, Fenner & Smith Inc. v. Baninvensa Capital
Mkts., Ltd., No. 94 Civ. 2778, 1995 WL 380129, at *1 (S.D.N.Y.
June 26, 1995); Donaldson Lufkin & Jenrette Secs. Corp. v.
Burgess, No. 92 Civ. 1174, 1992 WL 47980, at *1 (S.D.N.Y.
Mar. 2, 1992); Perrotta v. Giannoccaro, 532 N.Y.S.2d 998,
1000 (Sup. Ct. 1988) (noting that the showing is comparable
to that required when evaluating a preliminary injunction, “a
clear

showing

of

likelihood

of

merits”).
1.

Trademark Claims
7

ultimate

success

on

the

Under the Lanham Act, a plaintiff alleging trademark
infringement must demonstrate that (1) “it has a valid mark
that is entitled to protection” and that (2) the defendant’s
“actions are likely to cause confusion with [that] mark.” The
Sports Auth., Inc. v. Prime Hosp. Corp., 89 F.3d 955, 960 (2d
Cir. 1996); see also Tiffany & Co. v. Costco Wholesale Corp.,
971 F.3d 74, 92 (2nd Cir. 2020). The parties do not dispute
these

basic

elements

of

a

trademark

claim.

Rather

the

Trademark Defendants argue that their use of the Barbie Mark
was “fair use.”
When

a

person

“uses

the

words

constituting

[a

registered] mark in a purely descriptive sense, this use may
qualify as permissible fair use.” Id. To demonstrate fair
use, a defendant must establish that it used the allegedly
infringing

term

“(1)

other

than

as

a

mark;

(2)

in

a

descriptive sense; and (3) in good faith.” JA Apparel Corp.
v. Abboud, 568 F.3d 390, 400 (2d Cir. 2009); EMI Catalogue
P’ship v. Hill, Holliday, Connors, Cosmopulos Inc., 228 F.3d
56, 64 (2d Cir. 2000). Here, the Court is not persuaded the
Trademark Defendants have made a compelling case for fair
use, and thus Mattel has demonstrated a likelihood of success
on its trademark claims.
First, “a defendant uses a term as a mark when it employs
it as a symbol to attract public attention or to identify and
8

distinguish goods or services and to indicate their source.”
Tiffany, 971 F.3d at 92. Here, the Court is persuaded that
the Trademark Defendants have used the Barbie term as a mark.
Specifically,

the

Court

is

persuaded

that

the

Trademark

Defendants used the term Barbie as a means by which to attract
doll-accessory consumers to their Amazon page rather than
Mattel’s (or any other doll-accessory manufacturer’s) page.
But as Mattel points out, there is simply no reason for
the Trademark Defendants to use the term Barbie to describe
the size doll their accessories seek to fit. That size is
already included in the same bullet point:

9

Further, Mattel represented during oral argument that
the term “Barbie” does not refer to a specific size doll.
Accordingly, it would not be accurate for the Trademark
Defendants to refer to their clothes as fitting a “Barbie
doll”

as

consumers.

a

means

of

Instead,

describing
as

their

described

products’

above,

the

use

to

Court

is

persuaded that including the term “Barbie” in this instance
seems to be an attempt to drive traffic to the Trademark
Defendant’s webpage.
Second, “[w]hether a phrase is descriptive refers to its
tendency to describe the goods in question in a broad sense,
including not only words that describe a characteristic of
the goods such as size or quality, but also words or images
that more abstractly identify some information about the
goods in question.” Tiffany, 971 F.3d at 93; Cosmetically
Sealed Indus. v. Chesebrough-Pond’s USA Co., 125 F.3d 28, 30
(2d Cir. 1997). Here again, the Court is not persuaded that
the

Trademark

descriptively.

Defendants
For

have

instance,

used
the

the

term

Trademark

“Barbie”
Defendants

represent that they sell “5 Sets Barbie Clothes,” which is
not a necessarily a description of the products being sold,
10

but rather, a statement regarding the brand of the products.
In addition, as discussed above, Mattel has represented that
“Barbie” dolls come in various shapes and sizes, such that
using the term “Barbie” in an omnibus fashion would not
necessarily assist a consumer in understanding a product’s
use.
Finally, the Court is further not persuaded that the
Trademark Defendants have used the term in good faith. “The
inquiry

into

the

defendant’s

good

faith

‘concerns

the

question whether the user of a mark intended to create
consumer confusion as to source or sponsorship.’” JA Apparel,
568 F.3d at 401 (quoting EMI, 228 F.3d at 66–67). As noted
above, the Trademark Defendants use the term “Barbie Clothes”
at least one time in a manner that may cause reasonable
consumers to believe their products are made by Mattel. Worse
yet, the Trademark Defendants do not make clear that they are
in no way affiliated with Mattel, either as a licensee of the
Barbie Mark or as a subsidiary. As a result, consumers may
perceive the presence of the Barbie Mark as indicative of
Mattel’s association with the quality of products being sold.
While the Trademark Defendants argue that the product reviews
of the Amazon page submitted to the Court shows little
consumer confusion, the comments themselves are anecdotal at

11

best and shed no light on whether the consumers are aware of
the product’s true origin.
While

it

is

ultimately

possible

that

the

Trademark

Defendants could convince a jury that their use of the Barbie
Mark constitutes “fair use,” at this preliminary stage, the
Court is not persuaded that the Trademark Defendants have
made

a

sufficiently

Accordingly,

the

Court

compelling
will

case

grant

for

Mattel’s

fair
motion

use.
for

attachment as to the Trademark Defendants.
2.

Copyright Claims

The

relevant

copyrighted

Illustration,” is as follows:

12

work

here,

the

“Barbie

The Copyright Defendants’ use of the Barbie Illustration is
as follows:

13

Under the Copyright Act, a person who violates any of
the exclusive rights of the owner of a valid copyright is
liable for copyright infringement. See 17 U.S.C. § 106; Sony
Corp. v. Universal City Studios, Inc., 464 U.S. 417, 433
(1984).

The

parties

do

not
14

dispute

that

the

Copyright

Defendants used the Barbie Illustration, a copyrighted work
owned by Mattel, on the packaging of one of its products. And
the parties do not appear to dispute that the Copyright
Defendants’ use falls within the exclusive rights guaranteed
to Mattel by the statute. See Motion at 5; see also 17 U.S.C.
§ 106(1), (5). Instead, the Copyright Defendants argue that
their use of the Barbie Illustration is not an infringement
because it constitutes “fair use.”
The “fair use of a copyrighted work . . . is not an
infringement of copyright.” 17 U.S.C. § 107. “In determining
whether the use made of a work in any particular case is a
fair use the factors to be considered shall include: (1) the
purpose and character of the use, including whether such use
is of a commercial nature or is for nonprofit educational
purposes; (2) the nature of the copyrighted work; (3) the
amount and substantiality of the portion used in relation to
the copyrighted work as a whole; and (4) the effect of the
use upon the potential market for or value of the copyrighted
work.” Id.
“In fair use litigation, courts undertake a case-by-case
analysis in which each factor is considered, and the results
are weighed together, in light of the purposes of copyright.”
Fox News Network, LLC v. Tveyes, Inc., 883 F.3d 169, 176 (2d
Cir. 2018). The four factors are not exclusive. Swatch Grp.
15

Mgmt. Servs. Ltd. v. Bloomberg L.P., 756 F.3d 73, 81 (2d Cir.
2014).
Taking each factor in turn:
a.
“The

Purpose and Character of the Use

first

statutory

factor

specifically

instructs

courts to consider whether copyrighted materials are used for
a commercial purpose or for a nonprofit educational purpose,
the former tending ‘to weigh against a finding of fair use.’”
TCA Television Corp. v. McCollum, 839 F.3d 168, 183 (2d Cir.
2016) (quoting Campbell v. Acuff–Rose Music, Inc., 510 U.S.
569, 585 (1994)). There is no dispute that the Copyright
Defendants’ use of the Barbie Illustration is a commercial
use. Thus, this factor weighs against finding fair use.
The Copyright Defendants seek to minimize the impact of
this

factor

by

arguing

that

their

use

of

the

Barbie

Illustration is “highly transformative.” (Opposition at 8.)
Indeed “the more transformative the new work, the less will
be the significance of other factors, like commercialism,
that may weigh against a finding of fair use.” Campbell, 510
U.S. at 579. But the Copyright Defendants ignore that with
respect to a work being transformative, “the critical inquiry
is whether the new work uses the copyrighted material itself
for a purpose, or imbues it with a character, different from
that for which it was created.” TCA Television, 839 F.3d at
16

180. And here, the Copyright Defendants’ use of the Barbie
Illustration does not appear to be used for any particular
purpose other than to sell doll-related merchandise. While
this is slightly distinct from the purpose of the Style Guide,
which was created to promote Mattel’s movie, Barbie: A Fashion
Fairytale (2010), ultimately both Mattel and the Copyright
Defendants are using the Barbie Illustration to sell dollrelated products. Thus, the Copyright Defendants’ arguments
related to transformative use are unpersuasive, and this
factor weighs against finding fair use.
b.

Nature of Copyrighted Work

The second statutory factor seeks to protect those works
which “are closer to the core of intended copyright protection
than others, with the consequence that fair use is more
difficult to establish when the former works are copied.” TCA
Television, 839 F.3d at 184; see also Campbell, 510 U.S. at
586. But this factor “has rarely played a significant role in
the determination of a fair use dispute.” Fox News Network,
883 F.3d at 178 (quoting Authors Guild v. Google, Inc., 804
F.3d 202, 220 (2d Cir. 2015)). The Copyright Defendants
present no substantial argument that the Barbie Illustration
is undeserving of copyright attention. Thus, this factor also
weighs against finding fair use, though it “is not ever likely
to help much.” Campbell, 510 U.S. at 586.
17

c.

Amount and Substantiality of Use

The third statutory factor asks whether “the amount and
substantiality

of

the

portion

used

in

relation

to

the

copyrighted work as a whole are reasonable in relation to the
purpose of the copying.” Campbell, 510 U.S. at 586. In
assessing this factor, the Court considers “the quantity of
the

materials

used,”

as

well

as

“their

quality

and

importance.” Id. at 587. “The clear implication of the third
factor is that a finding of fair use is more likely when small
amounts, or less important passages, are copied than when the
copying is extensive, or encompasses the most important parts
of the original.” Authors Guild, 804 F.3d at 221. “The obvious
reason for this lies in the relationship between the third
and the fourth factors,” as the “larger the amount, or the
more important the part, of the original that is copied, the
greater the likelihood that the secondary work might serve as
an effectively competing substitute for the original, and
might therefore diminish the original rights holder’s sales
and profits.” Id.
Weighing in the Copyright Defendants’ favor is the fact
that the Barbie Illustration only comprises a small portion
of the entirety of the copyrighted work (the Style Guide).
And the Copyright Defendants’ use of the Barbie Illustration
encompasses

only

a

small

portion
18

of

their

products’

packaging. Thus, the Copyright Defendants have only copied a
small portion of the copyrighted work.
But the Copyright Defendants copied the face of the
Barbie Illustration –- the most important and identifying
portion of the Barbie Illustration. Nor does there appear to
be any justification for the Copyright Defendants to use any
amount of the copyrighted work. See, e.g., Campbell, 510 U.S.
at 586-87 (noting that the amount of the copyrighted work
used should be “reasonable in relation to the purpose of the
copying”). Because the Copyright Defendants have presented no
convincing reason why copying the key portion of Mattel’s
illustration was necessary, the Court can infer that they did
so in order to capitalize on Mattel’s reputation. On balance,
therefore, this factor likewise undercuts a finding of fair
use.
d.

Effect on Potential Market

The fourth factor “focuses on whether the copy brings to
the marketplace a competing substitute for the original, or
its

derivative,

so

as

to

deprive

the

rights

holder

of

significant revenues because of the likelihood that potential
purchasers may opt to acquire the copy in preference to the
original.” Google Books, 804 F.3d at 223; Fox News Network,
883 F.3d at 179. This factor requires the Court to assess
both “the market harm caused by the particular actions of the
19

alleged infringer” in addition to the market harm that would
result from “unrestricted and widespread conduct of the same
sort.” Campbell, 510 U.S. at 590; Fox News Network, 883 F.3d
at 179.
Here also, the Court is persuaded that this factor weighs
against a finding of fair use. In particular, if the Copyright
Defendants, and other market participants, were to engage in
“unrestricted or widespread conduct of the same sort,” there
is a clear market harm to Mattel. If doll clothing and
accessory manufacturers were given free rein to copy Mattel’s
copyrighted

work,

without

any

apparent

justification

or

license, Mattel would have little ability to protect its
intellectual property or license the use of such images. Even
allowing such a small amount of copying would likely open the
door for manufacturers to use increasing amounts of Mattel’s
copyrighted materials. Mattel would likely be forced to bring
lawsuit after lawsuit to protect its intellectual property.
The Court acknowledges that given the minimal amount of
the original work copied, and the minimal amount it featured
on

the

Copyright

Defendants’

products’

packaging,

it

is

unlikely that the Copyright Defendants’ use in this specific
case will completely “usurp the market for the copyrighted
work.” TCA Television Corp. v. McCollum, 151 F. Supp. 3d 419,
434 (S.D.N.Y. 2015). And the Court acknowledges that the
20

Copyright Defendants’ product, a doll closet, is not the same
as the copyrighted work, a collection of illustrations. But
Mattel persuasively responds that it may put the Style Guide
generally, or the Barbie Illustration specifically, to any
number of uses in the future, including the marketing and
promotion

of

doll

accessories.

Therefore,

the

Copyright

Defendants’ use nonetheless “impair[s] the value of Mattel’s
copyright.” (See Reply at 9-10.)
For

these

reasons,

allowing

direct

copying

without

justification, even in such a minimal fashion, would result
in market harm to Mattel. Therefore, this factor weighs
against a finding of fair use. And, given that each of the
four factors in the fair-use analysis weighs against the
Copyright Defendants, the Court is not persuaded that the
Copyright

Defendants

have

raised

a

compelling

fair-use

defense. Because Defendants have not otherwise challenged
Mattel’s likelihood of success on the merits, the Court will
grant Mattel’s Motion as to the Copyright Defendants.
IV.

ORDER

For the reasons stated above, it is hereby
ORDERED that the motion by plaintiff Mattel, Inc. for
prejudgment attachment pursuant to Rule 64 of the Federal
Rules of Civil Procedure (see Dkt. No. 22) is GRANTED as to
(a) the entities doing business as Unicorn Element at the URL
21

www.unicornelement.net (“Unicorn Element”); (b) the entities
doing business as the PayPal, Inc. (“PayPal”) merchant
(the “PayPal Merchant”); (c) the entities doing business
using

the

email

address

[e-mail]

(“[e-mail]”); (d) the entities doing business
on amazon.com under the brand name Zita Element, under the
store name Zita Element, and/or under the business name Yang
Liuhui (collectively, “Zita Element”); (e) the entities doing
business on amazon.com under the brand name Ecore Fun, under
the store name EC2Toy, and/or under the business name Huang
Qiong (collectively, “Ecore Fun”); (f) EMMS Trading GmbH
(“EMMS”); (g) Zhijian Li (“Li”); (h) Yang Liuhui (“Liuhui”);
and (i) Huang Qiong (“Qiong”).
SO ORDERED.
Dated: New York, New York
04 June 2021

22