ABC v. DEF

Filing 73

JUDGMENT AND ORDER GRANTING PLAINTIFF'S MOTION FOR DEFAULT JUDGMENT AND RELATED RELIEF: IT IS HEREBY ORDERED that: 1. Playboy's Motion for Default Judgment and Related Relief is GRANTED; 2. Under Federal Rule of Civil Procedure 55(b)( 2), default judgment is hereby entered against each Defendant for each and all of the Counts alleged in Playboy's Amended Complaint, namely, as further set forth herein. Under the Lanham Act, 15 U.S.C. § 1117(c), Playboy is entitled t o statutory damages of $100,000 per registered trademark, for a total trademark damages award of $2,500,000 jointly and severally against the Defendants. 5. Under the Copyright Act, 17 U.S.C. § 504, Playboy is entitled to statutory d amages of $30,000 per registered copyright, for a total copyright damages award of $60,000 jointly and severally against the Defendants, as further set forth herein. Upon service of this Order, the Defendants, and other Restrained Parties s hall be deemed to have actual notice of the issuance and terms of the permanent injunction, and any act by any of the Restrained Parties in violation of any of the terms of the permanent injunction may be considered and prosecuted as contempt of Co urt, and such other, further relief this Court deemsjust and proper. Within 14 days of entry of this Order, the Defendants shall file for dissolution of the Fraudulent Entities (as depicted within Exhibit A) with each of the entities' respective states of formation and provide evidence of the same to the Court and to the Plaintiff. Should the Defendants fail to file for dissolution and provide evidence thereof, the Plaintiff may move the Court for specific performance under Federal Rule of Civil Procedure 70, and any further relief the Court deems just and proper. In the event Playboy identifies additional counterfeit websites, domains, or fraudulent entities in connection with Defendants' counterfeiting scheme, Playboy may move the Court for an order modifying this injunction as appropriate. To the extent the Defendants attempt to use confusingly similar variations of the Counterfeit Websites, Counterfeit Domains, or Additional Domain with URLs that incorporate the Playboy Marks, Playboy may serve this Order on the website registrars and/or other third parties responsible for services involved with keeping the websites online, in order to freeze and/or make the websites and any confusingly similar variations of the Co unterfeit Websites, Counterfeit Domains, and/or Additional Domain frozen and inaccessible to the Defendants. IT IS FURTHER ORDERED that Court hereby releases the security posted by Playboy in the amount of $15,000 that was posted in connectio n with the temporary restraining order and preliminarily injunction order. See ECF 41. IT IS FURTHER ORDERED THAT, as good cause for alternative service continues to exist in this case, Playboy may serve the filings in this case upon all Defendan ts by email and/or other electronic means, and/or by overnight courier, using the identifying information emails set forth in Exhibit B, and/or Defendants' purported physical addresses to the degree necessary to ensure and effectuate service. SO ORDERED. Bunny Girl Union, Bunny Hunter, LLC, BunnyGirl Certification Institute, Ming Cai, E-Mode Limited, Fancy Space (Fujian) Brand Management Co. Ltd, Flower Color Space (Fujian) Brand Management Company Ltd, John Fu, Haihan Fashion (Shang hai) Enterprises Development Co., LTD., Huahua Rabbit (Xiamen) Health Science and Technology Co., LTD, Junhan Huang, Huase Space (Fujian) Brand Management Co., Ltd, International Model Certification Association, Kai Ming Lai, King Wong, Fu Manhua, Mo untain Crest Acquisition Corp., PLBY Group Inc., Playboy (China) Brand Management Center, Playboy Enterprises (Asia) Limited, Playboy Enterprises International, Inc., Playboy Enterprises, Inc., Playboy Tobacco Group Limited, Pleasure International, C orp., Wong's Bank Group, Wong's Capital Holding Group Limited, Wong's Foundation, Wong's International Bank, Wong's Syndicate, World Future Leader University, World Industrial Capital Organization, LingLing Zhang, Bunnies Own er Group and Bunny Girl Foundation terminated., Motions terminated: 63 MOTION for Default Judgment as to Defendants Playboy Enterprises, Inc.; PLBY Group, Inc.; Junhan Huang, aka John Huang; Mountain Crest Acquisition Corp., Playboy Enterprises (Asia) Limited; Wongs Capital Holding Group Limited; Playboy (China) Br filed by Playboy Enterprises International, Inc. (Signed by Judge Arun Subramanian on 9/29/2023) (vfr) Transmission to Finance Unit (Cashiers) for processing.

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
:
PLAYBOY ENTERPRISES
INTERNATIONAL, INC.,

:
:
Plaintiff,

v.
PLAYBOY ENTERPRISES, INC.; PLBY
GROUP, INC.; JUNHAN HUANG, AKA JOHN
HUANG; MOUNTAIN CREST ACQUISITION
CORP.; PLAYBOY ENTERPRISES (ASIA)
LIMITED; WONG’S CAPITAL HOLDING
GROUP LIMITED; PLAYBOY (CHINA)
BRAND MANAGEMENT CENTER;
PLAYBOY TOBACCO GROUP LIMITED;
HUAHUA RABBIT (XIAMEN) HEALTH
SCIENCE AND TECHNOLOGY CO., LTD;
HAIHAN FASHION (SHANGHAI)
ENTERPRISES DEVELOPMENT CO., LTD.;
BUNNIES OWNER GROUP; BUNNYGIRL
CERTIFICATION INSTITUTE; BUNNY GIRL
FOUNDATION, BUNNY GIRL UNION;
BUNNY HUNTER, LLC; INTERNATIONAL
MODEL CERTIFICATION ASSOCIATION;
PLAYBOY ENTERPRISES
INTERNATIONAL, INC.; PLEASURE
INTERNATIONAL, CORP.; WONG’S BANK
GROUP; WONG’S FOUNDATION; WONG’S
INTERNATIONAL BANK; WONG’S
SYNDICATE; WORLD FUTURE LEADER
UNIVERSITY; WORLD INDUSTRIAL
CAPITAL ORGANIZATION; FU MANHUA;
MING CAI; LINGLING ZHANG; JOHN FU;
E-MODE LIMITED; HUASE SPACE
(FUJIAN) BRAND MANAGEMENT CO.,
LTD.; KING WONG; KAI MING LAI;
FLOWER COLOR SPACE (FUJIAN) BRAND
MANAGEMENT COMPANY LTD.; and

21-cv-6419 (AS)

:
:
:
:
:
:
:
:

JUDGMENT AND ORDER
GRANTING PLAINTIFF’S
MOTION FOR DEFAULT
JUDGMENT AND
RELATED RELIEF

Case 1:21-cv-06419-AS Document 69 Filed 09/06/23 Page 2 of 12

FANCY SPACE (FUJIAN) BRAND
MANAGEMENT CO. LTD.
Defendants.

This matter having come before the Court on Plaintiff Playboy Enterprises International,
Inc.’s (“Playboy”) Motion for Default Judgment and Related Relief, under Federal Rules of Civil
Procedure 55 and 65; and this Court having reviewed the papers and proceedings in support of
that Motion, including Playboy’s Amended Complaint, Memorandum of Law in support of the
Motion, and the Declarations of Jennifer McCarthy and Maria R. Sinatra, along with
accompanying exhibits; and this Court being fully satisfied that the Defendants1 were properly
served with summonses, the Amended Complaint, Dkt. 25, and all other pertinent papers and
proceedings in this action, and failed to respond as required under Federal Rule of Civil
Procedure 12; and good cause being shown therefor;
THE COURT HEREBY FINDS THAT:
Jurisdiction and Venue
1. This Court has subject matter jurisdiction over Playboy’s claims under 28 U.S.C. §§ 1331

1

Defined as Playboy Enterprises, Inc.; PLBY Group, Inc.; Junhan Huang, aka John Huang;
Mountain Crest Acquisition Corp., Playboy Enterprises (Asia) Limited; Wong’s Capital Holding
Group Limited; Playboy (China) Brand Management Center; Playboy Tobacco Group Limited;
Huahua Rabbit (Xiamen) Health Science and Technology Co., Ltd.; Haihan Fashion (Shanghai)
Enterprises Development Co., Ltd., Bunnies Owner Group; Bunnygirl Certification Institute; Bunny
Girl Foundation; Bunny Girl Union; Bunny Hunter LLC; International Model Certification
Association; Playboy Enterprises International, Inc.; Pleasure International Corp.; Wong’s Bank
Group; Wong’s Foundation; Wong’s International Bank; Wong’s Syndicate; World Future Leader
University; World Industrial Capital Organization, Fu Manhua, Ming Cai, Lingling Zhang, John Fu,
E-Mode Limited, HuaSe Space (Fujian) Brand Management Co., Ltd., King Wong, Kai Ming LAI,
Flower Color Space (Fujian) Brand Management Company Ltd., and Fancy Space (Fujian) Brand
Management Co. Ltd.

2

& 1338, and 15 U.S.C. § 1121. See Amended Complaint ¶¶ 15-17.
2. This Court has personal jurisdiction over the Defendants because:
a. each Defendant has had continuous, systematic, and substantial contacts within
New York, including doing business in New York and targeting consumers in
New York, causing harm to Playboy’s business within this Judicial District, and
registering some of the Fraudulent Entities2 with the New York Secretary of State;
b. The Defendants have created the Counterfeit Websites, which is accessible to
consumers in New York and bears unauthorized copies of Playboy’s registered
trademarks and copyrighted content. Each Defendant has targeted New York
consumers by operating a fully interactive online website that is viewable by New
York consumers;
c. Defendants have sold services through the Counterfeit Websites to consumers
within the United States, including upon information and belief to consumers
within New York;
d. the Defendants are not independently managed, but are a group of interrelated
entities that share common and identical ownership through Defendant Junhan
Huang. Upon information and belief, the Defendants are financially dependent
upon one another as they were created for the purpose of a single counterfeiting

2

Defined as Defendants Playboy Enterprises, Inc., PLBY Group, Inc., Bunnies Owner Group,
Bunnygirl Certification Institute, Bunny Girl Foundation, Bunny Girl Union, Bunny Hunter
LLC, International Model Certification Association, Mountain Crest Acquisition Corp., Playboy
Enterprises International, Inc., Pleasure International Corp., Wong’s Bank Group, Wong’s
Foundation, Wong’s International Bank, Wong’s Syndicate, World Future Leader University,
and World Industrial Capital Organization.
3

scheme. Upon information and belief, the Defendants do not maintain
independent corporate boards from one another, share email addresses, and
market each other collectively through the use of forged documents; and
e. Defendants have registered Fraudulent Entities in the state of New York, availing
themselves of the privilege of conducting business in New York, and have
utilized instrumentalities located in New York and physical addresses located in
this Judicial District to carry out the infringing and fraudulent acts of which
Playboy complains.
See Amended Complaint ¶¶ 18-22; Memorandum of Law in Support of Default Judgment
(“Memo of Law”), at 2-3.
3. Venue is proper in this judicial district under 28 U.S.C. § 1391 because:
a. A substantial part of the events or omissions giving rise to Playboy’s claims has
occurred in this Judicial District because Defendants have registered some of the
Fraudulent Entities in the State of New York with the New York Secretary of
State utilizing addresses within this Judicial District, and because a substantial
part of the harm caused by Defendants has occurred in this Judicial District.
Through the Defendants’ Fraudulent Entities with addresses listed in this Judicial
District, Defendants have been able to perpetuate the acts complained of herein.
See Amended Complaint ¶ 23.
2. The Complaint pleads sufficient facts and states claims against Defendants for:
a. Trademark counterfeiting, unfair competition, and false designation of origin, in
violation of the Lanham Act, Sections 32 and 43(a) (15 U.S.C. §§ 1114, 1125(a)
(Counts I and III) (Memo of Law at 12-15);
4

b. Copyright infringement in violation of the Copyright Act (17 U.S.C. § 101 et
seq.) (Count II) (Memo of Law at 14-15); and
c. Trademark infringement and unfair competition in violation of New York
common law (Count IV) (Memo of Law at 13-14).
3. The Court finds that Playboy has provided sufficient facts demonstrating that
Defendants’ conduct in this action was undertaken willfully, particularly in light of the
multiple forged documents created by the Defendants in an effort to appear that they are
Playboy, or are authorized to act on behalf of Playboy when they are not (Amended
Complaint ¶¶ 182-266; Memo of Law at 15-16).
4. The Court finds that Playboy’s request for trademark statutory damages in its Motion is
reasonable, particularly as to Defendants’ willful infringement and the amount of
Plaintiff’s actual lost revenue that can be attributed to Defendants’ infringing conduct,
within the Court’s discretion, and permitted under the Lanham Act. See 15 U.S.C. §
1117(c); Jennifer McCarthy Declaration executed August 16, 2023 (“McCarthy Decl”) ¶¶
17-23. The Court further finds that statutory damages in this case in the amount requested
by Playboy is warranted to deter the Defendants and others from engaging in similar
online counterfeiting schemes.
5. The Court further finds that Playboy’s request for copyright infringement statutory
damages in its Motion is reasonable, again due to Defendants’ willful infringement. The
amount of damages per copyright registration is under the threshold permitted by the
Copyright Act and warranted due to the egregious nature of Defendants’ counterfeiting
scheme. See 17 U.S.C. § 504; Jennifer McCarthy Declaration ¶ 12 (a)-(q).

5

6. The Court finds that Playboy has established each of the factors required for a permanent
injunction, namely (1) Playboy has shown it is entitled to injunctive relief under the
Lanham Act and Copyright Act, and (2) Playboy has met the prerequisites for issuance of
an injunction showing actual success on the merits of its claims and irreparable harm. 15
U.S.C. § 1116; 17 U.S.C. § 502; Pitbull Prods., Inc. v. Universal Netmedia, Inc., No. 07cv-1784, 2007 WL 3287368, at *5 (S.D.N.Y. Nov. 7, 2007) (internal quotation omitted);
see also Gucci Am., Inc. v. Tyrrell-Miller, 678 F. Supp. 2d 117, 120 (S.D.N.Y. 2008) (quoting
Gucci Am., Inc. v. Duty Free Apparel, Inc., 286 F. Supp. 284, 290 (S.D.N.Y. 2003)). Upon
the Court's request, counsel for Plaintiff also submitted a letter justifying the particular relief
in the permanent injunction, with relevant authority. Dkt. 72. Though dissolution is strong
medicine, it is reasonable when the entities' very names and reasons for being are infringing.
IT IS HEREBY ORDERED that:
1. Playboy’s Motion for Default Judgment and Related Relief is GRANTED;
2. Under Federal Rule of Civil Procedure 55(b)(2), default judgment is hereby entered
against each Defendant for each and all of the Counts alleged in Playboy’s Amended
Complaint, namely:
a. Trademark Counterfeiting, in violation of Section 32 of the Lanham Act (15
U.S.C. § 1114) (“Count 1”);
b. Copyright Infringement, in violation of (17 U.S.C. § 101 et seq.) (“Count 2”)
c. Trademark infringement, false designation of origin, and unfair competition, in
violation of Section 43(a) of the Lanham Act (15 U.S.C. § 1125(a)) (“Count 3”);
and
d. Trademark infringement and unfair competition, in violation of New York
common law (“Count 4”)
3. The foregoing violations of Playboy’s rights, and federal and state law, were willful;
6

4. Under the Lanham Act, 15 U.S.C. § 1117(c), Playboy is entitled to statutory damages of
$100,000 per registered trademark, for a total trademark damages award of $2,500,000
jointly and severally against the Defendants.
5. Under the Copyright Act, 17 U.S.C. § 504, Playboy is entitled to statutory damages of
$30,000 per registered copyright, for a total copyright damages award of $60,000 jointly
and severally against the Defendants.
6. Under Federal Rule of Civil Procedure 65, each Defendant, and its officers, agents,
servants, employees, and attorneys, and all those in active concert or participation with
them, including but not limited to the Xiaotusky Associates3, who receive actual notice of
this Order by personal service or otherwise (“Restrained Parties”), are hereby
permanently enjoined and restrained from, directly or indirectly, anywhere in the world:
a. Using or counterfeiting the Playboy Marks4, the PLAYBOY© Copyrights5,
and/or associated common law rights, or any confusingly similar marks,
reproduction, counterfeit copies, or spurious imitations thereof, on or in
connection with the offering of any goods and/or services, licensing services,

3

Defined as Xiaotusky (Shenzhen) Biological Technology Co., Ltd. Shenzhen Zhuoran
Intellectual Property Agency Co., Ltd.; Lin Da Rong; Xiaotusky (Guangzhou) Enterprise
Development Co., Ltd; Fu Limei; Rabbit Grandpa (Hainan ) Brand Management Co., Ltd; Chen
Jian; Xiaotusky (Shenzhen) Biotechnology Co., Ltd. (“Xiaotusky Biotechnology”); Xiaotusky
(Shenzhen) Trading Company Ltd. (“Xiaotusky Trading”); Xiaotusky (Shenzhen) Brand
Management Co., Ltd. (“Xiaotusky Brand”); and Huahua Rabbit (Hangzhou) E-commerce Co.,
Ltd.
4

Defined as the PLAYBOY® Trademarks, RABBIT HEAD DESIGN® Trademarks, BUNNY
STORE® Trademark, PLBY® Trademark, and PLEASURE FOR ALL® Trademarks
collectively, along with their common low rights, as defined in Playboy’s Amended Complaint.
5

Defined as U.S. Copyright Registration Nos. VA 2-144-651, and VA 2-174-035.
7

websites, or social media, including but not limited to, owning or operating the
Counterfeit Websites6, Additional Domain7 and/or Counterfeit Domains8;
b. Using or counterfeiting the Playboy Marks and/or PLAYBOY© Copyrights, or
any confusingly similar marks, on or in connection with the Fraudulent Entities or
the legal name or dba of any entity;
c. Operating any other website, licensing business or other business, entity, or store
that purports to originate from Playboy, or to be sponsored or licensed by, or
affiliated with Playboy or Playboy’s authentic Website (www.playboy.com), or
contains any portion of the Playboy Marks within its name or d.b.a., when it is
not;
d. Forging, creating, circulating, or otherwise using any documents or materials
purporting to be executed by Playboy, or any of its affiliated entities, including
but not limited to forging signatures, seals, or other documents, including but not
limited to the Invalid Notarizations, and any other documents purporting to be
notarized by Ms. Olivia Liu on behalf of Defendant King Wong and/or Playboy
Enterprises International, Inc.;
e. Filing any document with any organization, including but not limited to U.S.
domestic government agencies, and/or foreign governments or governmental
agencies, purporting to be on behalf of Playboy, including but not limited to filing

6

Defined as www.playboychinabrand.com, and www.playboygo.com.

7

Defined as http://www.papaintl.com/.

8

Defined as www.playboy.com.hk, www.playboyint.com, and www.playboylicense.com.
8

any documents with the China National Intellectual Property Administration
purporting to be on behalf of Playboy Enterprises International, Inc. or any
purported licensee;
f. Forging, creating, circulating, or otherwise using any documents or materials
purporting to be issued by any U.S. domestic government agencies, and/or foreign
governments or governmental agencies in connection with Playboy and its
business, including but not limited to trademark registration certificates, or
copyright registration certificates;
g. Registering, owning, or using any domain name that consists of any of the
Playboy Marks, or includes “Playboy” in the domain portion of the domain name
and is using in connection with the Playboy Marks, PLAYBOY© Copyrights,
and/or any other Playboy source identifier, or that is confusingly similar thereto,
or that is calculated to confuse consumers into thinking that the website(s)
accessible via the domain name(s) originate with/from Playboy, or is sponsored or
licensed by, or affiliated with, Playboy or Playboy’s authentic Website, when it
is/they are not;
h. Registering, owning, or using any entity whose name or dba consists of the
Playboy Marks, or includes “Playboy”, or that is confusingly similar to any of the
Playboy Marks, or that is calculated to confuse consumers into believing that
Defendants are Playboy, affiliated with Playboy, or sponsored by Playboy, when
they are not;
i. Using in connection with Defendants’ activities, goods, or services (or purported
goods or services) any false or deceptive designations, representations, or
9

descriptions of Defendants or their activities, goods, or services (or purported
goods or services), whether by symbols, words, designs, statements, photographs,
or other devices, which would damage or injure Playboy or its customers, or
which would give Defendants an unfair competitive advantage or result in
consumer deception;
j. Committing other acts calculated to cause consumers to believe that Defendants’
domain names, websites, web content, goods/or services are offered under the
authorization, sponsorship, supervision, or control of Playboy, or otherwise are
connected with Playboy, or Playboy’s authentic Website, when they are not;
k. Further infringing the Playboy Marks; PLAYBOY© Copyrights, and/or any other
Playboy source identifier, or damaging any associated goodwill;
l. Stealing Playboy’s customer’s or potential customer’s, licensees, or potential
licensees;
m. Misappropriating that which rightfully belongs to Playboy, its customers or
potential customers, or in which Playboy or its customers or potential customers
have a proprietary interest;
n. Using, linking to, transferring, selling, exercising control over, or otherwise
owning or accessing the Counterfeit Websites, Counterfeit Domains, and
Additional Domain;
o. Using, linking to, transferring, selling, exercising control over, or otherwise
owning or using the Fraudulent Entities;
p. Using, transferring, exercising control over, or otherwise accessing any accounts
used in the transfer of money or electronic currency, or in the processing of card10

based transactions associated with the Counterfeit Websites, Counterfeit
Domains, Additional Domain or Fraudulent Entities, as a means to further their
fraudulent counterfeiting scheme.
Upon service of this Order, the Defendants, and other Restrained Parties shall be deemed
to have actual notice of the issuance and terms of the permanent injunction, and any act by any
of the Restrained Parties in violation of any of the terms of the permanent injunction may be
considered and prosecuted as contempt of Court, and such other, further relief this Court deems
just and proper. Within 14 days of entry of this Order, the Defendants shall file for
dissolution of the Fraudulent Entities (as depicted within Exhibit A) with each of the
entities’ respective states of formation and provide evidence of the same to the Court and to
the Plaintiff. Should the Defendants fail to file for dissolution and provide evidence thereof, the
Plaintiff may move the Court for specific performance under Federal Rule of Civil Procedure 70,
and any further relief the Court deems just and proper.
In the event Playboy identifies additional counterfeit websites, domains, or fraudulent
entities in connection with Defendants’ counterfeiting scheme, Playboy may move the Court for
an order modifying this injunction as appropriate. To the extent the Defendants attempt to use
confusingly similar variations of the Counterfeit Websites, Counterfeit Domains, or Additional
Domain with URLs that incorporate the Playboy Marks, Playboy may serve this Order on the
website registrars and/or other third parties responsible for services involved with keeping the
websites online, in order to freeze and/or make the websites and any confusingly similar
variations of the Counterfeit Websites, Counterfeit Domains, and/or Additional Domain frozen
and inaccessible to the Defendants.

11

EXHIBIT A

13

Company
Name

Incorporator

State

Playboy
Enterprises, Inc.
PLBY Group,
Inc.
Bunnies Owner
Group

Junhan Huang

New York

Junhan Huang

New York

Junhan Huang

California

Bunnygirl
Certification
Institute
Bunny Girl
Foundation
Bunny Girl
Union

Junhan Huang

Colorado

Junhan Huang

Colorado

May 5, 2021

Junhan Huang

California

January 19,
2021

Bunny Hunter
LLC
International
Model Cert.
Assoc.
Mountain Crest
Acquisition
Corp.
Playboy
Enterprises
International Inc
Pleasure
International
Corp.
Wong’s Bank
Group
Wong’s
Foundation
Wong’s
International
Bank
Wong’s
Syndicate
World Future
Leader
University

Junhan Huang

New York

May 5, 2021

Junhan Huang

California

January 18,
2021

Junhan Huang

New York

January 19,
2021

3230 Walnut St.
Denver, CO 80205
1620 Waterloo St.
Los Angeles, CA
09926
446 W 58th St.
New York, NY 10019
811 Fedora St.
Los Angeles, CA
90005
529 W 150th
New York, NY 10031

Junhan Huang

Georgia

December 11,
2020

115 Broad St. Sw
Atlanta, GA 30303

Junhan Huang

New York

November 5,
2020

127 Post Ave
New York, NY 10034

Junhan Huang

Colorado

May 5, 2021

Junhan Huang

Colorado

May 4, 2021

Junhan Huang

Colorado

April 14, 2021

2747 Arapahoe St
Denver, CO 80205
2049 Emerson St
Denver, CO 80205
2512 California St
Denver, CO 80205

Junhan Huang

Delaware

Junhan Huang

Colorado

January 21,
2021
May 4, 2021

14

Incorporation Claimed
Date
Mailing/Service
Address
March 3, 2020 316 W. 95th St.
New York, NY 10025
February 25,
511 W. 134th St.
2021
New York, NY 10031
April 5, 2021
3140 Blanchard St.
Los Angeles, CA
90063
March 18,
2225 Emerson St.
2021
Denver, CO 80205

1025 Kirkwood St.
Wilmington, DE 19801
861 Galapago St
Denver, CO 80204

Company
Name

Incorporator

World Industrial Junhan Huang
Capital
Organization

State

Colorado

Incorporation Claimed
Date
Mailing/Service
Address
September 24, 5030 Boardwalk Drive
2018
Suite 818
Colorado Springs, CO
80919
37-12 Prince St.
Unit 8C
Flushing, NY 11354

15

EXHIBIT B

16

1. [e-mail]
2. [e-mail]
3. [e-mail]
4. [e-mail]
5. [e-mail]
6. [e-mail]
7. [e-mail]
8. [e-mail]
9. [e-mail]
10. [e-mail]
11. [e-mail]
12. [e-mail]
13. [e-mail]
14. [e-mail]

17