ABC v. DEF

Filing 20

PRELIMINARY INJUNCTION ORDER: The injunctive relief previously granted in the TRO shall remain in place through the pendency of this litigation, and issuing this Order is warranted under Federal Rule of Civil Procedure 65 and Section 34 of the Lan ham Act. Accordingly, Defendants are hereby restrained and enjoined from engaging in any of the following acts or omissions pending the final hearing and determination of this action or until further order of the Court and further set forth in th is Order. Defendants are hereby given notice that they may be deemed to have actual notice of the terms of this Order and any act by them or anyone of them in violation of this Order may be considered and prosecuted as in contempt of this Court. T he $5,000.00 bond posted by Plaintiff shall remain with the Court until a final disposition of this case or until this Order is terminated. This Order shall remain in effect during the pendency of this action, or until further order of the Cou rt. Any Defendants that are subject to this Order may appear and move to dissolve or modify the Order on two (2) days' notice to Plaintiff or on shorter notice as set by the Court. (Signed by Judge Ronnie Abrams on 5/17/2022) (rro) Transmission to Finance Unit (Cashiers) for processing.

Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 1 of 16

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
MOONBUG ENTERTAINMENT LIMITED,
Plaintiff
v.
ABDG STORE, ANIME-HOUSE STORE, ANYANG
FEEKER TRADING CO., LTD., BABY BOARD
GAME(DROP
SHIPPING)
STORE
STORE,
BAOKANWEIYI STORE, BLACK MAN K STORE,
CHANGSHA WODEMORE TECHNOLOGY CO.,
LTD., CLHW GROCERY STORE, CUTE SMALL
MOUSE TOY STORE, CUTE STICKER HOUSE
STORE, CXLIDY PARTY STORE, DAILY
BOUTIQUE DEPARTMENT STORE, DONGGUAN
NUOSHENG ELECTRONIC TECHNOLOGY CO.,
LTD., DONGGUAN TONGJIA TOYS CO., LTD.,
DONGYANG YADI PET PRODUCT CO., LTD., EE
PARTY
STORE,
EWEISER
ELECTRONIC
TECHNOLOGY
(SHENZHEN)
CO.,
LTD.,
FACAIPARTY STORE, FARSHUNIN STORE,
FOOK FONG TOY STORE, FUJIAN PROVINCE
JIANOU CITY RUIYI CRAFTS CO., LTD., FUN LE
TOY CITY STORE, FUN-PARTY STORE,
GONGTEN STORE, GUANGZHOU HAPPY
ISLAND TOYS CO., LTD., GUANGZHOU YIMAI
TRADING CO., LTD., HANGZHOU XINGGE GIFT
CO., LTD., HANGZHOU XINGGE GIFTS CO.,
LTD., HEBEI SHUOHUI PAPER PRODUCTS CO.,
LTD., HENAN FEEKER IMPORT AND EXPORT
CO., LTD., HENAN SENFA TRADING CO., LTD.,
INDECOR STORE, JINHUA ZHIBO GARMENT
CO., LTD., JINJIANG CHENGLE SHOES AND
GARMENT CO., LTD., JJ PARTY STORE, KIDSTOY STORE, LET'S PARTY TOGETHER STORE,
LIFE & ART STORE, LITTLE MONKEY TOY
STORE, LU WOOD STORE, MOTHER AND BABY
TOY STORE STORE, PESENAR STORE,
PESENAR1314 STORE, PHOTURT BACKDROPS
STORE, PIAOLIANG BABY STORE, PP BABY
STORE, PURPLE GAME STORE, QINGDAO
BAZHIZHI CULTURE CO., LTD., QUANZHOU
HAPPY BROTHERS TRADING CO., LTD.,
QUANZHOU JINHETUO PACKAGING SUPPLIES

CIVIL ACTION NO.
22-cv-2386 (RA)

PRELIMINARY
INJUNCTION ORDER

Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 2 of 16
CO., LTD., QUANZHOU LONGKUN ARTS AND
CRAFTS CO., LTD., SHANGHAI XINYAN
INDUSTRIAL CO., LTD., SHAOXING HUALAI
EMB. & HOME TEXTILE CO., LTD., SHOP1970547
STORE, SHOP5702013 STORE, SHOP911116284
STORE, SKY HOME CO.,LTD, STICKER WORLD
STORE, TEMILA PLUSH TOY STORE, TOGETIT
STORE, VL STORE, WANMEI BABY STORE,
XIAMEN PALMY IMPORT & EXPORT CO., LTD.,
YANGZHOU
CAISHENG
HANDICRAFT
PRODUCT CO., LTD., YANGZHOU MEIXUAN
TOYS AND GIFTS CO., LTD., YIWU BOBO
CRAFTS CO., LTD., YIWU CHANGYUAN ECOMMERCE FIRM, YIWU CITY CARNIVAL
COSTUME FACTORY, YIWU DINGYI ECOMMERCE CO., LTD., YIWU FUXIN TRADE
CO., LTD., YIWU HUALEI E-COMMERCE CO.,
LTD., YIWU KAIRAN TRADING CO., LTD., YIWU
LONGFEI GARMENT CO., LTD., YIWU MIAOJIA
TECHNOLOGY CO., LTD., YIWU MINZHI
CLOTHING FIRM, YIWU QUEYI CLOTHING CO.,
LTD., YIWU TANGAO E-COMMERCE FIRM,
YIWU TOYSTOCKER TOYS CO., LTD., YIWU
YUYUN TRADING CO., LTD., YIWU ZIHAN
IMPORT AND EXPORT CO., LTD. and
YUDUOBAO
TOY
STORE,
Defendants

Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 3 of 16

GLOSSARY
Term
Plaintiff or Moonbug
Defendants

Definition
Moonbug Entertainment Limited
ABDG Store, Anime-House Store, Anyang Feeker
Trading Co., Ltd., Baby board game(drop shipping)
Store Store, BAOKANWEIYI Store, Black Man K
Store, Changsha Wodemore Technology Co., Ltd.,
CLHW Grocery Store, Cute Small Mouse Toy Store,
Cute Sticker House Store, CXLIDY PARTY Store,
Daily boutique department Store, Dongguan Nuosheng
Electronic Technology Co., Ltd., Dongguan Tongjia
Toys Co., Ltd., Dongyang Yadi Pet Product Co., Ltd.,
Ee Party Store, Eweiser Electronic Technology
(shenzhen) Co., Ltd., FACAIParty Store, Farshunin
Store, Fook Fong Toy Store, Fujian Province Jianou
City Ruiyi Crafts Co., Ltd., Fun Le Toy City Store,
Fun-party Store, GongTen Store, Guangzhou Happy
Island Toys Co., Ltd., Guangzhou Yimai Trading Co.,
Ltd., Hangzhou Xingge Gift Co., Ltd., Hangzhou
Xingge Gifts Co., Ltd., Hebei Shuohui Paper Products
Co., Ltd., Henan Feeker Import And Export Co., Ltd.,
Henan Senfa Trading Co., Ltd., Indecor Store, Jinhua
Zhibo Garment Co., Ltd., Jinjiang Chengle Shoes And
Garment Co., Ltd., JJ Party Store, Kids-toy Store, Let's
party together Store, Life & art Store, Little Monkey
Toy Store, LU Wood Store, Mother and baby toy store
Store, PESENAR Store, pesenar1314 Store,
PHOTURT Backdrops Store, piaoliang baby Store, PP
Baby Store, Purple Game Store, Qingdao Bazhizhi
Culture Co., Ltd., Quanzhou Happy Brothers Trading
Co., Ltd., Quanzhou Jinhetuo Packaging Supplies Co.,
Ltd., Quanzhou Longkun Arts And Crafts Co., Ltd.,
Shanghai Xinyan Industrial Co., Ltd., Shaoxing Hualai
Emb. & Home Textile Co., Ltd., Shop1970547 Store,
Shop5702013 Store, Shop911116284 Store, Sky Home
Co.,Ltd, Sticker world Store, Temila plush toy Store,
Togetit Store, VL Store, Wanmei baby Store, Xiamen
Palmy Import & Export Co., Ltd., Yangzhou Caisheng
Handicraft Product Co., Ltd., Yangzhou Meixuan Toys
And Gifts Co., Ltd., Yiwu Bobo Crafts Co., Ltd., Yiwu
Changyuan E-Commerce Firm, Yiwu City Carnival
Costume Factory, Yiwu Dingyi E-Commerce Co., Ltd.,
Yiwu Fuxin Trade Co., Ltd., Yiwu Hualei E-Commerce
Co., Ltd., Yiwu Kairan Trading Co., Ltd., Yiwu
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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 4 of 16

Alibaba

AliExpress

Epstein Drangel
New York Address
Complaint
Application

Ahton Dec.
Nastasi Dec.
Blippi
Blippi Content
Blippi Registrations

Longfei Garment Co., Ltd., Yiwu Miaojia Technology
Co., Ltd., Yiwu Minzhi Clothing Firm, Yiwu Queyi
Clothing Co., Ltd., Yiwu Tangao E-Commerce Firm,
Yiwu Toystocker Toys Co., Ltd., Yiwu Yuyun Trading
Co., Ltd., Yiwu Zihan Import And Export Co., Ltd. and
Yuduobao Toy Store
Alibaba.com, an online marketplace platform that
allows manufacturers, wholesalers and other thirdparty merchants, like Defendants, to advertise, offer for
sale, sell, distribute and ship their wholesale and retail
products originating from China directly to consumers
across the world and specifically to consumers residing
in the U.S., including New York
Aliexpress.com, an online marketplace platform that
allows manufacturers, wholesalers and other thirdparty merchants, like Defendants, to advertise, offer for
sale, sell, distribute and ship their wholesale and retail
products originating from China directly to consumers
across the world and specifically to consumers residing
in the U.S., including New York
Epstein Drangel LLP, counsel for Plaintiff
244 Madison Ave, Suite 411, New York, New York
10016
Plaintiff’s Complaint
Plaintiff’s Ex Parte Application for: 1) a temporary
restraining order; 2) an order restraining Merchant
Storefronts (as defined infra) and Defendants’ Assets
(as defined infra) with the Financial Institutions (as
defined infra); 3) an order to show cause why a
preliminary injunction should not issue; 4) an order
authorizing bifurcated and alternative service and 5) an
order authorizing expedited discovery
Declaration of Karine Ahton in Support of Plaintiff’s
Application
Declaration of Gabriela N. Nastasi in Support of
Plaintiff’s Application
A fun, energetic entertainer known for his goofy
mannerisms, signature blue and orange outfit and
educational videos
Interactive videos exploring the world through the eyes
of a child while teaching them valuable skills such as
counting, learning colors and much more
U.S. Trademark Registration Nos.: 5,333,930 for
“BLIPPI” for a variety of goods in Class 28; 5,335,209
for “BLIPPI” for a variety of goods in Class 25 and

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 5 of 16

Blippi Application
Blippi Marks
Blippi Products
Counterfeit Products

Infringing Listings
User Accounts

Merchant Storefronts

Defendants’ Assets
Defendants’ Financial
Accounts
Financial Institutions

6,495,654 for “
” for goods in Classes 9,
16, 25, 28 and 41
U.S. Trademark Serial Application No. 88/553,924 for
“BLIPPI”, for goods in Classes 18, 20, 21, 24 and 27
The marks covered by the Blippi Registrations and the
Blippi Application
A variety of consumer products, such as t-shirts,
backpacks and other gear
Products bearing or used in connection with the Blippi
Marks, and/or products in packaging and/or containing
labels bearing the Blippi Marks, and/or bearing or used
in connection with marks that are confusingly similar
to the Blippi Marks and/or products that are identical or
confusingly similar to the Blippi Marks
Defendants’ listings for Counterfeit Products
Any and all websites and any and all accounts with
online marketplace platforms such as Alibaba and
AliExpress, as well as any and all as yet undiscovered
accounts with additional online marketplace platforms
held by or associated with Defendants, their respective
officers, employees, agents, servants and all persons in
active concert or participation with any of them
Any and all User Accounts through which Defendants,
their respective officers, employees, agents, servants
and all persons in active concert or participation with
any of them operate storefronts to manufacture, import,
export, advertise, market, promote, distribute, display,
offer for sale, sell and/or otherwise deal in Counterfeit
Products, which are held by or associated with
Defendants, their respective officers, employees,
agents, servants and all persons in active concert or
participation with any of them
Any and all money, securities or other property or
assets of Defendants (whether said assets are located in
the U.S. or abroad)
Any and all financial accounts associated with or
utilized by any Defendants or any Defendants’ User
Accounts or Merchant Storefront(s) (whether said
account is located in the U.S. or abroad)
Any banks, financial institutions, credit card companies
and payment processing agencies, such as PayPal Inc.
(“PayPal”), Payoneer Inc. (“Payoneer”), the Alibaba
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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 6 of 16

Third Party Service
Providers

Group d/b/a Alibaba.com payment services (e.g.,
Alipay.com Co., Ltd., Ant Financial Services Group),
PingPong Global Solutions, Inc. (“PingPong”) and
other companies or agencies that engage in the
processing or transfer of money and/or real or personal
property of Defendants
Online marketplace platforms, including, without
limitation, those owned and operated, directly or
indirectly by Alibaba and/or AliExpress, as well as any
and all as yet undiscovered online marketplace
platforms and/or entities through which Defendants,
their respective officers, employees, agents, servants
and all persons in active concert or participation with
any of them manufacture, import, export, advertise,
market, promote, distribute, offer for sale, sell and/or
otherwise deal in Counterfeit Products which are
hereinafter identified as a result of any order entered in
this action, or otherwise

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 7 of 16

WHEREAS, Plaintiff having moved ex parte on March 24, 2022 against Defendants for
the following: 1) a temporary restraining order; 2) an order restraining Merchant Storefronts and
Defendants’ Assets with the Financial Institutions; 3) an order to show cause why a preliminary
injunction should not issue; 4) an order authorizing bifurcated and alternative service and 5) an
order authorizing expedited discovery;
WHEREAS, the Court entered an Order granting Plaintiff’s Application on April 13, 2022
(“TRO”) which ordered Defendants to appear on April 26, 2022 at 11:00 a.m. to show cause why
a preliminary injunction should not issue (“Show Cause Hearing”);
WHEREAS, on April 18, 2022, Plaintiff filed a letter requesting to modify and extend the
TRO;
WHEREAS, on the same day, April 18, 2022, the Court entered an Order granting
Plaintiff’s request and, inter alia¸ adjourning the April 26, 2022 Show Cause Hearing to May 17,
2022 at 11:00 a.m. (“April 18, 2022 Order”);
WHEREAS, on May 3, 2022, pursuant to the alternative methods of service authorized by
the TRO, Plaintiff served the Summons, Complaint, TRO, all papers filed in support of the
Application and the April 18, 2022 Order on each and every Defendant;
WHEREAS, on May 17, 2022 at 11:00 a.m., Plaintiff appeared at the Show Cause Hearing,
however, no Defendants appeared.
ORDER
1. The injunctive relief previously granted in the TRO shall remain in place through the
pendency of this litigation, and issuing this Order is warranted under Federal Rule of Civil
Procedure 65 and Section 34 of the Lanham Act.
a) Accordingly, Defendants are hereby restrained and enjoined from engaging in any of

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 8 of 16

the following acts or omissions pending the final hearing and determination of this
action or until further order of the Court:
i. manufacturing, importing, exporting, advertising, marketing, promoting,
distributing, displaying, offering for sale, selling and/or otherwise dealing in
Counterfeit Products or any other products bearing the Blippi Marks and/or
marks that are confusingly similar to, identical to and constitute a
counterfeiting and/or infringement of the Blippi Marks;
ii. directly or indirectly infringing in any manner Plaintiff’s Blippi Marks;
iii. using any reproduction, counterfeit, copy or colorable imitation of Plaintiff’s
Blippi Marks to identify any goods or service not authorized by Plaintiff;
iv. using Plaintiff’s Blippi Marks and/or any other marks that are confusingly
similar to the Blippi Marks on or in connection with Defendants’
manufacturing, importing, exporting, advertising, marketing, promoting,
distributing, displaying, offering for sale, selling and/or otherwise dealing in
Counterfeit Products;
v. using any false designation of origin or false description, or engaging in any
action which is likely to cause confusion, cause mistake and/or to deceive
members of the trade and/or the public as to the affiliation, connection or
association of any product manufactured, imported, exported, advertised,
marketed, promoted, distributed, displayed, offered for sale or sold by
Defendants with Plaintiff, and/or as to the origin, sponsorship or approval of
any product manufactured, imported, exported, advertised, marketed,
promoted, distributed, displayed, offered for sale or sold by Defendants and

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 9 of 16

Defendants’ commercial activities and Plaintiff;
vi. secreting, concealing, destroying, altering, selling off, transferring or
otherwise disposing of and/or dealing with: (i) Counterfeit Products and/or
(ii) any computer files, data, business records, documents or any other
records or evidence relating to their User Accounts, Merchant Storefronts or
Defendants’ Assets and the manufacture, importation, exportation,
advertising, marketing, promotion, distribution, display, offering for sale
and/or sale of Counterfeit Products;
vii. effecting assignments or transfers, forming new entities or associations, or
creating and/or utilizing any other platform, User Account, Merchant
Storefront or any other means of importation, exportation, advertising,
marketing, promotion, distribution, display, offering for sale and/or sale of
Counterfeit Products for the purposes of circumventing or otherwise
avoiding the prohibitions set forth in this Order; and
viii. knowingly instructing any other person or business entity to engage in any
of the activities referred to in subparagraphs 1(a)(i) through 1(a)(vii) above
and 1(b)(i) through 1(b)(ii) and 1(c)(i) below.
b) Accordingly, the Third Party Service Providers and Financial Institutions are hereby
restrained and enjoined from engaging in any of the following acts or omissions
pending the final hearing and determination of this action or until further order of the
Court:
i. secreting, concealing, transferring, disposing of, withdrawing, encumbering
or paying Defendants’ Assets from or to Defendants’ Financial Accounts

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 10 of 16

until further ordered by this Court;
ii. secreting, concealing, destroying, altering, selling off, transferring or
otherwise disposing of and/or dealing with any computer files, data, business
records, documents or any other records or evidence relating to Defendants’
Assets and Defendants’ Financial Accounts; and
iii. knowingly instructing, aiding, or abetting any person or business entity in
engaging in any of the activities referred to in subparagraphs 1(a)(i) through
1(a)(vii) and 1(b)(i) through 1(b)(ii) above and 1(c)(i) below.
c) Accordingly, the Third Party Service Providers are hereby restrained and enjoined from
engaging in any of the following acts or omissions pending the final hearing and
determination of this action or until further order of the Court:
i. providing services to Defendants, Defendants’ User Accounts and
Defendants’ Merchant Storefronts, including, without limitation, continued
operation of Defendants’ User Accounts and Merchant Storefronts;
ii. knowingly instructing, aiding, or abetting any other person or business entity
in engaging in any of the activities referred to in subparagraphs 1(a)(i)
through 1(a)(vii), 1(b)(i) through 1(b)(ii) and 1(c)(i) above.
2. As sufficient cause has been shown, the asset restraint granted in the TRO shall remain in
place through the pendency of this litigation, including that:
a) within seven (7) days of receipt of notice of this Order, any newly discovered Financial
Institutions who are served with this Order shall locate and attach Defendants’
Financial Accounts, shall provide written confirmation of such attachment to Plaintiff’s
counsel and provide Plaintiff’s counsel with a summary report containing account

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 11 of 16

details for any and all such accounts, which shall include, at a minimum, identifying
information for Defendants, including contact information for Defendants (including,
but not limited to, mailing addresses and e-mail addresses), account numbers and
account balances for any and all of Defendants’ Financial Accounts and confirmation
of said compliance with this Order.
3. As sufficient cause has been shown, the expedited discovery previously granted in the TRO
shall remain in place through the pendency of this litigation, including that:
a) Plaintiff may serve interrogatories pursuant to Rules 26 and 33 of the Federal Rules of
Civil Procedure as well as Local Civil Rule 33.3 of the Local Rules for the Southern
and Eastern Districts of New York and Defendants who are served with this Order shall
provide written responses under oath to such interrogatories within fourteen (14) days
of service to Plaintiff’s counsel.
b) Plaintiff may serve requests for the production of documents pursuant to Rules 26 and
34 of the Federal Rules of Civil Procedure and Defendants who are served with this
Order, their respective officers, employees, agents, servants and attorneys and all
persons in active concert or participation with any of them who receive actual notice of
this Order shall produce all documents responsive to such requests within fourteen (14)
days of service to Plaintiff’s counsel.
c) Within fourteen (14) days after receiving notice of this Order, all Financial Institutions
who receive service of this Order shall provide Plaintiff’s counsel with all documents
and records in their possession, custody or control (whether located in the U.S. or
abroad), relating to any and all of Defendants’ Financial Accounts, User Accounts and
Merchant Storefronts, including, but not limited to, documents and records relating to:

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 12 of 16

i.

account numbers;

ii.

current account balances;

iii.

any and all identifying information for Defendants, Defendants' User
Accounts and Defendants’ Merchant Storefronts, including but not limited
to, names, addresses and contact information;

iv.

any and all account opening documents and records, including, but not
limited to, account applications, signature cards, identification documents,
and if a business entity, any and all business documents provided for the
opening of each and every of Defendants’ Financial Accounts;

v.

any and all deposits and withdrawal during the previous year from each
and every one of Defendants’ Financial Accounts and any and all
supporting documentation, including, but not limited to, deposit slips,
withdrawal slips, cancelled checks and account statements;

vi.

any and all wire transfers into each and every of Defendants’ Financial
Accounts during the previous year, including, but not limited to, documents
sufficient to show the identity of the destination of the transferred funds,
the identity of the beneficiary’s bank and the beneficiary’s account number;

d) Within fourteen (14) days of receipt of service of this Order, the Third Party Service Providers
shall provide to Plaintiff’s counsel all documents and records in its possession, custody or
control (whether located in the U.S. or abroad) relating to Defendants’ User Accounts and
Defendants’ Merchant Storefronts, including, but not limited to, documents and records
relating to:

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Case 1:22-cv-02386-RA Document 20 Filed 05/17/22 Page 13 of 16

i.

any and all User Accounts and Defendants’ Merchant Storefronts and
account details, including, without limitation, identifying information and
account numbers for any and all User Accounts and Defendants’ Merchant
Storefronts that Defendants have ever had and/or currently maintain with
the Third Party Service Providers;

ii.

the identities, location and contact information, including any and all email addresses, of Defendants;

iii.

the nature of Defendants’ businesses and operations, methods of payment,
methods for accepting payment and any and all financial information,
including, but not limited to, information associated with Defendants’ User
Accounts, and Defendants Merchant Storefronts’, a full accounting of
Defendants’ sales history and listing history under such accounts, and
Defendants’ Financial Accounts with any and all Financial Institutions
associated with Defendants’ User Accounts and Defendants’ Merchant
Storefronts; and

vii.

Defendants’ manufacturing, importing, exporting, advertising, marketing,
promoting, distributing, displaying, offering for sale and/or selling of
Counterfeit Products, or any other products bearing the Blippi Marks
and/or marks that are confusingly similar to, identical to and constitute an
infringement of the Blippi Marks.

4. As sufficient cause has been shown, and pursuant to FRCP 4(f)(3), service may be made
on, and shall be deemed effective as to Defendants if it is completed by one of the following
means:

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a) delivery of: (i) a PDF copy of this Order, and (ii) a link to a secure website
(including NutStore, a large mail link created through Rmail.com and via website
publication through a specific page dedicated to this Lawsuit accessible through
ipcounselorslawsuit.com) where each Defendant will be able to download a PDF
copy of this Order to Defendants’ e-mail addresses toas identified by Alibaba
and/or AliExpress pursuant to Paragraph V(C) of the TRO; or
b) delivery of a message to Defendants through the same means that Plaintiff’s agents
have previously communicated with Defendants, namely the system for
communications established by the Third Party Service Providers on their
respective platforms, and providing a link to a secure website (such as NutStore or
a large mail link created through Rmail.com) where each Defendant will be able to
download a PDF copy of this Order.
5. As sufficient cause has been shown, that such alternative service by electronic means
ordered in the TRO and herein shall be deemed effective as to Defendants, Third Party
Service Providers and Financial Institutions through the pendency of this action.
6. As sufficient cause has been shown, service of this Order shall be made on and deemed
effective as to the Third Party Service Providers and Financial Institutions if it is completed
by the following means:
a) delivery of: (i) a PDF copy of this Order, or (ii) a link to a secure website where
PayPal Inc. will be able to download a PDF copy of this Order via electronic mail
to PayPal Legal Specialist at [e-mail];

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c) delivery of: (i) a PDF copy of this Order, or (ii) a link to a secure website where
AliPay.com Co., Ltd., Ant Financial Services will be able to download a PDF copy
of this Order via electronic mail Mr. Di Zhang, Member of the Legal & Compliance
Department – IP, at [e-mail];
d) delivery of: (i) a PDF copy of this Order, or (ii) a link to a secure website where
Alibaba will be able to download a PDF copy of this Order via electronic mail to
Chloe He, Alibaba Group at [e-mail];
e) delivery of: (i) a PDF copy of this Order, or (ii) a link to a secure website where
Payoneer Inc. will be able to download a PDF copy of this Order via electronic mail
to

Payoneer

Inc.’s

Customer

Service

Management

at

[e-mail]; and
f) delivery of: (i) a PDF copy of this Order, or (ii) a link to a secure website where
PingPong Global Solutions Inc. will be able to download a PDF copy of this Order
via electronic mail to PingPong Global Solutions Inc.’s Legal Department
[e-mail].
7. Defendants are hereby given notice that they may be deemed to have actual notice of the
terms of this Order and any act by them or anyone of them in violation of this Order may
be considered and prosecuted as in contempt of this Court.
8. The $5,000.00 bond posted by Plaintiff shall remain with the Court until a final disposition
of this case or until this Order is terminated.
9. This Order shall remain in effect during the pendency of this action, or until further order
of the Court.

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10. Any Defendants that are subject to this Order may appear and move to dissolve or modify
the Order on two (2) days’ notice to Plaintiff or on shorter notice as set by the Court.

SO ORDERED.
SIGNED this 17th day of May, 2022.
New York, New York
_________________________________
HON. RONNIE ABRAMS
UNITED STATES DISTRICT JUDGE

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