ABC v. DEF

Filing 9

PRELIMINARY INJUNCTION ORDER: The injunctive relief previously granted in the TRO shall remain in place through the pendency of this action, and issuing this Order is warranted under Federal Rule of Civil Procedure 65 and Section 34 of t he Lanham Act. Accordingly, Defendants are hereby restrained and enjoined from engaging in any of the acts or omissions set forth in this order pending the final hearing and determination of this action or until further order of the Court. A ccordingly, the Third Party Service Providers and Financial Institutions are hereby restrained and enjoined from engaging in any of the acts or omissions set forth in this order pending the final hearing and determination of this action or unti l further order of the Court. The $1,000.00 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 Court. (Signed by Judge J. Paul Oetken on 6/1/2022) (ate)

Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 1 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
KELLY TOYS HOLDINGS, LLC,

22-cv-3739 (JPO)

Plaintiff
v.
CHANG SHA ZHUO QIAN DIAN ZI KE JI YOU
XIAN GONG SI, CHANG ZHOU WAN KAI WEN
HUA YONG PIN YOU XIAN GONG SI,
CHENGDE JIUBO ELECTRONIC COMMERCE,
DALIAN JIAXU TRADING, DONG GUAN SHI
HAI
QI
MAO
YI
YOUXIANGONGSI,
DONGGUAN DEZHUOSHENG BUSINESS &
TRADING,
DONGGUAN
TINGQIWAN
TRADING,
FUDINGSHIXIAOQIRIYONGBAIHUOJINGYIN
GBU, GUANG ZHOU SHI AI NI MAO YI YOU
XIAN GONG SI, GUANGZHOU DOMINEERING
POINT
TRADING,
GUANGZHOU
JIWEI
INFORMATION TECHNOLOGY, GUANGZHOU
LINGHE
DIANZI
KEJIYOUXIANGONGSI,
GUANGZHOU
SHUZISHANDONG
KEJI
YOUXIAN GONGSI, GUANGZHOU TAOPAI
DEPARTMENT
STORE
CENTER,
GUANGZHOUFUHANJIAJUYONGPINYOUXIA
NGONGSI,
HAILUNSHIHUITENGSHANGMAOYOUXIANG
ONGSI, HANGZHOU MINGXU JINCHUKOU
YOUXIANGONGSI,
HANGZHOUHANFEIMAOYIYOUXIANGONGSI
,
HUIDA
CROSS-BORDER
LOGISTICS
(SHENZHEN),
HUIZHOU
RUICHANGDA
TECHNOLOGY, NANFANGYU (SHENZHEN)
GUOJIMAOYIYOUXIANGONGSI,
NANTONGWUNIUFANGZHIPINYOUXIANGON
GSI, QUANZHOU DENGKU ELECTRONIC
TECHNOLOGY, SHEN ZHEN SHI LE KA MAO
YI YOU XIAN GONG SI, SHEN ZHEN SHI PO FU
SHANG MAO YOU XIAN GONG SI, SHENZHEN
DONGRENHAO
TRADING,
SHENZHEN
FENGBO TRADING, SHENZHEN GUICHEN
TECHNOLOGY,
SHENZHEN
HAIWEISI
TECHNOLOGY,
SHENZHEN
HUAFEI
TRADING, SHENZHEN JIENUOYI TRADING,
SHENZHEN
LEBANGHUI
TRADING,
i

PRELIMINARY
INJUNCTION ORDER

Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 2 of 15
SHENZHEN
NAIERJIN
TECHNOLOGY,
SHENZHEN SHI JUNGE TRADING, SHENZHEN
TIANYING
E-COMMERCE,
SHENZHEN
XINYICHUANG
TECHNOLOGY,
SHENZHENSHI
BAOANQU
BISHUN
SHANGMAOHANG,
SHENZHENSHI
MAISITONG
KEJI
YOUXIANGONGSI,
SHENZHENSHI
MITANG
FANGZHIPIN
YOUXIANGONGSI,
SHENZHENSHI
NUOSHILAN DIANZI YOUXIAN GONGSI,
SHENZHENSHIAIYANKEJIYOUXIANGONGSI,
SHENZHENSHIHAOSHENGZHEKEJIYOUXIAN
GONGSI,
SHENZHENSHIHUAYUYANGMAOYIYOUXIA
NGONGSI,
SHENZHENSHISITABORUIKEJIYOUXIANGON
GSI,
TAIZHOUSHIYAGESUYEYOUXIANGONGSI,
WEIFANG YUJIN TRADING, WEIHAI LEKA
TECHNOLOGY,
WEIHAI
XUSHENG
TECHNOLOGY,
WUHUASHUIZHAIZHENRUNLINDICHANZHO
NGJIE, XINXIANG YALI NETWORK, XINYU
MAOXIN
TECHNOLOGY,
XUCHANG
HENGKANG TRADING COMPANY, YI WU SHI
OU XING DIANZI SHANG WU YOUXIAN
GONGSI,
YIWEISAI
(SHENZHEN)
ELECTRONIC and ZAOZHUANG BOQIN
TRADING COMPANY,
Defendants
GLOSSARY
Term
Plaintiff or Kelly Toys
Defendants

Definition
Kelly Toys Holdings, LLC
Chang Sha Zhuo Qian Dian Zi Ke Ji You Xian Gong
Si, Chang Zhou Wan Kai Wen Hua Yong Pin You Xian
Gong Si, Chengde Jiubo Electronic Commerce, Dalian
Jiaxu Trading, Dong Guan Shi Hai Qi Mao Yi
Youxiangongsi, Dongguan Dezhuosheng Business &
Trading,
Dongguan
Tingqiwan
Trading,
Fudingshixiaoqiriyongbaihuojingyingbu, Guang Zhou
Shi Ai Ni Mao Yi You Xian Gong Si, Guangzhou
Domineering Point Trading, Guangzhou Jiwei
Information Technology, Guangzhou Linghe Dianzi
Kejiyouxiangongsi, Guangzhou Shuzishandong Keji
Youxian Gongsi, Guangzhou Taopai Department Store
ii

Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 3 of 15

Fruugo

Epstein Drangel
New York Address
Complaint
Application

Center, Guangzhoufuhanjiajuyongpinyouxiangongsi,
Hailunshihuitengshangmaoyouxiangongsi, Hangzhou
Mingxu
Jinchukou
Youxiangongsi,
Hangzhouhanfeimaoyiyouxiangongsi, Huida Crossborder Logistics (Shenzhen), Huizhou Ruichangda
Technology,
Nanfangyu
(Shenzhen)
Guojimaoyiyouxiangongsi,
Nantongwuniufangzhipinyouxiangongsi,
Quanzhou
Dengku Electronic Technology, Shen Zhen Shi Le Ka
Mao Yi You Xian Gong Si, Shen Zhen Shi Po Fu Shang
Mao You Xian Gong Si, Shenzhen Dongrenhao
Trading, Shenzhen Fengbo Trading, Shenzhen Guichen
Technology, Shenzhen Haiweisi Technology,
Shenzhen Huafei Trading, Shenzhen Jienuoyi Trading,
Shenzhen Lebanghui Trading, Shenzhen Naierjin
Technology, Shenzhen Shi Junge Trading, Shenzhen
Tianying E-commerce, Shenzhen Xinyichuang
Technology,
Shenzhenshi
Baoanqu
Bishun
Shangmaohang,
Shenzhenshi
Maisitong
Keji
Youxiangongsi, Shenzhenshi Mitang Fangzhipin
Youxiangongsi, Shenzhenshi Nuoshilan Dianzi
Youxian Gongsi, Shenzhenshiaiyankejiyouxiangongsi,
Shenzhenshihaoshengzhekejiyouxiangongsi,
Shenzhenshihuayuyangmaoyiyouxiangongsi,
Shenzhenshisitaboruikejiyouxiangongsi,
TaiZhouShiYaGeSuYeYouXianGongSi,
Weifang
Yujin Trading, Weihai Leka Technology, Weihai
Xusheng
Technology,
Wuhuashuizhaizhenrunlindichanzhongjie, Xinxiang
Yali Network, Xinyu Maoxin Technology, Xuchang
Hengkang Trading Company, Yi Wu Shi Ou Xing
Dianzi Shang Wu Youxian Gongsi, Yiweisai
(Shenzhen) Electronic and Zaozhuang Boqin Trading
Company
Fruugo.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, NY 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
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Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 4 of 15

Kelly Dec.
Ioannou Dec.
Squishmallows
Application
Squishmallows
Registrations

Squishmallows Marks
Squishmallows Works
Squishmallows
Products

Counterfeit Products

Infringing Listings
User Accounts

Merchant Storefronts

preliminary injunction should not issue; 4) an order
authorizing bifurcated and alternative service; and 5) an
order authorizing expedited discovery
Declaration of Jonathan Kelly in Support of Plaintiff’s
Application
Declaration of Karena K. Ioannou in Support of
Plaintiff’s Application
U.S. Trademark Serial Application No.: 90/676,140 for
“ORIGINAL SQUISHMALLOWS,” for goods in
Class 28
U.S. Trademark Registration Nos.: 5,454,574 for
“SQUISHMALLOW” for goods in Class 28; 6,137,521
for “FLIP A MALLOWS” for goods in Class 28;
5,962,289 for “MYSTERY SQUAD” for goods in
Class 28; 2,029,047 for “KELLYTOY” for goods in
Class 28; and 6,654,108 for “SQUISHMALLOWS
HUG MEES” for goods in Class 28
The marks covered by the Squishmallows Registrations
and Squishmallows Application
The works covered by the U.S. copyright registrations
listed in Exhibit C to the Complaint
A line of loveable buddies made with a super soft,
marshmallow-like texture that come in a variety of sizes
from 3.5-inch clip-ons to extra-large 24 inch plush toys,
and have expanded to other styles including Hug Mees,
Stackables, Mystery Squad and Flip-A-Mallows.
Products bearing or used in connection with the
Squishmallows Marks and/or Squishmallows Works,
and/or products in packaging and/or containing labels
and/or hang tags bearing the Squishmallows Marks
and/or Squishmallows Works, and/or bearing or used in
connection with marks and/or artwork that are
confusingly or substantially similar to the
Squishmallows Marks and/or Squishmallows Works
and/or products that are identical or confusingly or
substantially similar to the Squishmallows Products
Defendants’ listings for Counterfeit Products
Any and all websites and any and all accounts with
online marketplace platforms such as Fruugo 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,
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Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 5 of 15
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
Defendants’ Assets
Any and all money, securities or other property or
assets of Defendants (whether said assets are located in
the U.S. or abroad)
Defendants’ Financial Any and all financial accounts associated with or
Accounts
utilized by any Defendants or any Defendants’ User
Accounts or Merchant Storefront(s) (whether said
accounts are located in the U.S. or abroad)
Financial Institutions
Any banks, financial institutions, credit card companies
and payment processing agencies, such as PayPal Inc.
(“PayPal”), Payoneer Inc. (“Payoneer”), Alipay.com
Co., Ltd. (“Alipay”), PingPong Global Solutions, Inc.
(“PingPong”), Wise US Inc. (“Wise”), National
Westminster Bank (“NatWest”) and other companies or
agencies that engage in the processing or transfer of
money and/or real or personal property of Defendants
Third Party Service
Online marketplace platforms, including, without
Providers
limitation, those owned and operated, directly or
indirectly by Fruugo, 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

v

Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 6 of 15

WHERAS, Plaintiff having moved ex parte on May 9, 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, on that same day, May 9, 2022, the Court entered an Order granting Plaintiff’s
Application (“TRO”) which ordered Defendants to appear on May 20, 2022 at 12:00 p.m. to show
cause why a preliminary injunction should not issue (“Show Cause Hearing”);
WHEREAS, on May 16, 2022, Plaintiff filed a letter requesting to modify and extend the
TRO;
WHEREAS, on May 18, 2022, the Court entered an order extending rescheduling the Show
Cause Hearing to May 31, 2022 at 3:00 p.m. and extending the TRO to the date of the Show Cause
Hearing (“May 18, 2022 Order”);
WHEREAS, on May 16, 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 on each and every Defendant;
WHEREAS, on May 18, 2022, the May 18, 2022 Order was served on each and every
Defendant;
WHEREAS, on May 31, 2022 at 3:00 p.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 action, and issuing this Order is warranted under Federal Rule of Civil

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Procedure 65 and Section 34 of the Lanham Act.
a) 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:
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 Squishmallows Marks
and/or Squishmallows Works and/or marks or artwork that are confusingly
and/or substantially similar to, identical to and constitute a counterfeiting or
infringement of the Squishmallows Marks and/or Squishmallows Works;
ii. directly or indirectly infringing in any manner Plaintiff’s Squishmallows Marks
and/or Squishmallows Works;
iii. using any reproduction, counterfeit, copy or colorable imitation of Plaintiff’s
Squishmallows Marks and/or Squishmallows Works, to identify any goods or
services not authorized by Plaintiff;
iv. using Plaintiff’s Squishmallows Marks and/or Squishmallows Works and/or
any other marks that are confusingly similar to the Squishmallows Marks and/or
any other artwork that is substantially similar to the Squishmallows Works, on
or in connection with Defendants’ manufacturing, importing, exporting,
advertising, marketing, promoting, distributing, 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

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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
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 in engaging in any of
the activities referred to in subparagraphs I(A)(i) through I(A)(vii) above and
I(B)(i) through I(B)(ii) and I(C)(i) below.

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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 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, or
any other records or evidence relating to Defendants’ Assets and Defendants’
Financial Accounts; and
iii. knowingly instructing any person or business entity to engage in any of the
activities referred to in subparagraphs I(A)(i) through I(A)(vii) and I(B)(i)
through I(B)(ii) above and I(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; and
ii. knowingly instructing any person or business entity to engage in any of the
activities referred to in subparagraphs I(A)(i) through I(A)(vii) and I(B)(i)
through I(B)(ii) above and I(C)(1) above.

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2. As sufficient cause has been shown, the asset restraint granted in the TRO shall remain in
place through the pendency of this action, 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 and shall provide written confirmation of such attachment to
Plaintiff’s counsel.
3. As sufficient cause has been shown, the expedited discovery previously granted in the TRO
shall remain in place through the pendency of this action, 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 Fed. R. Civ.
P. 26 and 34, and Defendants who are served with this Order and the requests for the
production of documents 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:
i.

account numbers;

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Case 1:22-cv-03739-UA Document 9 Filed 06/01/22 Page 11 of 15

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 withdrawals 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; and

vi.

any and all wire transfers into each and every one 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:
i.

any and all User Accounts and Defendants’ Merchant Storefronts and account
details, including, without limitation, identifying information and account numbers

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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 that were not previously provided pursuant to Paragraph VI of the TRO;
ii.

the identities, location and contact information, including any and all e-mail
addresses of Defendants that were not previously provided pursuant to Paragraph
I(C) of the TRO;

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

iv.

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

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 to be determined after having been
identified by Fruugo pursuant to Paragraph V(C) of the TRO or may otherwise be
determined; 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, notifying Defendants that an action has been filed against them in this Court
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
Fruugo will be able to download a PDF copy of this Order via electronic mail to
Fruugo’s Legal Department at [e-mail];

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b) 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];
c) delivery of: (i) a PDF copy of this Order, or (ii) a link to a secure website where
AliPay 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
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];
e) 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
at [e-mail];
f) delivery of (i) a PDF copy of this Order, or (ii) a link to a secure website where
Wise will be able to download a PDF copy of this Order via electronic mail to
[e-mail]; and
g) delivery of (i) a PDF copy of this Order, or (ii) a link to a secure website where
NatWest will be able to download a PDF copy of this Order via electronic mail
to [e-mail].

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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 $1,000.00 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.
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.
June 1, 2022
New York, New York
_________________________________
HON. J. PAUL OETKEN
UNITED STATES DISTRICT JUDGE

10