VPR Brands, LP v. Shenzhen Weiboli Technology Co. Ltd. et al
| VPR Brands, LP |
| Shenzhen Weiboli Technology Co. Ltd. doing business as ELFBAR, Ylsn Distribution LLC, Ecto World LLC, Safa Goods LLC, D&A Distribution LLC, UNISHOW (U.S.A.), INC., SV3 LLC, Kingdom Vapor Inc. and Shenzhen Weiboli Technology Co. Ltd. |
| 9:2022cv81576 |
| October 13, 2022 |
| US District Court for the Southern District of Florida |
| Aileen M Cannon |
| Bruce E Reinhart |
| Trademark |
| 15 U.S.C. § 1114 Trademark Infringement |
| Plaintiff |
Docket Report
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| Filing 55 NOTICE by VPR Brands, LP re #53 Order, Terminate Motions, Set/Reset Deadlines/Hearings (Rothman, Joel) |
| Filing 54 Exhibit List and Exhibits from Hearing on Motion for Preliminary Injunction by VPR Brands, LP.. (Attachments: #1 Exhibit PX 22, #2 Exhibit PX 23, #3 Exhibit PX 24, #4 Exhibit PX 25, #5 Exhibit PX 26, #6 Exhibit PX 27)(Rothman, Joel) |
Filing 53
ORDER FOLLOWING PRELIMINARY INJUNCTION HEARING: Granting #33 Unopposed Second MOTION for Judicial Notice. Signed by Judge Aileen M. Cannon on 12/5/2022. See attached document for full details. (scn)
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| Filing 52 PAPERLESS Minute Entry for proceedings held before Judge Aileen M. Cannon: Continued Motion Hearing held on December 1, 2022. The Court heard sworn testimony and received evidence on #5 Plaintiff's Motion for Preliminary Injunction. Witnesses: Bryan Haynes, Haitham Shriteh, Jon Glauser, Kevin Frija. Order to follow. Total time in court: 4 hours, 50 minutes. Attorney Appearances: Joel Benjamin Rothman, Layla Nguyen, Marian V. Quintero, Tucker Crowley Motta, Anna Stressenger, Carrie A. Shufflebarger, Eric Heyer, Meixuan (Michelle) Li. Court Reporter: Diane Miller, 772-467-2337 / Diane_Miller@flsd.uscourts.gov. (kts) |
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Filing 51
PAPERLESS ORDER granting #50 Defendants' Motion to Present Testimony of Louis K. Ebling via Zoom. Mr. Louis K. Ebling may appear via Zoom for the continued hearing on Plaintiff's Motion for Preliminary Injunction #5 . Mr. Ebling should join the hearing using the Zoom link and information emailed to the parties on November 29, 2022. All other parties must appear in person for the December 1, 2022, 9:00 A.M. hearing. Signed by Judge Aileen M. Cannon on 11/30/2022. (kts)
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| Filing 50 First MOTION Witness Appear via Zoom by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. (Attachments: #1 Affidavit Exhibit A - Declaration of Louis K. Ebling)(Motta, Tucker) |
| Filing 49 REPORT REGARDING Joint Hearing Plan by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC (Motta, Tucker) |
| Filing 48 PAPERLESS Minute Entry for proceedings held before Magistrate Judge Bruce E. Reinhart: Discovery Hearing on Defendants' Motion for a Protective Order (DE 30) held on 11/28/2022. Total time in court: 15 minutes. (Digital BER_1_11.28.2022) (hk02) |
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Filing 47
PAPERLESS ORDER denying without prejudice #30 Defendants' Motion for a Protective Order. The Court did not reach the scope of information to be made publicly available during the hearing on Plaintiff's Motion for a Preliminary Injunction currently pending before Judge Cannon. Counsel will continue to confer and negotiate the terms of their confidentiality stipulation. Signed by Magistrate Judge Bruce E. Reinhart on 11/28/2022. (hk02)
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| Filing 46 TRANSCRIPT of Motions Hearing held on 11/18/2022 before Judge Aileen M. Cannon, 1-152 pages, Court Reporter: Diane Miller, 772-467-2337 / Diane_Miller@flsd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased by contacting the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/14/2022. Redacted Transcript Deadline set for 12/27/2022. Release of Transcript Restriction set for 2/21/2023. (dmr) |
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Filing 45
PAPERLESS ORDER taking under advisement #30 Defendants' Motion for a Confidentiality Order and setting a Telephone Discovery Hearing for 11/28/2022 at 2:00 PM before Magistrate Judge Bruce E. Reinhart. Counsel shall appear telephonically using the following conference call instructions: Dial 1-888-557-8511; Enter access code 4098267#; and Enter security code 1234#. Signed by Magistrate Judge Bruce E. Reinhart on 11/23/2022. (hk02)
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| Filing 44 RESPONSE in Opposition re #30 MOTION for Protective Order filed by VPR Brands, LP. Replies due by 11/29/2022. (Rothman, Joel) |
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Filing 42
PAPERLESS ORDER taking under advisement #30 Defendant's Motion for Entry of a Confidentiality Order and ORDERING Plaintiff's counsel to file a response to the motion by 11/22/22. Signed by Magistrate Judge Bruce E. Reinhart on 11/21/2022. (hk02)
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| Reset Deadline per DE#42 as to #30 MOTION for Protective Order. Responses due by 11/22/2022. (scn) |
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Filing 43
ORDER FOLLOWING MOTION HEARING granting #29 Motion for Judicial Notice. Evidentiary Motion Hearing set for 12/1/2022 09:00 AM in Fort Pierce Division before Judge Aileen M. Cannon. Responses due by 11/30/2022 Responses due by 12/1/2022 Signed by Judge Aileen M. Cannon on 11/18/2022. See attached document for full details. (pcs)
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Filing 41
PAPERLESS ORDER REFERRING #30 Defendants' Motion for Entry of Protective Order to Judge Bruce E. Reinhart. Signed by Judge Aileen M. Cannon on 11/18/2022. (kts)
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| Filing 40 PAPERLESS NOTICE OF HEARING: Continued Motion Hearing re #5 Plaintiff's Motion for Preliminary Injunction scheduled for 12/01/2022 at 9:00 A.M. in Fort Pierce Division before Judge Aileen M. Cannon. (kts) |
| Filing 39 PAPERLESS Minute Entry for proceedings held before Judge Aileen M. Cannon: Motion Hearing held on November 18, 2022. The Court heard testimony and received evidence on #5 Plaintiff's Motion for Preliminary Injunction. Witness: Kevin Frija. Motion hearing to continue on December 1, 2022 at 9:00 A.M. in Fort Pierce Division. Order to follow. Total time in court: 3 hours 50 minutes. Attorney Appearances: Joel Benjamin Rothman, Tucker Crowley Motta, Anna Stressenger, Carrie A. Shufflebarger, Eric Heyer, Krupa Patel, Meixuan (Michelle) Li. Other Appearances: Craig Wirth, Eliezer Lekht, Geoff Habicht, Joe Dunne, Jon Glauser, Karen Pineda, Layla Nguyen, Lia Williams, Marian V. Quintero. Court Reporter: Diane Miller, 772-467-2337 / Diane_Miller@flsd.uscourts.gov. (kts) |
| Filing 38 HEARING EXHIBITS PX 1-11, PX 13-21 by VPR Brands, LP. (Attachments: #1 Exhibit PX 1, #2 Exhibit PX 2, #3 Exhibit PX 3, #4 Exhibit PX 4, #5 Exhibit PX 5, #6 Exhibit PX 6, #7 Exhibit PX 7, #8 Exhibit PX 8, #9 Exhibit PX 9, #10 Exhibit PX 10, #11 Exhibit PX 11, #12 Exhibit PX 13, #13 Exhibit PX 14, #14 Exhibit PX 15, #15 Exhibit PX 16, #16 Exhibit PX 17, #17 Exhibit PX 18, #18 Exhibit PX 19, #19 Exhibit PX 20, #20 Exhibit PX 21)(Rothman, Joel) |
| Filing 37 NOTICE by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC re #32 Response in Opposition to Motion, -- Notice of Filing Defendants' Exhibit List (Attachments: #1 Exhibit D-1, #2 Exhibit D-2, #3 Exhibit D-3, #4 Exhibit D-4, #5 Exhibit D-5, #6 Exhibit D-6, #7 Exhibit D-7, #8 Exhibit D-8, #9 Exhibit D-9, #10 Exhibit D-10, #11 Exhibit D-11, #12 Exhibit D-12, #13 Exhibit D-13, #14 Exhibit D-14, #15 Exhibit D-15, #16 Exhibit D-16, #17 Exhibit D-17, #18 Exhibit D-18) (Motta, Tucker) |
| Filing 36 Exhibit List Supplemental Exhibit List and Exhibits for Hearing on Motion for Preliminary Injunction by VPR Brands, LP.. (Attachments: #1 Exhibit PX 21, #2 Exhibit PX 22)(Rothman, Joel) |
| Filing 35 Exhibit List and Exhibits in Support of Motion for Preliminary Injunction for Hearing by VPR Brands, LP.. (Attachments: #1 Exhibit PX1, #2 Exhibit PX2, #3 Exhibit PX3, #4 Exhibit PX4, #5 Exhibit PX5, #6 Exhibit PX6, #7 Exhibit PX7, #8 Exhibit PX8, #9 Exhibit PX9, #10 Exhibit PX10, #11 Exhibit PX11, #12 Exhibit PX12, #13 Exhibit PX13, #14 Exhibit PX14, #15 Exhibit PX15, #16 Exhibit PX16, #17 Exhibit PX17, #18 Exhibit PX18, #19 Exhibit PX19, #20 Exhibit PX20)(Rothman, Joel) |
| Filing 34 Plaintiff's REPLY to Response to Motion re #5 Plaintiff's MOTION for Preliminary Injunction filed by VPR Brands, LP. (Rothman, Joel) |
| Filing 33 Second MOTION for Judicial Notice by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. (Attachments: #1 Exhibit A - Declaration of Carrie Shufflebarger)(Motta, Tucker) |
| Filing 32 RESPONSE in Opposition re #5 Plaintiff's MOTION for Preliminary Injunction filed by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Replies due by 11/28/2022. (Motta, Tucker) |
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Filing 31
PAPERLESS ORDER: The parties should be prepared to discuss #29 Defendants' Motion for Judicial Notice and #30 Defendants' Motion for Entry of Protective Order at the Motion Hearing scheduled for November 18, 2022. Signed by Judge Aileen M. Cannon on 11/17/2022. (kts)
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| Filing 30 MOTION for Protective Order by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. (Attachments: #1 Text of Proposed Order - Proposed Protective Order)(Motta, Tucker) |
| Filing 29 MOTION for Judicial Notice by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. (Attachments: #1 Exhibit A - Declaration of Anna Stressenger)(Motta, Tucker) |
| Filing 28 STATUS REPORT by VPR Brands, LP (Rothman, Joel) |
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Filing 27
PAPERLESS ORDER: In light of Attorney Eric N. Heyer's Amended Motion to Appear Pro Hac Vice #20 , Attorney Eric N. Heyer's Motion to Appear Pro Hac Vice #18 is denied as moot. Signed by Judge Aileen M. Cannon on 11/15/2022. (kts)
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Filing 26
PAPERLESS ORDER granting #20 #21 #22 #23 #25 the Motions to Appear Pro Hac Vice, Consents to Designation, and Requests to Electronically Receive Notices of Electronic Filing for Attorneys Eric N. Heyer, Meixuan (Michelle) Li, Anna Stressenger, Carrie Shufflebarger, and Krupa Patel. The Court reserves the power to withdraw permission for special appearance at any time. Failure to abide by any court order or failure to appear at any scheduled matter may result in immediate revocation of counsel's pro hac vice status. Local counsel must be ready to adequately represent the party at any time. Signed by Judge Aileen M. Cannon on 11/15/2022. (kts)
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| Filing 25 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Krupa Patel. Filing Fee $ 200.00 Receipt # AFLSDC-16097658 by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Responses due by 11/28/2022 (Attachments: #1 Text of Proposed Order Granting Krupa Patel, Esq. Motion to Appear Pro Hac Vice)(Motta, Tucker) |
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Filing 24
PAPERLESS ORDER denying #19 Defendants' Expedited Motion for Telephonic Status Conference. The motion hearing on 11/18/2022 at 10:00 A.M. via the Zoom platform remains as scheduled #7 . All parties should be prepared to present argument and any relevant evidence/testimony in support of, or in opposition to, Plaintiff's Motion for Preliminary Injunction #5 . Signed by Judge Aileen M. Cannon on 11/13/2022. (kts)
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| Filing 23 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Carrie Shufflebarger. Filing Fee $ 200.00 Receipt # AFLSDC-16095146 by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Responses due by 11/28/2022 (Attachments: #1 Text of Proposed Order Granting Carrie Shufflebarger, Esq. Motion to Appear Pro Hac Vice)(Motta, Tucker) |
| Filing 22 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Anna Stressenger. Filing Fee $ 200.00 Receipt # AFLSDC-16095076 by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Responses due by 11/28/2022 (Attachments: #1 Text of Proposed Order Granting Anna Stressenger, Esq. Motion to Appear Pro Hac Vice)(Motta, Tucker) |
| Filing 21 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Meixuan (Michelle) Li. Filing Fee $ 200.00 Receipt # AFLSDC-16094943 by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Responses due by 11/28/2022 (Attachments: #1 Text of Proposed Order Granting Meixuan (Michelle) Li, Esq. Motion to Appear Pro Hac Vice)(Motta, Tucker) |
| Filing 20 Amended MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Eric N. Heyer. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See #18 Motion to Appear Pro Hac Vice,, by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Responses due by 11/28/2022 (Attachments: #1 Text of Proposed Order Granting Eric N. Heyer, Esq. Amended Motion to Appear Pro Hac Vice)(Motta, Tucker) |
| Filing 19 EXPEDITED MOTION for Telephonic Status Conference by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. (Motta, Tucker) |
| Filing 18 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Eric N. Heyer. Filing Fee $ 200.00 Receipt # AFLSDC-16093065 by D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Responses due by 11/28/2022 (Attachments: #1 Text of Proposed Order Granting Eric N. Heyer, Esq. Motion to Appear Pro Hac Vice)(Motta, Tucker) |
| Filing 17 NOTICE of Attorney Appearance by Tucker Crowley Motta on behalf of Kingdom Vapor Inc., SV3 LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Attorney Tucker Crowley Motta added to party Kingdom Vapor Inc.(pty:dft), Attorney Tucker Crowley Motta added to party SV3 LLC(pty:dft), Attorney Tucker Crowley Motta added to party Shenzhen Weiboli Technology Co. Ltd.(pty:dft), Attorney Tucker Crowley Motta added to party UNISHOW (U.S.A.), INC.(pty:dft), Attorney Tucker Crowley Motta added to party Ylsn Distribution LLC(pty:dft). (Motta, Tucker) |
| Filing 16 NOTICE of Attorney Appearance by Tucker Crowley Motta on behalf of D&A Distribution LLC, Ecto World LLC, Safa Goods LLC. Attorney Tucker Crowley Motta added to party D&A Distribution LLC(pty:dft), Attorney Tucker Crowley Motta added to party Ecto World LLC(pty:dft), Attorney Tucker Crowley Motta added to party Safa Goods LLC(pty:dft). (Motta, Tucker) |
| Filing 15 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by VPR Brands, LP. Ylsn Distribution LLC served on 10/21/2022, response/answer due 11/14/2022. (Rothman, Joel) |
| Filing 14 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by VPR Brands, LP. Kingdom Vapor Inc. served on 10/22/2022, response/answer due 11/14/2022. (Rothman, Joel) |
| Filing 13 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by VPR Brands, LP. SV3 LLC served on 10/26/2022, response/answer due 11/16/2022. (Rothman, Joel) |
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Filing 12
ORDER GRANTING #11 MOTION FOR ALTERNATIVE SERVICE ON SHENZHEN WEIBOLI TECHNOLOGY CO. LTD. Signed by Judge Aileen M. Cannon on 10/26/2022. See attached document for full details. (scn)
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| Filing 11 MOTION for Leave to Serve defendant Shenzen Weiboli Technology Co. Ltd. by Alternate Means by VPR Brands, LP. (Attachments: #1 Affidavit Declaration of Kevin Frija in Support of Motion for Alternate Service, #2 Text of Proposed Order Proposed Order on Motion for Alternate Service)(Rothman, Joel) |
| Filing 10 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by VPR Brands, LP. D&A Distribution LLC served on 10/20/2022, response/answer due 11/10/2022. (Rothman, Joel) |
| Filing 9 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by VPR Brands, LP. Safa Goods LLC served on 10/19/2022, response/answer due 11/9/2022. (Rothman, Joel) |
| Filing 8 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by VPR Brands, LP. Ecto World LLC served on 10/20/2022, response/answer due 11/10/2022. (Rothman, Joel) |
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Filing 7
ORDER Setting Hearing on #5 Plaintiff's MOTION for Preliminary Injunction. Motion Hearing set for 11/18/2022 10:00 AM before Judge Aileen M. Cannon via the Zoom platform. Status Report due by 11/15/2022. Signed by Judge Aileen M. Cannon on 10/17/2022. See attached document for full details. (scn)
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Filing 6
ORDER Requiring Combined Responses. Signed by Judge Aileen M. Cannon on 10/17/2022. See attached document for full details. (kts)
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| Filing 5 Plaintiff's MOTION for Preliminary Injunction by VPR Brands, LP. (Attachments: #1 Affidavit Frija Declaration, #2 Text of Proposed Order)(Rothman, Joel) |
| Filing 4 Summons Issued as to D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. (scn) |
| Filing 3 FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK. (Attachments: #1 Complaint and Exhibits) (scn) |
| Filing 2 Clerks Notice of Judge Assignment to Judge Aileen M. Cannon. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Bruce E. Reinhart is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (scn) |
| Filing 1 COMPLAINT FOR TRADEMARK INFRINGEMENT, UNFAIR COMPETITION AND PATENT INFRINGEMENT (INJUCTIVE RELIEF DEMANDED) against D&A Distribution LLC, Ecto World LLC, Kingdom Vapor Inc., SV3 LLC, Safa Goods LLC, Shenzhen Weiboli Technology Co. Ltd., UNISHOW (U.S.A.), INC., Ylsn Distribution LLC. Filing fees $ 402.00 receipt number AFLSDC-16021053, filed by VPR Brands, LP. (Attachments: #1 Exhibit 1 - ELF Registration, #2 Exhibit 2 - Elf Specimen, #3 Exhibit 3 - 622 Patent, #4 Civil Cover Sheet, #5 Summon(s) Shenzen Weiboli Summons, #6 Summon(s) Ylsn Summons, #7 Summon(s) Ecto World Summons, #8 Summon(s) Safa Goods Summons, #9 Summon(s) D&A Summons, #10 Summon(s) UNISHOW Summons, #11 Summon(s) SV3 Summons, #12 Summon(s) Kingdom Vapor Summons)(Rothman, Joel) |
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