UNITED STATES DISTRICT COURT STRICR WESTERN DISTRICT OF NEW YORK Ss □□ MAR 2 9 2004 peer es Plaintiff, RN DisTRICT OF

v. 24-CV-59 (JLS) THE CORPORATIONS, INDIVIDUALS, PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE “A”, Defendants.

PRELIMINARY INJUNCTION ORDER Before the Court is Plaintiff Umbra LLC’s motion for a preliminary injunction (Dkt. 7). Based on its review of the complaint (Dkt. 1), the motion for a preliminary injunction and supporting declarations and exhibits (Dkt. 7), and the record of proceedings in this case, the Court finds the following: e On February 22, 2024, Plaintiff filed ex parte applications for: (1) a temporary restraining order; (2) an order restraining Defendants’ seller accounts and assets with relevant third-party service platforms and financial institutions; (3) an order to show cause why a preliminary injunction should not issue; (4) an order authorizing alternative service of process via email and website posting; and (5) an order authorizing expedited discovery of e-commerce marketplace platforms located at Temu.com, SHEIN.com, and eBay.com;

° On March 6, 2024, the Court entered an order granting Plaintiffs ex parte application (Dkt. 13) (the “TRO”), which ordered Defendants to

appear on March 15, 2024, at 2:00 p.m., to show cause why a preliminary injunction should not issue; e On March 12, 2024, Plaintiff effectuated service of the subpoenas and TRO on all third-party service providers; e On March 12, 2024, Plaintiff moved for an extension of certain deadlines contained within the TRO, as well as for an extension of the TRO (Dkt. 14); e On March 15, 2024, the Court granted Plaintiffs extension motion (Dkt. 15), extending the TRO by fourteen days, setting a March 27, 2024 deadline for any written opposition to the TRO and preliminary injunction motion, and rescheduling the show-cause hearing to March 29, 2024 at 3:30 p.m.; ° On March 20, 2024, Plaintiff served all papers filed in this lawsuit on each known Defendant; ° On March 27, 2024, pursuant to the alternative methods of service authorized by the TRO, Plaintiff received 57 signed summonses that were uploaded to a secure website containing copies of the complaint, the TRO, all papers filed in support of Plaintiffs application, and the March 15, 2024 extension order for review by each Defendant with a valid email address;

e No Defendant submitted a written opposition to the TRO and preliminary injunction motion by the March 27, 2024 deadline; ° On March 29, 2024, at 3:30 p.m., Plaintiff appeared at the show-cause hearing, but no Defendants appeared; ° For the reasons discussed on the record at the March 29, 2024 show- cause hearing, all Defendants, except Defendants 6, 8, and 11, received sufficient notice of the TRO and preliminary injunction motion; and

° For the reasons discussed on the record at the March 29, 2024 show-

cause hearing, the Court has personal jurisdiction over all Defendants, except Defendants 6, 8, and 11. Based on the above, and the record of the proceedings in this case, and for the additional reasons in the TRO (Dkt. 13), IT IS HEREBY ORDERED that: 1. This order shall apply to all of the seller IDs, associated e-commerce stores and websites, and any other seller identification names, e- commerce stores, domain names, websites, or financial accounts that are being used by Defendants to infringe Plaintiffs patent and/or unfairly compete with Plaintiff. 2. Each Defendant listed in Schedule “A”—except Defendants 6, 8, and including its officers, directors, employees, agents, subsidiaries, and all persons in active concert or participation with any Defendant, having notice of this and order, are hereby restrained and enjoined until further order of this Court:

a. from manufacturing, importing, advertising, promoting, offering to sell, selling, distributing, or transferring any products infringing on the claims protected in Plaintiffs patent (Patent No: US 10,273,671 B2, dated April 20, 2019), or bearing reproductions or derivatives of Plaintiffs patent other than those actually manufactured or distributed by Plaintiff; and b. from secreting, concealing, destroying, selling off, transferring, or otherwise disposing of: (i) any products, not manufactured or distributed by Plaintiff, bearing reproductions or derivatives of Plaintiffs patent; or (ii) any evidence relating to the manufacture, importation, sale, offer for sale, distribution, or transfer of any products bearing reproductions or derivatives of Plaintiffs patent; or (iii) any assets or other financial accounts subject to this order, including inventory assets, in the actual or constructive possession of, or owned, controlled, or held by, or subject to access by, any Defendant, including, but not limited to, any assets held by or on behalf of any Defendant. 3. Each Defendant, its officers, directors, employees, agents, subsidiaries, and any third-party financial institutions, payment processors, banks, escrow services, or money transmitters, and their related companies and affiliates, having notice of this order shall: a. immediately discontinue the use of any unauthorized copies Plaintiffs patent, on or in connection with all Internet based e-

commerce seller stores owned and operated, or controlled by them, including the Internet based e-commerce stores operating under the seller IDs listed in Schedule “A” until further order of this Court; b. not transfer ownership of the seller IDs listed in Schedule “A” during the pendency of this action, or until further order of the Court; c. restrain the transfer of all funds, including funds relating to ongoing account activity, held or received for Defendants’ benefit

or to be transferred into Defendants’ respective financial accounts and restrain any other financial accounts tied thereto, and immediately divert those restrained funds to a holding account for the trust of the Court. AND IT IS FURTHER ORDERED that Plaintiff shall serve this order upon each Defendant, promptly upon ascertaining their email addresses, by: 1. sending emails to each Defendant via the email accounts provided by each Defendant as part of the data related to its e-commerce store, including customer service email addresses and onsite contact forms, or by the e-commerce platform email for each of the e-commerce stores, and in the email providing the address to Plaintiffs designated website to Defendants; and 2. publicly posting a copy of this order and all filings in this matter on Plaintiffs designated website: https://bit.ly/RP-Umbra;

AND IT IS FURTHER ORDERED that Defendants are hereby given notice that they may be deemed to have actual notice of the terms of this order, and any act in violation of this order may be considered and prosecuted as contempt of this Court; AND IT IS FURTHER ORDERED that the $10,000 bond posted by Plaintiff shall remain with the Court until a final disposition of this case, or until this order is terminated; AND IT IS FURTHER ORDERED that this order shall remain in effect during the pendency of this action, or until further order of the Court; AND IT IS FURTHER ORDERED that any Defendant subject to this order

may appear and move to dissolve or modify the order on two days’ notice to Plaintiff

or on shorter notice as set by the Court; AND IT IS FURTHER ORDERED that if Defendants do not appear, Plaintiff shall provide the Court with a status update by May 13, 2024, informing the Court whether Plaintiff intends to move for an order granting a permanent injunction and default judgment; AND IT IS FURTHER ORDERED that this order shall go into effect immediately; AND IT IS FURTHER ORDERED that thi 4 unsealed. (> i

Dated: Bae = “ee k GZ 7 uftalo, New Yor <f A \ =u JOHN L. SINATRA; JR. UNITED STATES DISTRICT JUDGE

SCHEDULE A

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