RESPONSE by Kuiper Ventures LLCin Opposition to MOTION by Defendant Bedshe International Co., Ltd. to stay OPPOSED MOTION TO STAY PENDING RESOLUTION OF ITS MOTION TO DISMISS OR TRANSFER [57]

附件：

1:Exhibit 1 - Declaration of Nathan Jermolenko

MINUTE entry before the Honorable Mary M. Rowland: In person hearing on motion to compel [67] set for 2/5/26 at 9:30 AM. Mailed notice.

ANSWER to amended complaint by SUZHOU LIMIT TRADING CO.,LTD.

ATTORNEY Appearance for Defendant SUZHOU LIMIT TRADING CO.,LTD. by Mingzi Ouyang

MEMORANDUM by Kuiper Ventures LLC in support of motion to compel[67]

附件：

1:Exhibit 3 - Declaration of N. Jermolenko
2:Exhibit 2 - Bedsure Response to Requests for Production 1-4
3:Exhibit 1 - Requests for Production 1-4 to Bedsure

MOTION by Plaintiff Kuiper Ventures LLC to compel Bedsure to provide responses to the four requests for production issued to it

SUMMONS Returned Executed by Kuiper Ventures LLC as to Changshushizhilankejiyouxiangongsi on 1/11/2026, answer due 2/2/2026.

SUMMONS Returned Executed by Kuiper Ventures LLC as to SUZHOU LIMIT TRADING CO.,LTD. on 1/11/2026, answer due 2/2/2026.

SUMMONS Returned Executed by Kuiper Ventures LLC as to Bedshe International Co., Ltd. on 1/7/2026, answer due 1/28/2026.

MINUTE entry before the Honorable Mary M. Rowland: Reply in support of the motion for preliminary injunction is due 1/30/26. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to extend the time to file for an extension of the TRO [38] is denied as moot. See [50]. Mailed notice.

MEMORANDUM by Bedshe International Co., Ltd. in Opposition to motion for preliminary injunction[44]

附件：

1:Declaration
2:Exhibit A
3:Exhibit A-1
4:Exhibit B
5:Exhibit C
6:Exhibit D

ATTORNEY Appearance for Plaintiff Kuiper Ventures LLC by Jonathan Michael Francis

MINUTE entry before the Honorable Mary M. Rowland: Response to the motion to dismiss for improper venue [55] due 2/17/26; reply due 3/3/26. Response to motion to stay entry to a preliminary injunction and discovery as to defendant Bedshe International due 1/27/26; reply due 2/3/26. The TRO will remain in place as to Bedshe while the court considers the motion to stay. Mailed notice.

MEMORANDUM IN SUPPORT OF ITS OPPOSED MOTION TO STAY PENDING RESOLUTION OF ITS MOTION TO DISMISS OR TRANSFER

附件：

1:Exhibit
2:Exhibit
3:Exhibit
4:Exhibit
5:Exhibit
6:Exhibit

MOTION by Defendant Bedshe International Co., Ltd. to stay OPPOSED MOTION TO STAY PENDING RESOLUTION OF ITS MOTION TO DISMISS OR TRANSFER

MEMORANDUM by Bedshe International Co., Ltd. in support of motion to dismiss[55]

附件：

1:Exhibit A(Chen Decl)

MOTION by Defendant Bedshe International Co., Ltd. to dismiss FOR IMPROPER VENUE

SUMMONS Issued (Court Participant) as to Defendants Bedshe International Co., Ltd., Changshushizhilankejiyouxiangongsi, SUZHOU LIMIT TRADING CO.,LTD.

SUMMONS Submitted (Court Participant) for defendant(s) SUZHOU LIMIT TRADING CO.,LTD. by Plaintiff Kuiper Ventures LLC

SUMMONS Submitted (Court Participant) for defendant(s) changshushizhilankejiyouxiangongsi by Plaintiff Kuiper Ventures LLC

SUMMONS Submitted (Court Participant) for defendant(s) BEDSHE INTERNATIONAL CO., LTD. by Plaintiff Kuiper Ventures LLC

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to amend/correct [28] is denied as moot. [32]. Plaintiff's motion for early discovery regarding Amazon's takedowns [34] is granted. The Court grants the motion to extend the TRO [36] for 14 days from the expiration of the original TRO or until 1/6/25. Any response to the motion for preliminary injunction is due 1/20/26. A status report on whether any defendant opposed the motion for preliminary injunction is due 1/26/26. Plaintiff's motion to file an amended complaint [49] is granted. Response to amended complaint due 1/26/26. Mailed notice.

MOTION by Plaintiff Kuiper Ventures LLC for leave to file Amended Verified Complaint

AMENDED complaint by Kuiper Ventures LLC against Bedshe International Co., Ltd., Changshushizhilankejiyouxiangongsi, SUZHOU LIMIT TRADING CO.,LTD. and terminating Elite Collection US

附件：

1:Exhibit 2 - Listing Images
2:Schedule A
3:Exhibit 1 - Patent at Issue

SUMMONS - ERROR UNPROCESSED due to an order is required to issue a summons applicable to all defendants, or those that differ from the case caption of the complaint filed.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/31/2025: Mailed notice.

MEMORANDUM by Kuiper Ventures LLC in support of motion for preliminary injunction[44] CORRECTED

附件：

1:Exhibit 6 - Declaration of N. Jermolenko re: Sochow
2:Exhibit 5 - Declaration of N. Jermolenko re: Plush & Plaid
3:Exhibit 1 - Patent at Issue
4:Exhibit 2 - Declaration of N. Jermolenko re: investigation
5:Exhibit 3 - Declaration of Counsel
6:Exhibit 4 - Declaration of N. Jermolenko re Bedsure

MEMORANDUM by Kuiper Ventures LLC in support of motion for preliminary injunction[44]

附件：

1:Exhibit 3 - Declaration of Counsel
2:Exhibit 4 - Declaration of N. Jermolenko re: Bedsure
3:Exhibit 6 - Declaration of N. Jermolenko re: Sochow
4:Exhibit 5 - Declaration of N. Jermolenko re: Plush & Plaid
5:Exhibit 1 - Patent at Issue
6:Exhibit 2 - Declaration of N. Jermolenko re: investigation

MOTION by Plaintiff Kuiper Ventures LLC for preliminary injunction

SUMMONS Submitted (Court Participant) for defendant(s) Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associates Identified On Schedule A by Plaintiff Kuiper Ventures LLC

SUMMONS - ERROR UNPROCESSED due to an order is required to issue a summons applicable to all defendants, or those that differ from the case caption of the complaint filed.

NOTICE of Voluntary Dismissal by Kuiper Ventures LLC of guawodianzishangwuyixingyouxiangongsi d/b/a Elite Collection US (Defendant 2

SUMMONS Submitted (Court Participant) for defendant(s) SUZHOU LIMIT TRADING CO.,LTD. (Def. 3) by Plaintiff Kuiper Ventures LLC

SUMMONS Submitted (Court Participant) for defendant(s) BEDSHE INTERNATIONAL CO., LTD (Def. 1) by Plaintiff Kuiper Ventures LLC

SUMMONS Submitted (Court Participant) for defendant(s) changshushizhilankejiyouxiangongsi (Def. 4) by Plaintiff Kuiper Ventures LLC

MOTION by Plaintiff Kuiper Ventures LLC for extension of time to file for extension of TRO.

附件：

1:Exhibit 1 - Declaration of Counsel

MEMORANDUM by Kuiper Ventures LLC in support of extension of time[36]

附件：

1:Exhibit 1 - Declaration of Counsel

NEW PARTIES: Bedshe International Co., Ltd., SUZHOU LIMIT TRADING CO.,LTD. and Changshushizhilankejiyouxiangongsi added to case caption.

MOTION by Plaintiff Kuiper Ventures LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Kuiper Ventures LLC in support of motion for miscellaneous relief[34]

附件：

1:Exhibit 2 - Takedown Dashboard and Response
2:Exhibit 1 - Messages Suggesting Takedowns Would Be Removed In Exchange for Sett

MOTION by Plaintiff Kuiper Ventures LLC early discovery re: Amazon takedowns against Plaintiff and follow up messages

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to unseal documents [30] is granted. The Clerk is directed to unseal documents [6][11][15] and [26]. Mailed notice.

ORDER Signed by the Honorable Mary M. Rowland on 12/23/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: The Court has considered Plaintiff's motion to modify the asset restraint. [29]. That motion is granted. Enter order. Defendant Bedsure's motion to modify the TRO [23] is denied as moot. The parties' motions to seal [22] and [27] are granted. Mailed notice.

MOTION by Plaintiff Kuiper Ventures LLC to unseal document sealed document, [11], sealed document[26], SEALED Order[15], sealed document, [6]

MOTION by Plaintiff Kuiper Ventures LLC to amend/correct SEALED Order[15] to Modify Asset Restraint of Defendants 3 and 4

MOTION by Plaintiff Kuiper Ventures LLC to amend/correct SEALED Order[15] to Modify Asset Restraint of Defendant 1-Bedsure

MOTION by Plaintiff Kuiper Ventures LLC to seal document sealed document[26]

SEALED DOCUMENT by Plaintiff Kuiper Ventures LLC Unredacted Declaration of Nathan Jermolenko

MEMORANDUM by Kuiper Ventures LLC in Opposition to Sealed motion, [23]

附件：

1:Exhibit 3 - Declaration of Counsel
2:Exhibit 1 - Email Chain
3:Exhibit 2 - Declaration of N. Jermolenko

SEALED DOCUMENT by Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The MEMORANDUM IN SUPPORT OF EMERGENCY OPPOSED MOTION TO MODIFY TRO for Defendant Bedsure

SEALED MOTION by Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The DEFENDANTS EMERGENCY OPPOSED MOTION TO MODIFY TRO for Defendant Bedsure

SEALED MOTION by Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The motion to seal for Defendant Bedsure

ATTORNEY Appearance for Defendant Elite Collection US by David Silver

BOND in the amount of $4000.00 cashier's check, Receipt No. 100027658, posted by Kuiper Ventures LLC

Registry Deposit Information Form by Kuiper Ventures LLC

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Christopher James Fahy for Defendant Bedsure

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Yu Di for Defendant Bedsure

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Hao Tan for Defendant Bedshe

ATTORNEY Appearance for Defendant Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified On Schedule A, The by Xuanjie Wang for Defendant Bedsure

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 12/9/2025.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to seal [13] is granted. The Court grants Plaintiff's motion for a Temporary Restraining Order [10]. Plaintiff is to send a proposed TRO to the Court's proposed order box for review. Mailed notice.

MOTION by Plaintiff Kuiper Ventures LLC to seal document sealed document, [11]

MEMORANDUM by Kuiper Ventures LLC in support of motion for temporary restraining order, motion for miscellaneous relief, motion for discovery, [10]

附件：

1:Exhibit 2 - Declaration of N. Jermolenko
2:Exhibit 1 - Patent at Issue

MOTION by Plaintiff Kuiper Ventures LLC for temporary restraining order, MOTION by Plaintiff Kuiper Ventures LLCtemporary restraining order, early discovery, asset restraint, MOTION by Plaintiff Kuiper Ventures LLC for discovery early

Order on Motion for Miscellaneous Relief

Miscellaneous Relief

SEALED DOCUMENT by Plaintiff Kuiper Ventures LLC Verified Complaint & Exhibits

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motions to file under seal [3][4] are granted. Plaintiff is to file the documents unredacted under seal by 12/8/25. Mailed notice.

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 1).

MOTION by Plaintiff Kuiper Ventures LLC to seal document complaint, 1 CORRECTED

MOTION by Plaintiff Kuiper Ventures LLC to seal document complaint, 1

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kuiper Ventures LLC

COMPLAINT filed by Kuiper Ventures LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-24400280.

附件：

1:Exhibit 1 - Redacted
2:Exhibit 2 - Redacted
3:Redacted Schedule A
4:(Civil Cover Sheet)