PLAINTIFF'S MOTION FOR JUDGMENT ON THE ANSWER OF THIRD PARTY CITATION RESPONDENT AND TURNOVER OF FUNDS

GARY FEINERMAN, District Judge.

Now Comes the Plaintiff, Weifang Tengyi Jewelry Trading Co., Ltd., by and through one of its attorneys, Charles E. McElvenny, and in support of Plaintiff's Motion for Judgment on the Answer of Third Party Citation Respondent, ContextLogic, Inc., and for Turnover of Funds, states as follows:

1. On February 14, 2019, judgment was entered in this Court in favor of the Plaintiff, Weifang Tengyi Jewelry Trading Co., Ltd. (Plaintiff), and against the Defendants in the attached exhibit entitled "Default Defendant Lists" in the total amount of $200,000. See Exhibits A [Docket 178] and B ["Default Defendant Lists"], respectively. Since the date of the Judgment and service of the Citation to Discover Assets, Plaintiff has not collected any amounts due. There is now due the sum of $200,000.

2. A Citation to Discover Assets to a Third Party was served on Third Party ContextLogic, Inc. on February 5, 2020. See Citation, attached hereto as Exhibit C.

3. ContextLogic, Inc. served its Answer on February 19, 2020, indicating that it is in possession of non-exempt funds belonging to certain Defendants and indicating that $948.68 in total was being withheld. See ContextLogic, Inc.'s Answer, attached hereto as Exhibit D.

4. Supplementary proceedings to enforce a judgment are governed by Federal Rule of Civil Procedure 69(a) which provides that a district court is to use state procedure governing the execution of any such judgment. Fed. R. Civ. P. 69(a).

5. Section 5/2-1402 of the Illinois Code of Civil Procedure provides that when assets of a judgment debtor not exempt from the satisfaction of a judgment are discovered, a court may enter an order or judgment compelling the person cited to deliver said assets. 735 ILCS 5/2-1402.

6. As such, the Plaintiff is entitled to the non-exempt property of Defendants identified in Schedule A of Exhibit D in partial satisfaction of the Judgment Balance remaining due.

WHEREFORE, the Plaintiff Weifang Tengyi Jewelry Trading Co., Ltd., respectfully requests that this Court enter a Judgment on its Third Party Citation and order Third Party Citation Respondent, Context Logic, Inc., to turnover to Plaintiff in partial satisfaction of the judgment, the property of judgment debtors identified in Schedule A to Exhibit D in the total amount of $948.68, and for such other relief that this Court deems just and proper.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

FINAL JUDGMENT ORDER

This action having been commenced by Plaintiff Weifang Tengyi Jewelry Trading Co., Ltd. ("Weifang" or "Plaintiff") against the defendants identified on Schedule A, attached hereto, and using the Online Marketplace Accounts (collectively, the "Defendant Internet Stores"), and Plaintiff having moved for entry of Default Judgment, following the previous entry of default, against the defendants identified on Schedule A attached hereto (collectively, the "Defaulting Defendants");

This Court having entered upon a showing by Weifang, a temporary restraining order against Defaulting Defendants which included an order shutting down the Defendant Internet Stores;

Weifang having properly completed service of process on Defaulting Defendants, the combination of providing notice via electronic publication and e-mail, along with any notice that Defaulting Defendants received from eBay, Wish and/or Paypal, being notice reasonably calculated under all circumstances to apprise Defaulting Defendants of the pendency of the action and affording them the opportunity to answer and present their objections; and

Defaulting Defendants having failed to answer the Amended Complaint or otherwise plead, and the time for answering the Amended Complaint having expired;

THIS COURT HEREBY FINDS that it has personal jurisdiction over Defaulting Defendants since Defaulting Defendants directly target their business activities toward consumers in the United States, including Illinois. Specifically, Defaulting Defendants are reaching out to do business with Illinois residents by operating one or more commercial, interactive Defendant Internet Stores through which Illinois residents can purchase products using counterfeit versions of the Plaintiff's federally registered ULOVEIDO Trademark, U.S. Trademark Registration No. 5,017,523.

THIS COURT FURTHER FINDS that Defaulting Defendants are liable for willful federal trademark infringement and counterfeiting (15 U.S.C. § 1114), false designation of origin (15 U.S.C. § 1125(a)), and violation of the Illinois Uniform Deceptive Trade Practices Act (815 ILCS § 510, et seq.).

IT IS HEREBY ORDERED that Weifang's Motion for Entry of Default Judgment is GRANTED in its entirety, that Defaulting Defendants are deemed in default and that this Final Judgment is entered against Defaulting Defendants. IT IS FURTHER ORDERED that:

1. Defaulting Defendants, their affiliates, officers, agents, servants, employees, attorneys, confederates, and all persons acting for, with, by, through, under, or in active concert with them be permanently enjoined and restrained from:

2. Pursuant to 15 U.S.C. § 1117(c)(2), Weifang is awarded statutory damages from each of the Defaulting Defendants in the amount of two hundred thousand dollars ($200,000) for willful use of counterfeit ULOVEIDO Trademarks on products sold through at least the Defendant Internet Stores. The two hundred thousand dollar ($200,000) award shall apply to each distinct Defaulting Defendant only once, even if they are listed under multiple different aliases in the Amended Complaint and Schedule A.

3. Plaintiff may send notice of any supplemental proceeding to Defaulting Defendants by sending an e-mail to the e-mail addresses identified in Exhibits 1-16 to the Declaration of Teng Guangyao [Doc. 10] and any e-mail addresses provided for Defendants by third parties that includes a link to said website.

4. Plaintiff may send notice of any supplemental proceeding to third parties by delivery of this Order and other relevant documents to the following Financial Institutions and/or Third Party Service Providers at the following addresses:

i. PayPal, attention EE Omaha Legal Specialist at EEOMALegalSpecialist@paypal.com;

ii. Alipay, attention Mr. Benjamin Bai, Vice President and Chief IP Counsel of Ant Financial Services Group at benjamin.bai@alipay.com or Mr. Di Zhang, Member of the Legal & Compliance Department — IP, at di.zd@alipay.com;

iii. Alibaba, attention Ms. Jacqueline Ko, Legal Counsel, Alibaba Group at Jacqueline.ko@alibaba-inc.com;

iv. DHgate (including DHPay.com) attention counsel for DHGate at slucks@fishinlucks.com;

v. Wish, attention Mr. Dwight D. Lueck at dlueck@btlaw.com;

vi. eBay, Inc. attention Mr. James Kaplan, eDiscovery Counsel, at jnkaplan@ebay.com.

This is a Final Judgment.

Amended Schedule A

WeifangTengyi Jewelry Trading Co. Ltd v. IMSUNSHINE et al. Case No. 18-cv-4651

Default Defendant Lists

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

NOTICE OF THIRD PARTY CITATION TO DISCOVER ASSETS

Judgment Debtor's last known email address:

Provided by Third Parties in the above captioned case.

This Third Party Citation is set for February 26, 2020, at 9 a.m. at 120 N. LaSalle St. Suite 1200, Chicago, IL 60602.

A judgment in favor of Plaintiff and against The Defendants identified in the attached Schedule was entered on February 14, 2019, in this Court under Case Number 18 cv 4651 in the amount of $200,000 and $200,000 remains unsatisfied.

NOTICE: The court has issued a citation against the person named above. The citation directs that the person to appear in court to be examined for the purpose of allowing the judgment creditor to discover income and assets belonging to the judgment debtor or in which the judgment debtor has an interest. The citation was issued on the basis of a judgment against the judgment debtor and in favor of the judgment creditor in the amount stated above. On or after the court date stated above, the court may compel the application of any discovered income or assets toward payment on the judgment.

The amount of income or assets that may be applied toward the judgment is limited by federal and Illinois law. THE JUDGMENT DEBTOR HAS THE RIGHT TO ASSERT STATUTORY EXEMPTIONS AGAINST CERTAIN INCOME OR ASSETS OF THE JUDGMENT DEBTOR WHICH MAY NOT BE USED TO SATISFY THE JUDGMENT IN THE AMOUNT STATED ABOVE.

1. Under Illinois or federal law, the exemption of personal property owned by the debtor includes the debtor's equity interest, not to exceed $4,000 in value, in any personal property as chosen by the debtor, including money in a bank account.

2. Social Security and SSI benefits;

3. Public assistance benefits;

4. Unemployment compensation benefits;

5. Worker's compensation benefits;

6. Veteran's benefits;

7. Circuit breaker property tax relief benefits;

8. The debtor's equity interest, not to exceed $2,400 in value, in any one motor vehicle;

9. The debtor's equity interest, not to exceed $1.500 in value, in any implements, professional books, or tools of the trade of the debtor;

10. Under Illinois law every person is entitled to an estate in homestead, when it is owned and occupied as a residence to the extent in value of $15,000 which homestead is exempt from judgment.

11. Under Illinois law, the amount of wages that may be applied toward a judgment is limited to the lesser of (i) 15% of gross weekly wages or (ii) the amount by which disposable earnings for a week exceed the total of 45 times the greater of the state or federal minimum hourly wage.

12. Under federal law, the amount of wages that may be applied toward a judgment is limited to the lesser of (i) 25% of disposable earnings for a week or (ii) the amount by which disposable earnings for a week exceed 30 times the federal minimum hourly wage.

13. Pension and retirement benefits (including IRA accounts) and refunds may be claimed as exempt under Illinois law.

The judgment debtor may have other possible exemptions under the law.

THE JUDGMENT DEBTOR HAS THE RIGHT AT THE CITATION HEARING TO DECLARE EXEMPT CERTAIN INCOME OR ASSETS OR BOTH. The judgment debtor also has the right to seek a declaration at an earlier date by notifying the clerk in writing at the office of the Clerk of the United States District Court for the northern District of Illinois, Eastern Division, 219 South Dearborn Street, 20th Floor, Chicago, IL 60604. When so notified. the Clerk of the United States District Court will obtain a prompt hearing date from the court and will provide the necessary forms that must be prepared by the judgment debtor or the attorney for the judgment debtor and sent to the judgment creditor or the judgment creditor's attorney by regular first class mail, regarding the time and location of such hearing.

This notice may be sent to the judgment debtor and any other person/entity by regular first class mail and/or email.

CERTIFICATE OF SERVICE

I, the undersigned an attorney, state that I served the enclosed Citation to Discover Assets to Third Party and Notice of Citation on the above named persons at the above stated addresses by mail and/or email in Chicago, Illinois by this 4th der of 7ebruary 2020.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

CITATION TO DISCOVER ASSETS TO A THIRD PARTY

YOU ARE REQUIRED to either file your answer to this Citation on the form appearing on the reverse side or appear on February 26, 2020 before 9:30 am at 120 N. LaSalle St., Suite 1200, Chicago, IL 60602.

Judgment was entered on February 14, 2019, in favor of Plaintiff and against Defendants identified in the attached Schedule in this court under case number 18 cv 4651 in the sum of $200,000. There is now due, less credit and off-set, sum of $200,000 (Judgment Balance). Further sums may become due as costs and interests accrue.

Your answer will inform the Court as to property you may hold belonging to the Defendants identified in the attached Schedule.

YOU ARE FURTHER COMMANDED TO PRODUCE:

Any and all account information identifying, controlled by, connected or relating to the Defendants identified in the attached Schedule.

You are prohibited from making or allowing any transfer or other disposition of, or interfering with, any property not exempt from the enforcement of a judgment, a deduction order or garnishment, property belonging to the judgment debtor or to which s/he may be entitled or which may thereafter be acquired by or become due to him or her, and from paying over or otherwise disposing of any monies not so exempt, which are due to the judgment debtor. This prohibition shall remain in effect until further order of court or termination of the proceeding.

You are not required to withhold the payment of any monies beyond double the amount of the total sum due the judgment creditor.

If the account consists solely of funds that can be identified as exempt under federal or state law, you are PROHIBITED from FREEZING THE ACCOUNT and YOU MUST RESPOND that the account consists solely of exempt funds. Deposited funds that are exempt under federal and state law include Social Security, SSI, veteran's benefits, Railroad Retirement benefits, public assistance benefits, unemployment compensation benefits and/or circuit breaker property tax relief benefits.

WARNING: Your failure to comply with the citation proceeding may result in a judgment being entered against you for the unsatisfied amount of this judgment. 735 ILCS 5/2-1402(f)(1).

WARNING: Your failure to appear in court or file you answer as directed may cause you to be arrested and brought before the court to answer to a charge of contempt of court, which may be punishable by imprisonment in the county jail.

CERTIFICAT ON BY ATTORNEY FOR JUDGMENT CREDITOR

Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure (735 ILCS 5/1-109), the undersigned certifies that the above information regarding the amount of the judgment, the date or the judgment, or its revival date, the balance due thereon, the name of the court and the number of the case is true and correct./

Clerk of the Court for the United States District Court, Northern District of Illinois

ANSWER OF THIRD PARTY RESPONDENT CITATION

This first section must be filled out by the judgment creditor.

INTERROGATORIES

1. On the date of service of the citation, did you have in your possession, custody or control any personal property or monies belonging to the judgment debtor? Yes/No If the answer is "yes" go to the next question. If "no", go to the instructions.

2. Is this an IRA account? Or have all of the deposits made during the past 90 days been electronically deposited and identified as exempt Social Security, Unemployment Compensation, Public Assistance, Veteran's Benefits, Pension or Retirement or by a source drawing from any other statutory exemptions? Yes/No

If the answer is "yes" go to the next question. If "no", go to the instructions.

3. Is/Are the account(s)' current balance(s) equal to or less than the total of the exempt deposits? Yes/No

If you answered "yes" to all three (3) questions and funds in the account(s) are exempt, do not freeze the funds. Go to the "instructions" below.

5. List all electronic deposits into account(s) and their source(s) except deposits:

6. List all joint account holders or adverse claimants:

INSTRUCTIONS

Deliver this Answer at least three (3) days before the court date to assure timely processing.

Complete the Answer of Third Party Respondent Citation section on this form.

Complete and sign the certification at the bottom of this page.

CERTIFICATION

Under the penalties as provided by law pursuant to Section 1-109 of the code of Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct and that I have mailed this Answer to Defendant(s).

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

ANSWER OF THIRD PARTY RESPONDENT CONTEXTLOGIC INC. TO CITATION TO DISCOVER ASSETS TO A THIRD PARTY

INTERROGATORIES

1. On the date of service of the citation, did you have in your possession, custody or control any personal property or monies belonging to the judgment debtor? Yes/No If the answer is "yes" go to the next question. If "no", go to the instructions.

ANSWER: Yes.

2. Is this an IRA account? Or have all of the deposits made during the past 90 days been electronically deposited and identified as exempt Social Security, Unemployment Compensation, Public Assistance, Veteran's Benefits, Pension or Retirement or by a source drawing from any other statutory exemptions? Yes/No If the answer is "yes" go to the next question. If "no", go to the instructions.

ANSWER: No.

3. Is/Are the account(s)' current balance(s) equal to or less than the total of the exempt deposits? Yes/No

ANSWER: Not applicable.

If you answered "yes" to all three (3) questions and funds in the account(s) are exempt, do not freeze the funds. Go to the "instructions" below.

5. List all electronic deposits into account(s) and their source(s) except deposits:

6. List all joint account holders or adverse claimants:

INSTRUCTIONS

Deliver this Answer at least three (3) days before the court date to assure timely processing.

Complete the Answer of Third Party Respondent Citation section on this form.

Complete and sign the certification at the bottom of this page.

CERTIFICATION

Under the penalties as provided by law pursuant to Section 1-109 of the code of Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct and that I have mailed this Answer to Defendant(s).

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of this Answer of Third Party Respondent ContextLogic Inc. to Citation to Discovery Assets to a Third Party is being sent via electronic mail and via first class mail, postage prepaid, to the following counsel of record this February 19, 2020.

Schedule A