“This action having been commenced by Plaintiff CAO Group, Inc. (“Plaintiff”) against Defendant ZHUHAI JIASHU DIANZISHANGWU YOUXIANGONGSI D/B/A GD-SSS A/K/A GD-WHITENING (“GD-WHITENING”), and Plaintiff having moved for entry of Default and Default Judgment against GD-Whitening (hereinafter, “Defaulting Defendant”); This Court having entered a preliminary injunction; Plaintiff having properly completed service of process on Defaulting Defendant, the combination of providing notice via e-mail, along with any notice that Defaulting Defendant received from online marketplaces and payment processors, being notice reasonably calculated under all circumstances to apprise Defaulting Defendant of the pendency of the action and affording them the opportunity to answer and present their objections; and Defaulting Defendant having failed to answer or appear in any way, and the time for answering having expired, so that the allegations of the Complaint are uncontroverted and are deemed admitted; This Court finds that it has personal jurisdiction over Defaulting Defendant because Case: 1:24-cv-05129 Document #: 13 Filed: 08/06/25 Page 1 of 7 PageID #:158 2 Defaulting Defendant directly targets its business activities toward consumers in the United States, including Illinois. Specifically, Plaintiff has provided a basis to conclude that Defaulting Defendant has targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more seller aliases, offer shipping to the United States, including Illinois, and have sold products that infringe upon Plaintiff’s federally registered patents, as claim in in U.S. Patent Nos. 10,603,259 B2 (“the ‘259 Patent”); 10,646,419 B2 (“the ‘419 Patent”); and 11,219,582 B2 (“the ‘582 Patent”); U.S. Patent No. 11,826,444, and U.S. Patent No. 11,826,445 (collectively, “Plaintiff’s Patents”) to residents of Illinois. In this case, Plaintiff has presented screenshot evidence that Defendant e-commerce store is reaching out to do business with Illinois residents by operating one or more commercial, interactive internet stores through which Illinoisresidents can and do purchase products that infringe Plaintiff’s Patents. See Schedule A and Exhibit 3 to the Verified Third Amended Complaint in Case No. 1:24-cv-01211, Docket Nos. [125-1] and [125-8], which includes links and product ID numbers for the subject storefronts and infringing products and screenshot evidence confirming that each Defendant e-commerce store does stand ready, willing and able to ship its infringing products to customers in Illinois; see also Exhibit G to the Verified Second Amended Complaint, Docket Nos. [2-7], which are claim charts outlining infringement by Defaulting Defendant. This Court further finds that Defaulting Defendant IS liable for willful patent infringement on each of the five patent infringement claims (Counts I, II, III, IV, and V) in Plaintiff’s Verified Second Amended Complaint. Accordingly, this Court orders that Plaintiff’s Motion for Entry of Default and Default Judgment is GRANTED as follows, that Defaulting Defendant is deemed in default, and that this Default Judgment is entered against Defaulting Defendant. Case: 1:24-cv-05129 Document #: 13 Filed: 08/06/25 Page 2 of 7 PageID #:159 3 This Court further orders that: 1. Defaulting Defendant, their officers, agents, servants, employees, attorneys, and all persons acting for, with, by, through, under, or in active concert with them be permanently enjoined and restrained from: a. Making, using offering for sale, selling, and/or importing into the United States for subsequent sale any products that infringe upon Plaintiff’s Patents or use of any product that infringes upon Plaintiff’s Patents in any manner in connection with the distribution, marketing, advertising, offering for sale, or sale of any product that is not a genuine Plaintiff product or not authorized by Plaintiff to be sold in connection with Plaintiff’s Patents; b. passing off, inducing, or enabling others to sell or pass off any product as a genuine Plaintiff product or any other product produced by Plaintiff, that is not Plaintiff’s or not produced under the authorization, control, or supervision of Plaintiff and approved by Plaintiff for use of the inventions claimed in Plaintiff’s Patents; c. committing any acts calculated to cause consumers to believe that Defaulting Defendant’s products are those sold under the authorization, control, or supervision of Plaintiff, or are sponsored by, approved by, or otherwise connected with Plaintiff and its rights in Plaintiff’s Patents; and d. manufacturing, shipping, delivering, holding for sale, transferring or otherwise moving, storing, distributing, returning, or otherwise disposing of, in any manner, products or inventory not manufactured by or for Plaintiff, nor authorized by Plaintiff to be sold or offered for sale, and which infringe upon the inventions claimed in Plaintiff’s Patents. Case: 1:24-cv-05129 Document #: 13 Filed: 08/06/25 Page 3 of 7 PageID #:160 4 2. Defaulting Defendant and any third party with actual notice of this Order who is providing services for the Defaulting Defendant, or in connection with the Defaulting Defendant’s Online Marketplaces, including, without limitation, any online marketplace platforms such as Amazon.com, Inc. (“Amazon”), eBay, Inc. (“eBay”), and Walmart, Inc. (“Walmart”), (collectively, the “Third Party Providers”), shall within seven (7) calendar days of receipt of this Order cease: a. using, linking to, transferring, selling, exercising control over, or otherwise owning the Online Marketplace Accounts, or any other online marketplace account that is being used to sell or is the means by which Defaulting Defendant could continue to sell goods that infringe upon Plaintiff’s Patents; and b. operating and/or hosting websites that are involved with the distribution, marketing, advertising, offering for sale, or sale of any product infringing Plaintiff’s Patents or any reproductions, copies or colorable imitations thereof that is not a genuine Plaintiff product or not authorized by Plaintiff to utilize the inventions claimed in Plaintiff’s Patents. 3. Upon Plaintiff’s request, those with notice of this Order, including the Third Party Providers as defined in Paragraph 2, shall within seven (7) calendar days after receipt of such notice, disable and cease displaying any advertisements used by or associated with Defaulting Defendant in connection with the sale of infringing goods using the inventions claimed in Plaintiff’s Patents. 4. Pursuant to 35 U.S.C. § 284, Plaintiff is awarded damages equal to a reasonable royalty from the Defaulting Defendant in the amount of $500,000.00. Case: 1:24-cv-05129 Document #: 13 Filed: 08/06/25 Page 4 of 7 PageID #:161 5 5. Pursuant to 35 U.S.C. § 284, Plaintiff is awarded expected transaction costs associated with the hypothetical negotiations and drafting of royalty and licensing agreements between it and the Defaulting Defendant listed below. Plaintiff is awarded $50,000.00 in expected transaction costs. 6. Pursuant to 35 U.S.C. § 284, Defaulting Defendant is subject to treble damages and Plaintiff is awarded three times the amount awarded in both paragraphs 4 and 5. 7. As a result of the damages awarded to Plaintiff in paragraphs 4 through 6 of this Order, the total awarded to the Plaintiff is $1,650,000 against Defaulting Defendant. 8. Any Third Party Providers holding funds for Defaulting Defendant, including Amazon Pay, eBay, PayPal, Inc. (“PayPal”), Payoneer Global, Inc. (“Payoneer”), and Walmart, shall, within seven (7) calendar days of receipt of this Order, permanently restrain and enjoin any accounts connected to Defaulting Defendant or the Defendant Internet Stores from transferring or disposing of any funds (up to the total damages awarded in Paragraph 4 through 7 above) or other of Defaulting Defendant’s assets. 9. All monies (up to the total damages and attorneys’ fees awarded in Paragraph 4 through 8 above) currently restrained in Defaulting Defendant’s financial accounts, including monies held by Third Party Providers such as Amazon Pay, eBay, PayPal, Payoneer, and Walmart, are hereby released to Plaintiff as partial payment of the above-identified damages, and Third Party Providers, including Amazon Pay, eBay, PayPal, Payoneer, and Walmart, are ordered to release to Plaintiff the amounts from Defaulting Defendant’s financial accounts within fourteen (14) calendar days of receipt of this Order. Case: 1:24-cv-05129 Document #: 13 Filed: 08/06/25 Page 5 of 7 PageID #:162 6 10. Until Plaintiff has recovered full payment of monies owed to it by Defaulting Defendant, Plaintiff shall have the ongoing authority to commence supplemental proceedings under Federal Rule of Civil Procedure 69. 11. In the event that Plaintiff identifies any additional online marketplace accounts or financial accounts owned by Defaulting Defendant, Plaintiff may send notice of any supplemental proceeding, including a citation to discover assets, to Defaulting Defendant by e-mail at the e-mail addresses provided for Defaulting Defendant by third parties. 12. To obtain release of the bond previously posted in this action, Plaintiff’s counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. This is a Default Judgment in Case No. 24-cv-05129.”