Just Play, LLC v. Borei Toys, et al.

NOTICE OF VOLUNTARY PARTIAL DISMISSAL : Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, Plaintiff Just Play, LLC ("Just Play" or "Plaintiff"), by its undersigned attorneys, hereby gives notice of dismissal of all claims against Defendant Choice VIP Store in the above-captioned action, without prejudice, and with each party to bear its own attorneys' fees, costs and expenses. It is so ORDERED., (Choice VIP Store terminated.) (Signed by Judge Lewis A. Kaplan on 9/3/25)

CERTIFICATE OF SERVICE. Document filed by Just Play, LLC.

PRELIMINARY INJUNCTION ORDER: 1. The injunctive relief previously granted in the TRO shall remain in place through the pendency of this action, and issuing this Order is warranted under Federal Rule of Civil Procedure 65 and Section 34 of the Lanham Act. a) Accordingly, Defendants are hereby restrained and enjoined from engaging in any of the following acts or omissions pending the final hearing and determination of this action or until further order of the Court: As further set forth by this Order. The $25,000.00 bond posted by Plaintiff shall remain with the Court until a final disposition of this case or until this Order is terminated. This Order shall remain in effect during the pendency of this action, or until further order of the Court. Any Defendants that are subject to this Order may appear and move to dissolve or modify the Order on two (2) days' notice to Plaintiff or on shorter notice as set by the Court. SO ORDERED. (Signed by Judge Jed S. Rakoff on 8/14/2025) (tg) Transmission to Finance Unit (Cashiers) for processing.

CERTIFICATE OF SERVICE. Borei Toys served on 8/6/2025, answer due 8/27/2025; Botou Yongchuang Spring Manufacturing Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Chaoshanliangzai served on 8/6/2025, answer due 8/27/2025; Dongguan Jiule Bussiness Limited Company served on 8/6/2025, answer due 8/27/2025; EIDOMAC CAR served on 8/6/2025, answer due 8/27/2025; FINEWE INDUSTRY CO., LTD. Store served on 8/6/2025, answer due 8/27/2025; Foshan Nanhai Qili Hardware And Spring Products Factory served on 8/6/2025, answer due 8/27/2025; Happy beauty beauty served on 8/6/2025, answer due 8/27/2025; Hunan Raco Enterprises Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Jiangmen Hengxin Precision Parts Co., served on 8/8/2025, answer due 8/29/2025; Mai Mai Store served on 8/6/2025, answer due 8/27/2025; NOAS served on 8/6/2025, answer due 8/27/2025; Ningbo Jiangbei Lisheng Spring Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Novel design served on 8/6/2025, answer due 8/27/2025; Shanghai Long Nice International Trading Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Shantou Longhu Longheng Toys Factory served on 8/6/2025, answer due 8/27/2025; Shantou Market Union Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Shenzhen Dakunlun Hardware & Plastic Products Co.,Ltd. served on 8/7/2025, answer due 8/28/2025; Shenzhen Hongyan E- Commerce Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Shenzhen Songkang Technology Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Shenzhen Yuxiang Technology Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Shop1102400224 Store served on 8/6/2025, answer due 8/27/2025; Shop1102844309 Store served on 8/6/2025, answer due 8/27/2025; Shop1103202353 Store served on 8/6/2025, answer due 8/27/2025; Shop1103277074 Store served on 8/6/2025, answer due 8/27/2025; Shop1103602395 Store served on 8/6/2025, answer due 8/27/2025; Shop1104162738 Store served on 8/6/2025, answer due 8/27/2025; Suzhou Best Crafts Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Xiamen Finewe Industry Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Xiamen Hongsheng Hardware -Spring Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Yiwu Bobo Toys Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Yiwu Guangmao E-Commerce Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Yiwu Pianpian Trading Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Yiwu You Can Imp & Exp Co., Ltd. served on 8/6/2025, answer due 8/27/2025; Yue wen xiu served on 8/6/2025, answer due 8/27/2025; ZONGHE Store served on 8/6/2025, answer due 8/27/2025; Zhang Xiao dian served on 8/6/2025, answer due 8/27/2025; Zhejiang Zhengna Technology Co., Ltd. served on 8/6/2025, answer due 8/27/2025; raychoi served on 8/6/2025, answer due 8/27/2025. Document filed by Just Play, LLC.

Minute Entry for proceedings held before Judge Jed S. Rakoff in his capacity as Part I judge: Show Cause Hearing held on 8/14/2025. The preliminary injunction is granted.

***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. [16] Notice of Voluntary Dismissal was reviewed and referred to Judge Lewis A. Kaplan for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety.

NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, with prejudice and without costs against the defendant(s) Choice VIP Store. Document filed by Just Play, LLC. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers).

TEMPORARY RESTRAINING ORDER; ORDER RESTRAINING DEFENDANTS' MERCHANT STOREFRONTS AND DEFENDANTS' ASSETS WITH THE FINANCIAL INSTITUTIONS; ORDER AUTHORIZING BIFURCATED AND ALTERNATIVE SERVICE; AND ORDER AUTHORIZING EXPEDITED DISCOVERY. (Signed by Judge Jeannette A. Vargas, Sitting in Part 1 on 7/17/2025) ***Previously filed under seal in envelope # 3, and unsealed by docket entry # 4.***

[PROPOSED] 1) TEMPORARY RESTRAINING ORDER; 2) ORDER RESTRAINING DEFENDANTS' MERCHANT STOREFRONTS AND DEFENDANTS' ASSETS WITH THE FINANCIAL INSTITUTIONS; 3) ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; 4) ORDER AUTHORIZING BIFURCATED AND ALTERNATIVE SERVICE; AND 5) ORDER AUTHORIZING EXPEDITED DISCOVERY. Document filed by Just Play, LLC. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.*** (ras) Proposed Order to be reviewed by Clerk's Office staff.

DECLARATION OF MELISSA J. LEVINE AND ACCOMPANYING EXHIBITS IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION FOR: 1) TEMPORARY RESTRAINING ORDER; 2) AN ORDER RESTRAINING MERCHANT STOREFRONTS AND DEFENDANTS' ASSETS WITH THE FINANCIAL INSTITUTIONS; 3) AN ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; 4) ORDER AUTHORIZING BIFURCATED AND ALTERNATIVE SERVICE AND 5) ORDER AUTHORIZING EXPEDITED DISCOVERY. Document filed by Just Play, LLC.

DECLARATION OF STEPHANIE NORTH AND ACCOMPANYING EXHIBITS IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION FOR: 1) TEMPORARY RESTRAINING ORDER; 2) AN ORDER RESTRAINING MERCHANT STOREFRONTS AND DEFENDANTS' ASSETS WITH THE FINANCIAL INSTITUTIONS; 3) AN ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; 4) ORDER AUTHORIZING BIFURCATED AND ALTERNATIVE SERVICE AND 5) ORDER AUTHORIZING EXPEDITED DISCOVERY. Document filed by Just Play, LLC.

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION FOR 1) A TEMPORARY RESTRAINING ORDER; 2) ORDER RESTRAINING DEFENDANTS' MERCHANT STOREFRONTS AND DEFENDANTS' ASSETS WITH THE FINANCIAL INSTITUTIONS; 3) AN ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; 4) ORDER AUTHORIZING BIFURCATED AND ALTERNATIVE SERVICE AND 5) ORDER AUTHORIZING EXPEDITED DISCOVERY. Document filed by Just Play, LLC. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.***

[PROPOSED] ORDER TO EXCEED WORD LIMIT. Document filed by Just Play, LLC. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.*** (ras) Proposed Order to be reviewed by Clerk's Office staff.

MOTION TO EXCEED WORD LIMIT OF PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S EX PARTE APPLICATION FOR A TEMPORARY RESTRAINING ORDER; ORDER RESTRAINING DEFENDANT'S USER ACCOUNTS, MERCHANT STOREFRONT AND DEFENDANT'S ASSETS WITH THE FINANCIAL INSTITUTIONS; AN ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; ORDER AUTHORIZING BIFURCATED AND ALTERNATIVE SERVICE; AND ORDER AUTHORIZING EXPEDITED DISCOVERY. Document filed by Just Play, LLC. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.***

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Just Play, LLC. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.***

AO 120 FORM TRADEMARK - CASE OPENING - SUBMITTED. In compliance with the provisions of 15 U.S.C. 1116, the Director of the U.S. Patent and Trademark Office is hereby advised that a court action has been filed on the following trademark(s) in the U.S. District Court Southern District of New York. Director of the U.S. Patent and Trademark Office electronically notified via Notice of Electronic Filing (NEF). ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.***

CIVIL COVER SHEET filed. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.***

COMPLAINT against Borei Toys, Botou Yongchuang Spring Manufacturing Co., Ltd., Chaoshanliangzai, Choice VIP Store, Dongguan Jiule Bussiness Limited Company, EIDOMAC CAR, FINEWE INDUSTRY CO., LTD. Store, Foshan Nanhai Qili Hardware And Spring Products Factory, Happy beauty beauty, Hunan Raco Enterprises Co., Ltd., Mai Mai Store, NOAS, Ningbo Jiangbei Lisheng Spring Co., Ltd., Novel design, Shanghai Long Nice International Trading Co., Ltd., Shantou Longhu Longheng Toys Factory, Shantou Market Union Co., Ltd., Shenzhen Dakunlun Hardware & Plastic Products Co.,Ltd., Shenzhen Hongyan E- Commerce Co., Ltd., Shenzhen Songkang Technology Co., Ltd., Shenzhen Yuxiang Technology Co., Ltd., Shop1102400224 Store, Shop1102844309 Store, Shop1103202353 Store, Shop1103277074 Store, Shop1103602395 Store, Shop1104162738 Store, Suzhou Best Crafts Co., Ltd., Xiamen Finewe Industry Co., Ltd., Xiamen Hongsheng Hardware -Spring Co., Ltd., Yiwu Bobo Toys Co., Ltd., Yiwu Guangmao E-Commerce Co., Ltd., Yiwu Pianpian Trading Co., Ltd., Yiwu You Can Imp & Exp Co., Ltd., Yue wen xiu, ZONGHE Store, Zhang Xiao dian, Zhejiang Zhengna Technology Co., Ltd., Jiangmen Hengxin Precision Parts Co., Ltd., raychoi. Document filed by Just Play, LLC.

UNSEALING ORDER: WHEREAS the Court orders that this Action be unsealed, and Records Management upload all documents filed to date on the Electronic Case Filing system. (Signed by Judge Jed S. Rakoff on 8/12/2025)

SUMMONS ISSUED as to Borei Toys, Botou Yongchuang Spring Manufacturing Co., Ltd., Chaoshanliangzai, Choice VIP Store, Dongguan Jiule Bussiness Limited Company, EIDOMAC CAR, FINEWE INDUSTRY CO., LTD. Store, Foshan Nanhai Qili Hardware And Spring Products Factory, Happy beauty beauty, Hunan Raco Enterprises Co., Ltd., Jiangmen Hengxin Precision Parts Co., Mai Mai Store, NOAS, Ningbo Jiangbei Lisheng Spring Co., Ltd., Novel design, Shanghai Long Nice International Trading Co., Ltd., Shantou Longhu Longheng Toys Factory, Shantou Market Union Co., Ltd., Shenzhen Dakunlun Hardware & Plastic Products Co.,Ltd., Shenzhen Hongyan E- Commerce Co., Ltd., Shenzhen Songkang Technology Co., Ltd., Shenzhen Yuxiang Technology Co., Ltd., Shop1102400224 Store, Shop1102844309 Store, Shop1103202353 Store, Shop1103277074 Store, Shop1103602395 Store, Shop1104162738 Store, Suzhou Best Crafts Co., Ltd., Xiamen Finewe Industry Co., Ltd., Xiamen Hongsheng Hardware -Spring Co., Ltd., Yiwu Bobo Toys Co., Ltd., Yiwu Guangmao E-Commerce Co., Ltd., Yiwu Pianpian Trading Co., Ltd., Yiwu You Can Imp & Exp Co., Ltd., Yue wen xiu, ZONGHE Store, Zhang Xiao dian, Zhejiang Zhengna Technology Co., Ltd., raychoi. ***Previously filed under seal in envelope # 2, and unsealed by docket entry # 4.***