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`Case 3:25-cv-07322-JSC Document 20
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`Mingbo Ye (Texas Bar No. 24124835)
`Admitted Pro hac vice
`mye@myiptrustlaw.com
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`MY IP & TRUST LAW
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`12603 Southwest Fwy Suite 210
`Stafford TX 77479
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`Tel: 832-462-0087
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`Hongchang Deng (Cal. Bar No. 354529)
`rdeng@lawmayus.com
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`2108 N St., Ste.9124
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`Sacramento, CA 95816
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`M: 213-682-7241
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`Attorneys for Plaintiffs
`Wondershare Technology Group Co., Ltd.
`Wondershare Technology (Hunan) Co., Ltd.
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`Filed 09/18/25 Page 1 of 3
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`WONDERSHARE TECHNOLOGY
`GROUP CO., LTD.,
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`AND WONDERSHARE TECHNOLOGY
`(HUNAN) CO., LTD.
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`Plaintiffs,
`V.
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`SUPERACE SOFTWARE TECHNOLOGY
`CO., LTD., AND HONGKONG
`SUPERACE SOFTWARE TECHNOLOGY
`CO., LIMITED,
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`Defendants.
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`Case No. 3:25-cv-07322-JSC
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`DECLARATION OF MINGBO YE IN
`SUPPORT OF PLAINTIFFS’ RENEWED
`MOTION FOR ALTERNATIVE SERVICE
`OF PROCESS
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`DECLARATION OF MINGBO YE IN SUPPORT OF PLAINTIFFS’
`RENEWED MOTION FOR ALTERNATIVE SERVICE OF PROCESS
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`3:25-cv-07322-JSC
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`-1-
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`Case 3:25-cv-07322-JSC Document 20 Filed 09/18/25 Page 2 of 3
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`I, Mingbo Ye, declare as follows:
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`1.
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`I am an attorney duly licensed and admitted to practice law in Texas (Bar No. 24124835)
`and admitted pro hac vice in this matter. [ am counsel of record for Plaintiffs Wondershare
`Technology Group Co., Ltd. and Wondershare Technology (Hunan) Co., Ltd. (“Plaintiffs”
`or “Wondershare”). I make this declaration based on my personal knowledge and my role
`as Plaintiffs’ counsel. If called as a witness, I could and would testify competently to the
`facts stated herein.
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`Plaintiffs develop and distribute digital software products worldwide, including the
`flagship PDF editor PDFelement. Defendants Superace Software Technology Co., Ltd.
`(“China Superace”) and Hongkong Superace Software Technology Co., Limited (“Hong
`Kong Superace”) market and sell a competing PDF editor, UPDF, through their website
`and through app platforms such as the Apple App Store and Google Play, where they target
`U.S. consumers. To promote UPDF, Defendants have engaged in a campaign of false and
`misleading comparative advertising targeting Wondershare’s PDFelement, misleading
`consumers at the point of purchase, unlawfully diverting sales, and causing ongoing harm
`to Wondershare’s reputation and goodwill.
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`On September 1, 2025, I sent a demand letter to Defendants via the business email address
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`of their Global Marketing Director, Taylor Pang, at marketing@superace.com. On
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`September 4, 2025, Defendants responded to my letter through the same email address. A
`true and correct copy of the correspondences is attached hereto as Exhibit A.
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`This email exchange confirms that the address marketing@superace.com is active,
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`monitored, and used by Defendants in the ordinary course of business. Defendants have
`used this channel to receive and respond to Plaintiffs’ communications regarding the
`subject matter of this dispute. See Exhibit A.
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`To my knowledge, China Superace conducts its commercial activities primarily online and
`does not maintain any office or agent for service of process in the United States. Its
`operations include marketing, selling, and delivering software products to U.S. consumers
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`through electronic platforms and communications.
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`DECLARATION OF MINGBO YE IN SUPPORT OF PLAINTIFFS’
`RENEWED MOTION FOR ALTERNATIVE SERVICE OF PROCESS
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`3:25-cv-07322-JSC -2-
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`Case 3:25-cv-07322-JSC Document 20 Filed 09/18/25 Page 3 of 3
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Date: September 18, 2025 Signed by: %W/
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`DECLARATION OF MINGBO YE IN SUPPORT OF PLAINTIFFS’
`RENEWED MOTION FOR ALTERNATIVE SERVICE OF PROCESS
`3:25-cv-07322-JSC -3-
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