`
`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`Before The Honorable MaryJoan McNamara
`Administrative Law Judge
`
`In the Matter of
`
`
`CERTAIN PERCUSSIVE MASSAGE DEVICES
`
`
`
`Investigation No. 337-TA-1206
`
`
`
`
`YONGKANG AIJIU INDUSTRIAL & TRADE CO., LTD.’S MOTION TO INTERVENE
`AS A RESPONDENT
`
`
`Pursuant to the United States International Trade Commission’s Rule 210.19, Yongkang
`
`Aijiu Industrial & Trade Co., Ltd. (“Aijiu”) respectfully moves to intervene as a Respondent in the
`
`above-captioned investigation in order to protect its rights with respect to its percussive massage
`
`devices. As set forth in the accompanying memorandum, certain of Aijiu’s percussive massage
`
`devices are potentially subject to exclusion in the event the Commission enters a general exclusion
`
`order as requested by Complainant Hyper Ice, Inc. (“Hyper Ice”), and Aijiu’s interests are not
`
`adequately represented by any of the current respondents participating in this Investigation.
`
`Aijiu has conferred with Hyper Ice, the Office of Unfair Import Investigations (“Staff”),
`
`and Respondents who have made an appearance in this Investigation. Hyper Ice has advised that
`
`it does not oppose the intervention by Aijiu. Respondents Rechar, Inc., Ning Chen, Opove, Ltd.,
`
`Shenzhen Shufang E-Commerce Co., Ltd., Shenzhen Fusi Technology Co., Ltd., and Performance
`
`Health Systems, LLC do not oppose the instant motion. The Staff has stated that they will take a
`
`position upon filing of the motion.
`
`
`
`
`
`

`

`
`Dated: September 17, 2020
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`DENTONS US LLC
`
`/s/ Mark L. Hogge
`Mark L. Hogge
`Nicholas H. Jackson
`Orrin J. Neitzke
`Washington, D.C. 20006
`Telephone: (202) 496-7500
`Facsimile: (202) 496-7756
`
`Qianwu Yang
`DENTONS CHINA
`3F&4F, Block A, Shenzhen International
`Innovation Center
`No. 1006, Shennan Boulevard,
`Futian District
`Shenzhen 518026
`China
`Telephone: +86 139 2521 2009
`
`Counsel for Proposed Intervenor-Respondent
`Yongkang Aijiu Industrial & Trade Co., Ltd.
`
`2
`
`

`

`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`Before The Honorable MaryJoan McNamara
`Administrative Law Judge
`
`In the Matter of
`
`
`CERTAIN PERCUSSIVE MASSAGE DEVICES
`
`
`
`Investigation No. 337-TA-1206
`
`
`
`YONGKANG AIJIU INDUSTRIAL & TRADE CO., LTD.’S MEMORANDUM OF LAW
`IN SUPPORT OF ITS MOTION TO INTERVENE AS A RESPONDENT
`
`
`
`

`

`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION .............................................................................................................. 2
`
`STATEMENT OF FACTS ................................................................................................. 2
`
`III.
`
`LEGAL STANDARD ......................................................................................................... 3
`
`IV.
`
`ARGUMENT ...................................................................................................................... 4
`
`V.
`
`CONCLUSION ................................................................................................................. 11
`
`
`
`
`
`
`
`ii
`
`

`

`TABLE OF AUTHORITIES
`
`
`
`Page(s)
`
`Cases
`
`Certain Electronic Devices, Including Mobile Phones and Tablet Computers, and
`Components Thereof,
`Inv. No. 337-TA-847, Order No. 3 (August 3, 2012) ................................................................4
`
`Certain Electronic Devices With Image Processing Systems, Components Thereof,
`and Associated Software,
`Inv. No. 337-TA-724, Comm. Op’n (Dec. 21, 2011) ............................................................3, 4
`
`Certain Foam Footwear,
`Inv. No. 337-TA-567, Order No. 25 (Oct. 10, 2006) .................................................................6
`
`Certain Network Interface Cards and Access Points for Use in Direct Sequence
`Spread Spectrum Wireless Local Area Networks and Products Containing
`Same,
`Inv. No. 337-TA-455, Comm. Op’n (July 17, 2001) .............................................................4, 6
`
`Certain Sucralose, Sweeteners Containing Sucralose, And Related Intermediate
`Compounds Thereof,
`Inv. No. 337-TA-604 (“Sucralose”), Order No. 7 (July 25, 2007) ........................................5, 6
`
`Other Authorities
`
`19 C.F.R. §210.19 ................................................................................................................1, 2, 3, 4
`
`85 Fed. Reg. 44322-24 (July 22, 2020) ...........................................................................................3
`
`Federal Rule of Civil Procedure 24 .................................................................................................3
`
`
`
`
`
`ii
`
`

`

`I.
`
`INTRODUCTION
`
`Pursuant to Commission Rule 210.19, Yongkang Aijiu Industrial & Trade Co., Ltd.
`
`(“Aijiu”) respectfully moves to intervene as a Respondent in the above-captioned investigation in
`
`order to protect its rights with respect to its percussive massage devices. Intervention is necessary
`
`in this Investigation because Hyper Ice is requesting the imposition of a general exclusion order,
`
`which if issued, would exclude all percussive massage devices that Customs and Border Protection
`
`(“CBP”) believes infringe one or more of the patent claims asserted by Hyper Ice in this
`
`investigation. None of the current Respondents participating in this Investigation have any interest
`
`in proving that Aijiu’s products do not infringe any of patent claims asserted by Hyper Ice or
`
`should not be excluded from any general exclusion order, if issued. Accordingly, only Aijiu can
`
`present evidence and arguments that would protect its percussive massage devices from the scope
`
`of the general exclusion order sought by Hyper Ice.
`
`II.
`
`STATEMENT OF FACTS
`
`On June 16, 2020, Hyper Ice filed a complaint at the ITC naming nineteen proposed
`
`respondents. In its complaint, Hyper Ice alleged that the proposed respondents imported into the
`
`United States, sold for importation, and/or sold within the United States after importation
`
`percussive massage devices that infringe one or more claims 1-9, 14, 15 of Hyper Ice’s U.S. Patent
`
`No. 10,561,574 (“the ’574 Patent”) and/or its U.S. Patent Nos. D855,822 and D886,317 “the
`
`Asserted Patents”). Complaint at ¶ 2 (June 16, 2020). In its complaint, Hyper Ice sought a general
`
`exclusion order forbidding entry into the United States of any percussive massage device that
`
`infringes the ’574 or ’822 patents, regardless of source. Id. at ¶ 3. On July 22, 2020, the
`
`Commission published its notice of institution of the investigation to determine whether a violation
`
`
`
`2
`
`

`

`
`
`of Section 337 had occurred as alleged by Hyper Ice in its complaint. 85 Fed. Reg. 44322-24 (July
`
`22, 2020).
`
`The complaint specifically names several manufacturers and importers of percussive
`
`massage devices and accuses them violating Section 337 on the basis of infringing Hyper Ice’s
`
`patents. The requested remedy sought by Hyper Ice is not limited to the named respondents
`
`however, rather Hyper Ice has requested a general exclusion order that attempts to exclude all
`
`products found to infringe the Asserted Patents, regardless of whether they are manufactured or
`
`imported by or on behalf of a Respondent in this Investigation. The complaint failed to name Aijiu
`
`as a respondent in this Investigation and none of the currently named Respondents have a
`
`cognizable interest in defending Aijiu’s interests. Therefore, if Aijiu is not allowed to intervene,
`
`its percussive massage devices are at risk of being excluded under a general exclusion order
`
`without any evidence or argument presented.
`
`III. LEGAL STANDARD
`
`Intervention is dictated by 19 C.F.R. §210.19, which provides that “[a]ny person desiring
`
`to intervene in an investigation . . . shall make a written motion after institution” and “the
`
`administrative Law Judge by initial determination, may grant the motion to the extent and upon
`
`such terms as may be proper under the circumstances.” 19 C.F.R. §210.19. In deciding a motion
`
`to intervene, the Commission will look to Federal Rule of Civil Procedure 24 for guidance in
`
`determining whether intervention in a particular matter is appropriate. Certain Electronic Devices
`
`With Image Processing Systems, Components Thereof, and Associated Software, Inv. No. 337-TA-
`
`724, Comm. Op’n at 57 (Dec. 21, 2011). “Based on the factors set forth in the Federal Rule, the
`
`Commission has found a motion to intervene ‘most persuasive’ where (1) the motion is timely; (2)
`
`the movant has an interest relating to the property or transaction which is the subject of the action;
`
`3
`
`

`

`
`
`(3) the movant is so situated that the disposition of the action may as a practical matter impair or
`
`impede its ability to protect that interest; (4) the movant is not adequately represented by the
`
`existing parties; and (5) the intervention will not unduly delay or prejudice the adjudication of the
`
`original parties’ rights. Id. The touchstone for deciding whether an intervenor should be accorded
`
`status as a respondent is whether the complaint seeks to “directly exclude” the intervenor's
`
`products. Certain Network Interface Cards and Access Points for Use in Direct Sequence Spread
`
`Spectrum Wireless Local Area Networks and Products Containing Same, Inv. No. 337-TA-455,
`
`Comm. Op'n at 10 (July 17, 2001)). In order to be granted the status of a respondent, “the moving
`
`party must produce relevant evidence sufficient to show that articles supplied by the moving party
`
`could, in fact, be found in violation of section 337 and could therefore be excluded from entry into
`
`the United States if the remedy sought by the complaints were granted.” Id.
`
`IV. ARGUMENT
`
`Aijiu satisfies the standard for intervention as set forth in Commission Rule 210.19 and
`
`Electronic Devices and should be granted full Respondent status.
`
`First, Aijiu’s motion is timely. Timeliness is determined from all of the circumstances.
`
`Electronic Devices, Inv. No. 337-TA-724, Comm. Op’n at 58 (finding commonly considered
`
`factors included how far the litigation had progressed; the length of time during which the
`
`prospective intervenor knew or reasonably should have known of its rights; the risk of prejudice
`
`to the existing parties or proposed intervenor; and the existence of other unusual circumstances
`
`militating either for or against a determination that the motion is timely); see also Certain
`
`Electronic Devices, Including Mobile Phones and Tablet Computers, and Components Thereof,
`
`Inv. No. 337-TA-847, Order No. 3 at 3 (August 3, 2012) (granting motion to intervene finding,
`
`inter alia, the motion to be timely when filed approximately five weeks after the investigation was
`
`4
`
`

`

`
`
`instituted because investigation was “still in its infancy…”). This Investigation was instituted on
`
`July 22, 2020, approximately eight weeks ago. Moreover, discovery is in its very early stages. The
`
`deadline for responding to contention interrogatories is not until October 23, 2020 and the deadline
`
`for substantial completion of document production is October 16. There is more than an adequate
`
`amount of time for Hyper Ice to receive discovery from Aijiu. Accordingly, Aijiu intervening will
`
`not delay the resolution of this Investigation and thus will not prejudice Hyper Ice or any other
`
`party to this Investigation. Aijiu agrees to adopt and meet these deadlines, and also agrees that no
`
`modification of the ALJ’s scheduling order is necessitated based on Aijiu’s intervention.
`
`Second, Aijiu has an interest relating to the percussive massage devices that are the subject
`
`of the Investigation. Aijiu manufactures percussive massage devices, including the Legiral,
`
`Bobbito, Miudaml, Tiction, Xgody, and Hethtec percussion massagers, which are available for
`
`sale on Amazon1 and have been imported into the United States. Aijiu therefor has an interest in
`
`
`
`1 The products are available at the following links:
`- Legiral (https://www.amazon.com/stores/Legiral/page/1DEAB205-3CA6-4265-9783-
`B3F0BA38F7DD?ref_=ast_bln)
`- Bobbito (https://www.amazon.com/Percussion-Electric-Massagers-Portable-
`Brushless/dp/B088D2NMTQ/ref=sr_1_4?dchild=1&keywords=bobbito&qid=1598717199&sr=8-4)
`- Miudaml (https://www.amazon.com/Athletes-Percussion-Massager-Handheld-
`Soreness/dp/B085PSD21W/ref=asc_df_B085PSD21W/?tag=hyprod-
`20&linkCode=df0&hvadid=459565948985&hvpos=&hvnetw=g&hvrand=612382360764975890&hvpone=&hvpt
`wo=&hvqmt=&hvdev=c&hvdvcmdl=&hvlocint=&hvlocphy=9008165&hvtargid=pla-972632396364&psc=1)
`- Tiction (https://www.amazon.com/Tiction-Professional-Massager-Percussion-Sports-Enthusiasts-
`Relaxation/dp/B088KCN6NG/ref=mp_s_a_1_19_sspa?dchild=1&keywords=muscle+massager&qid=1598403486
`&sprefix=muscl&sr=8-19-
`spons&psc=1&spLa=ZW5jcnlwdGVkUXVhbGlmaWVyPUEyUzE4SVFJWTJRWEZDJmVuY3J5cHRlZElkPU
`EwMjYzMDYxMVBUOEhROVVRMkNUNiZlbmNyeXB0ZWRBZElkPUEwNDg1NTc5MVFPTzhHSjlUTDJL
`TiZ3aWRnZXROYW1lPXNwX3Bob25lX3NlYXJjaF9tdGYmYWN0aW9uPWNsaWNrUmVkaXJlY3QmZG9O
`b3RMb2dDbGljaz10cnVl)
`- Xgody (https://www.amazon.com/Percussion-Massager-Brushless-Handheld-
`Electric/dp/B088MCB4W5/ref=mp_s_a_1_225_sspa?dchild=1&keywords=massage+gun&qid=1598403148&sr=
`8-225-
`spons&psc=1&spLa=ZW5jcnlwdGVkUXVhbGlmaWVyPUExTElJNDdSSTlWNDg2JmVuY3J5cHRlZElkPUEw
`MzU0ODkyMjlJWEZNS05MVjFaRSZlbmNyeXB0ZWRBZElkPUEwNzU3MjM2QkxSQ05DSlQ0VlZaJndpZG
`dldE5hbWU9c3BfcGhvbmVfc2VhcmNoX2J0ZiZhY3Rpb249Y2xpY2tSZWRpcmVjdCZkb05vdExvZ0NsaWNr
`PXRydWU=)
`- Hethtec (https://www.amazon.com/Hethtec-Massage-Handheld-Massager-
`Carrying/dp/B085PS5PD8/ref=sr_1_74?dchild=1&keywords=massage+gun&qid=1598406236&s=hpc&sr=1-74)
`
`5
`
`

`

`
`
`intervening in this investigation to present arguments and evidence that its percussive massage
`
`devices do not infringe any of the asserted claims of Hyper Ice’s Asserted Patents and should not
`
`be subject to any general exclusion order. Images of these products have been reproduced below:
`
`Legiral
`
`Bobbito
`
`
`
`
`
`6
`
`

`

`
`
`
`Miudaml
`
`Tiction
`
`
`
`
`
`
`
`7
`
`

`

`Xgody
`
`
`
`Hethtec
`
`
`
`
`
`Third, the disposition of this Investigation will, as a practical matter, impair or impede
`
`Aijiu’s ability to protect its interests in its percussive massage devices. In its complaint Hyper Ice
`
`requested a general exclusion order “barring from entry into the United States all percussive
`
`massage devices that infringe the ’574 Patent, the ’822 Patent, and/or the ’317 Patent.” Complaint
`
`8
`
`

`

`
`
`at ¶ 3. If a violation of Section 337 is found and the Commission issues a general exclusion order,
`
`CBP will examine all importations in to the United States of percussive massage devices for
`
`whether they infringe Hyper Ice’s Asserted Patents. If Aijiu is not allowed to intervene, CBP will
`
`undertake this effort without the benefit of an evidentiary record of Aijiu’s products. If CBP
`
`erroneously believes that Aijiu’s products infringe the Asserted Patents, it may improperly bar
`
`Aijiu’s products from entry. While Aijiu is confident that its products do not infringe the Asserted
`
`Patents, and would present evidence and arguments to show the contrary if CBP made such a
`
`determination, such an improper exclusion would unfairly cost Aijiu time, money, and would
`
`generally disrupt Aijiu’s business. It is therefore necessary for Aijiu to intervene to protect its
`
`interests in importing its products into the United States. See Certain Sucralose, Sweeteners
`
`Containing Sucralose, And Related Intermediate Compounds Thereof, Inv. No. 337-TA-604
`
`(“Sucralose”), Order No. 7 at 5 (July 25, 2007) (movant’s ability to protect its interest would be
`
`impaired “because [complainants] have requested that the Commission issue a general exclusion
`
`order, which would directly affect [movant’s] sale of sucralose.”).
`
`As described above, Aijiu manufactures percussive massage devices, the very subject of
`
`this Investigation. The touchstone for deciding whether an intervenor should be accorded status as
`
`a respondent is whether the complaint seeks to “directly exclude” the intervenor’s products.
`
`Network Interface Cards, Inv. No. 337-TA-455, Comm. Op’n at 10. Hyper Ice’s requested general
`
`exclusion order seeks to bar “all percussive massage devices” that infringe the Asserted Patents
`
`regardless of whether a party to this Investigation or not. As a manufacturer of the very products
`
`Hyper Ice accuses of infringement, Aijiu’s products are directly excludable should a general
`
`9
`
`

`

`
`
`exclusion order eventually issue.2 Accordingly, Aijiu should be granted respondent status in this
`
`Investigation. Sucralose, Inv. 337-TA-604, Order No. 7 at 2 (granting motion to intervene as a
`
`respondent, stating: “[i]t is clear that JK has an interest relating to the subject of this investigation-
`
`-sucralose--. . . [t]his is because Tate & Lyle have requested that the Commission issue a general
`
`exclusion order, which could directly affect JK’s sale of sucralose.”).
`
`Fourth, no Respondents currently participating in this Investigation have any cognizable
`
`interest in presenting evidence that Aijiu’s products do not infringe the Asserted Patents and should
`
`not be subject to any remedial orders that might issue. Rather, the Respondents in this Investigation
`
`have an interest in presenting evidence and arguments rebutting Hyper Ice’s assertions that their
`
`own products infringe the Asserted Patents. Aijiu should be allowed to intervene to present
`
`evidence in order to protect its products from exclusion. See Certain Foam Footwear, Inv. No.
`
`337-TA-567, Order No. 25 at 2 (Oct. 10, 2006) (“Old Dominion’s interests are not adequately
`
`represented by any of the named parties, as none of the named parties manufacture, distribute, or
`
`have any information regarding the Aqua Ducks shoe products.”)
`
`Finally, Aijiu’s intervention will not cause any unduly delay in this Investigation and will
`
`not prejudice the rights of any of the existing parties. As described above, this Investigation is in
`
`its infancy, having been instituted approximately eight weeks ago on July 22, 2020. Furthermore,
`
`the parties have just began discovery and the existing parties will have ample time to get discovery
`
`from Aijiu and formulate their contentions as they relate to Aijiu’s products. Hyper Ice originally
`
`
`
`2 Aijiu’s circumstances are inapposite to circumstances in which the Commission has denied motions to intervene as
`a respondent. For example, the Commission has denied motions to intervene as a respondent when the proposed
`intervenor manufactured and imported components that were used in the products that were the subject of the
`requested exclusion order. See Network Interface Cards, Inv. No. 337-TA-455 at 11 (“Intersil has produced no
`evidence that its chips themselves are properly within the scope of this investigation and that the remedies sought
`by Proxim, if granted, would exclude Intersil chips themselves from entry.”).
`
`10
`
`

`

`
`
`named nineteen proposed respondents in this Investigation; Aijiu’s participation will not add any
`
`material burden to Complainant Hyper Ice. To further avoid any prejudice to the Complainant,
`
`Aijiu agrees to respond to the Complaint and Notice of Investigation within 5 business days of the
`
`motion being granted and agrees to respond to the equivalent discovery responses served to the
`
`other participating respondents within 10 calendar days of the motion being granted along with the
`
`corresponding document production. Aijiu agrees to join the appearing respondents in all common
`
`deadlines that have already passed or will have already passed by the date this motion is granted
`
`(e.g. claim construction terms, notice of prior art, etc.). Finally, Aijiu agrees that it will not request
`
`a target date extension or other deadline modification purely based upon the intervention.
`
`V.
`
`CONCLUSION
`
`For the foregoing reasons, Aijiu respectfully requests that its motion to intervene be
`
`granted, and that it be allowed to intervene as a full respondent in this Investigation.
`
`Dated: September 17, 2020
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`DENTONS US LLC
`
`/s/ Mark L. Hogge
`Mark L. Hogge
`Nicholas H. Jackson
`Orrin J. Neitzke
`Washington, D.C. 20006
`Telephone: (202) 496-7500
`Facsimile: (202) 496-7756
`
`Qianwu Yang
`DENTONS CHINA
`3F&4F, Block A, Shenzhen International
`Innovation Center
`No. 1006, Shennan Boulevard,
`
`11
`
`

`

`
`
`Futian District
`Shenzhen 518026
`China
`Telephone: +86 139 2521 2009
`
`Counsel for Proposed-Intervenor Respondent
`Yongkang Aijiu Industrial & Trade Co., Ltd.
`
`12
`
`

`

`
`
`Certain Percussive Massage Devices
`
`Inv. No. 337-TA-1206
`
`CERTIFICATE OF SERVICE
`
`I, Nicholas H. Jackson, hereby certify that on September 17, 2020, copies of YONGKANG
`
`AIJIU INDUSTRIAL & TRADE CO., LTD.’S MOTION TO INTERVENE AS A
`RESPONDENT was served upon the following parties as indicated:
`
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via EDIS
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email (McNamara337@usitc.gov and
`jae.lee@usitc.gov)
`
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email (Monisha.Deka@usitc.gov)
`
`
`
`
`
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
`The Honorable Lisa Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, SW
`Room 112
`Washington, DC 20436
`
`Honorable MaryJoan McNamara
`Chief Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`
`Monisha Deka
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`On Behalf of Complainant Hyper Ice, Inc.:
`
`Brian G. Arnold
`Jonathan Pink
`LEWIS BRISBOIS BISGAARD & SMITH
`LLP
`633 West 5th Street, Suite 4000
`Los Angeles, CA 90071
`E-Mail: Brian.Arnold@lewisbrisbois.com
`Jonathan.Pink@lewisbrisbois.com
`
`Paul M. Bartkowski
`ADDUCI, MASTRIANI & SCHAUMBERG,
`LLP
`1133 Connecticut Avenue, NW, 12th Floor
`Washington, DC 20036
`E-Mail: Hyperice-001@adduci.com
`
`
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
`
`WODFitters
`6281 Corder Lane
`Lorton, VA 22079
`
`Massimo Motor Sports, LLC
`3101 W Miller Road
`Garland, TX 75041
`
`Kinghood International Logistics Inc.
`16851 Knott Avenue
`La Mirada, CA 90638
`
`Manybo Ecommerce Ltd.
`Unit 622, Kwai Shun Ind. Centre
`51-63 Container Port Road
`Kwai Chung, N.T., Hong Kong
`China
`
`
`Shenzhen Let Us Win-Win Technology Co.,
`Ltd.
`4F, No.229, Busha Road
`Buji, Shenzhen
`Guangdong Province
`China
`
`Shenzhen Infein Technology Co., Ltd.
`12-1, 1st Factory Building, Tian’an Digital
`Innovation Park
`No. 441, Huangge Road, Longcheng Street,
`Longgang District,
`Shenzhen, Guangdong, 518000
`China
`
`Hong Kong Yongxu Capital Management
`Co., Ltd.
`
`
`
`

`

`
`
` Via Facsimile
` Via FedEx
` Via Email
`
`
`
`
`
`
`
`
`
`
`
`
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
` Via First Class mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via FedEx
` Via Email
`
`Flat/Rm 1804, Beverly House, 93-107
`Lockhart Road,
`Wanchai, Hong Kong, 999077
`China
`
`Laiwushiyu Xinuan Trading Company
`Chendaxia Village, Laiwu
`Shandong District, 271100
`China
`
`Shenzhen QingYueTang E-commerce Co.,
`Ltd.
`Rm.1001, 10th Floor, Zhongken Building
`No.2002 Bixin Road, Longgang District,
`Shenzhen
`Guangdong, 518000
`China
`
`Shenzhen Shiluo Trading Co., Ltd.
`37 East 305 Minli Old Village, Minzhi Street,
`Longhua New District, Shenzhen
`Guangdong, 518000
`China
`
`
`Kula eCommerce Co., Ltd.
`No. 50, Danshui Baiyun Yi Road, Huiyang
`District,
`Huizhou City
`Guangdong, 516211
`China
`
`Shenzhen Qifeng Technology Co., Ltd.
`1019, Weidonglong Technology Building,
`Meilong Boulevard,
`Longhua Sub-District, Longhua Ne W District
`Shenzhen, Guangdong, 518015
`China
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`

`

`/s/ Nicholas H. Jackson
`Dentons US LLP
`1900 K Street, N.W.
`Washington, DC 20006
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