throbber
UNITED STATES INTERNATIONAL TRADE COMMISSION
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`Washington, D.C.
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`
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`
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` Inv. No. 337-TA-1410
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`
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`In the Matter of
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`CERTAIN DISPOSABLE VAPORIZER
`DEVICES
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`
`ORDER NO. 11:
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`
`
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`GRANTING COMPLAINANTS’ MOTION FOR AN ORDER TO
`SHOW CAUSE WHY CERTAIN RESPONDENTS SHOULD NOT
`BE FOUND IN DEFAULT
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`(September 3, 2024)
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`On August 15, 2024, Complainants RAI Strategic Holdings, Inc. (“RAI”), R.J. Reynolds
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`Vapor Company (“RJRV”), R.J. Reynolds Tobacco Company (“RJRT”), and RAI Services
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`Company (“RAISC”) (collectively, “Reynolds” or “Complainants”) filed a motion (“Mot.”) and
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`memorandum in support thereof (“Mem.”) for an order to show cause why Respondents
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`Vapeonly Technology Co. Ltd.; iMiracle (Shenzhen) Technology; Nevera (HK) Ltd.; Wonder
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`Ladies Ltd.; Sailing South Ltd.; Marea Morada Ltd.; Social Brands, LLC; Palma Terra Ltd.;
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`Heaven Gifts International Ltd.; Shenzhen LC Technology Co., Ltd.; LCF Labs, Inc.; Flumgio
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`Technology Ltd.; Flawless Vape Shop Inc.; Flawless Vape Wholesale & Distribution Inc.; and
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`VICA Trading Inc. d/b/a Vapesourcing (collectively, “Defaulting Respondents”) should not be
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`found in default for failing to respond to the complaint and notice of investigation (“NOI”). Mot.
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`Dkt. No. 1410-002. In the event that the Defaulting Respondents do not make the requisite
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`showing, Complainants seek an initial determination finding the Defaulting Respondents in
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`default. Mot. at 2. On August 26, 2024, the Commission Investigative Staff (“Staff”) filed a
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`response supporting the motion (“Staff Resp.”; EDIS Doc. ID 830510). The Motion states that
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`the appearing Respondents take no position on the Motion. Mot. at 1. No other responses were
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`received.
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`Commission Rule 210.16(a)(1) states that “[a] party shall be found in default if it fails to
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`respond to the complaint and notice of investigation in the manner prescribed in § 210.13 or
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`§ 210.59(c), or otherwise fails to answer the complaint and notice, and fails to show cause why it
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`should not be found in default.” 19 C.F.R. § 210.16(a)(1). When a respondent fails to respond or
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`appear, “a party may file a motion for . . . an order directing [that] respondent to show cause why
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`it should not be found in default. If the respondent fails to make the necessary showing . . . , the
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`administrative law judge shall issue an initial determination finding the respondent in default.”
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`19 C.F.R. § 210.16(b)(1). A party found in default is deemed to have waived its right to appear,
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`to be served with documents, and to contest the allegations at issue in the investigation. 19
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`C.F.R. § 210.16(b)(4).
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`On June 11, 2024, Complainants filed a complaint with the Commission, alleging a
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`violation of Section 337 of the Tariff Act of 1930, as amended, based on the alleged importation
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`into the United States, sale for importation, or sale within the United States after importation of
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`certain disposable vaporizer devices that infringe U.S. Patent No. 11,952,202 (“the ’202 patent”)
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`by forty-two proposed respondents, including the Defaulting Respondents. See 88 Fed. Reg.
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`51365-66 (June 17, 2024). On the same day, the Complainants filed a Motion for Temporary
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`Relief under 19 U.S.C. § 1337(e) and (f) and 19 C.F.R. § 210.52. The Commission voted to
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`institute this investigation against thirty-five respondents, including the Defaulting Respondents,
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`on July 17, 2024 and the NOI was published on July 22, 2024. See Fed. Reg. 59158 (July 22,
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`2024).
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`2
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`I.
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`FINDINGS
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`Of the fifteen Defaulting Respondents, five are domestic entities and ten are located
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`outside of the United States. Between July 19, 2024 and July 22, 2024 Complainants served each
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`of the Defaulting Respondents by overnight delivery with a service package containing, among
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`other things, the public Complaint, the NOI, and the Motion for Temporary Relief, Mot. at 2-3,
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`as detailed below. In Order No. 7, the undersigned set August 12, 20241 as the deadline for
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`respondents to respond to the Complaint, Notice of Investigation, and Complainants’ Motion for
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`Temporary Relief. See Order No. 7 (July 31, 2024). Each of the Defaulting Respondents’
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`responses would have been due on August 12, 2024.
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`Vapeonly Technology Co. Ltd. Vapeonly Technology Co. Ltd. (“Vapeonly”) is a foreign
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`entity with a principal place of business in Hong Kong, China.2 Mem. at 4. The service package
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`for Vapeonly was shipped on July 18, 2024 and delivered on July 22, 2024. EDIS Doc. ID
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`827527, Proof of Service Ex. 3 at 1, 4.
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`Vapeonly also—through counsel—appears as a signee on Request to Deny Provisional
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`Acceptance of Complainants’ Motion for Temporary Relief (EDIS Doc. ID 824391), which was
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`filed on June 25, 2024, prior to institution of the investigation.
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`1 19 C.F.R. § 210.13(a) permits the administrative law judge to order a response deadline different than
`the default twenty-day response period. (“Except as provided in § 210.59(a) and unless otherwise ordered
`in the notice of investigation or by the administrative law judge, respondents shall have 20 days from the
`date of service of the complaint and notice of investigation, by the Commission under § 210.11(a) or by a
`party under § 210.11(b), within which to file a written response to the complaint and the notice of
`investigation.”).
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` Vapeonly Technology Co. Ltd. admitted that its principal place of business is located at 19H Maxgrand
`Plaza, No. 3 Tai Yau Street, San Po Kong, Kowloon, Hong Kong in its response to the complaint in a co-
`pending investigation. See Certain Disposable Vaporizer Devices, Inv. No. 337-TA-1381, EDIS Doc. ID
`No. 812394, Response to the Verified Complaint at ¶ 51 (Jan. 22, 2024).
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` 2
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`3
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`Nevera (HK) Ltd. Nevera (HK) Ltd. (“Nevera”) is a foreign entity with a principal place
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`of business in Hong Kong, China.3 Mem. at 5; Compl. at ¶ 21. The service package for Nevera
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`was shipped on July 18, 2024 and delivered on July 22, 2024. EDIS Doc. ID 827527, Proof of
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`Service Ex. 7 at 1, 4.
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`Wonder Ladies Ltd. Wonder Ladies Ltd. (“Wonder Ladies”) is a foreign entity with a
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`principal place of business in Tortola, British Virgin Islands.4 Mem. at 5; Compl. at ¶ 23. The
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`service package for Wonder Ladies was shipped on July 18, 2024 and delivered on July 22,
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`2024. EDIS Doc. ID 827527, Proof of Service Ex. 9 at 1, 4.
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`Sailing South Ltd. Sailing South Ltd. (“Sailing South”) is a foreign entity with a
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`principal place of business in Tortola, British Virgin Islands.5 Mem. at 6; Compl. at ¶ 24. The
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`service package for Sailing South was shipped on July 18, 2024 and delivered on July 22, 2024.
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`EDIS Doc. ID 827527, Proof of Service Ex. 10 at 1, 4.
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`Marea Morada Ltd. Marea Morada Ltd. (“Marea Morada”) is a foreign entity with a
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`principal place of business in Tortola, British Virgin Islands.6 Mem. at 6; Compl. at ¶ 25. The
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`service package for Marea Morada was shipped on July 18, 2024 and delivered on July 22, 2024.
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`EDIS Doc. ID 827527, Proof of Service Ex. 11 at 1, 4.
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`3 Nevera was served at the address that appears on its product boxes, 19H, Maxgrand Plaza, No. 3 Tai
`Yau Street, San Po Kong, Kowloon, Hong Kong. Mem. at 5; Compl. at ¶ 21.
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` 4
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` Wonder Ladies was served at the address that appears on its product boxes, Sea Meadow House, P.O.
`Box 116, Road Town, Tortola, British Virgin Islands, VG1110. Mem. at 5; Compl. at ¶ 23.
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` 5
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` Sailing South was served at the address that appears on its product boxes, Sea Meadow House, P.O. Box
`116, Road Town, Tortola, British Virgin Islands, VG1110. Mem. at 5; Compl. at ¶ 23.
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` 6
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` Marea Morada was served at the address that appears on its product boxes, Sea Meadow House, P.O.
`Box 116, Road Town, Tortola, British Virgin Islands, VG1110. Mem. at 5; Compl. at ¶ 23.
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`4
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`Social Brands, LLC. Social Brands, LLC (“Social Brands”) is a domestic entity located
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`in Dallas, TX. Mem. at 6; Compl. ¶ 26.7 The service package for Social Brands was shipped to
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`registered agent Beshoy Saad and delivered on July 22, 2024.8 EDIS Doc. ID 827527, Proof of
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`Service Ex. 12 at 2.
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`Palma Terra Ltd. Palma Terra Ltd. (“Palma Terra”) is a foreign entity with a principal
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`place of business in Tortola, British Virgin Islands.9 Mot. at 6; Compl. at ¶ 29. The service
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`package for Palma Terra was shipped on July 18, 2024 and delivered on July 22, 2024. EDIS
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`Doc. ID 827527, Proof of Service Ex. 16 at 1, 4.
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`Heaven Gifts International Ltd. Heaven Gifts International Ltd. (“Heaven Gifts”) is a
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`foreign entity located in China.10 Mem. at 7; Compl. at ¶ 32. The service package for Heaven
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`Gifts was shipped on July 18, 2024 and delivered on July 22, 2024. EDIS Doc. ID 827527, Proof
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`of Service Ex. 18 at 1, 4.
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`Shenzen LC Technology Co., Ltd. Shenzen LC Technology Co., Ltd. (“Shenzen LC”) is
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`a foreign entity located in Shenzen, China.11 Mem. at 7-8; Compl. at ¶ 48. The service package
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`for Shenzen LC was shipped on July 18, 2024 and delivered on July 22, 2024. EDIS Doc. ID
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`827527, Proof of Service Ex. 26 at 1, 4.
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`7 Social Brands was served at the address listed in Social Brand’s Texas taxable entity registration, which
`has the same zip code as the address listed on its packaging. Mem. at 6; Compl. at ¶ 26.
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` 8
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` The proof of service indicates that the label was created on 7/03/2024, but does not indicate when the
`package was shipped. The proof of delivery, however, indicates that it was successfully delivered on July
`22, 2024. EDIS Doc. ID 827527, Proof of Service Ex. 12 at 2.
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` 9
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` Marea Morada was served at the address that appears on its product boxes, Sea Meadow House, P.O.
`Box 116, Road Town, Tortola, British Virgin Islands, VG1110. Mem. at 5; Compl. at ¶ 23.
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`10 Heaven Gifts was served at the address listed as its “Registered Office” with the Government of Hong
`King Special Administrative Region Companies Registry. See Mem. at 7; Mot. Ex. 2.
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`11 Shenzen LC was served at the address listed as its registered business address with the National
`Enterprise Credit Information Publicity System. See Mem. at 7-8; Mot. Ex. 3.
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`5
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`LCF Labs, Inc. LCF Labs, Inc. (“LCF Labs”) is a domestic entity located in California.
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`Mem. at 8; Compl. ¶ 49. The service package for LCF Labs was served on LCF Labs at 9881 6th
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`St. Suite 206, Rancho Cucamonga, CA 91730-5700, an address associated with LCF Labs, and at
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`6045 Forest Glen Drive, Fontana, CA 92336-1070, which Complainants explain “appears to be
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`the residence of one of LCF’s Labs’ owners, Akbar Razavi.”12 Mot. at 8; Mot. Ex. 5. The service
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`package for LCF Labs to the Rancho Cucamonga, CA address was shipped on July 17, 2024 and
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`delivered on July 19, 2024. EDIS Doc. ID 827527, Proof of Service Ex. 28 at 2. The service
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`package for LCF Labs to the Fontana, CA address was shipped on July 17, 2024 and delivered
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`on July 22, 2024. EDIS Doc. ID 827527, Proof of Service Ex. 29 at 2.
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`Flumgio Technology Ltd. Flumgio Technology Ltd. (“Flumgio”) is a foreign entity
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`located in Hong Kong, China.13 Mot. at 9; Compl. at ¶ 53. The service package for Flumgio was
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`shipped on July 18, 2024 and delivered on July 22, 2024. EDIS Doc. ID 827527, Proof of
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`Service Ex. 31 at 1, 4.
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`12 Commission Rule 201.16 provides that service shall be effected: (1) “[b]y mailing, delivering, or
`serving by electronic means a copy of the document to the person to be served, to a member of the
`partnership to be served, to the president, secretary, other executive officer, or member of the board of
`directors of the corporation, association, or other organization to be served;” (2) “[b]y leaving a copy
`thereof at the principal office of such person, partnership, corporation, association, or other organization;”
`or (3) “[b]y using an express delivery service to send a copy of the document to the principal office of
`such person, partnership, corporation, association, or other organization.” 19 C.F.R. §§ 201.16(a)(1)-(3).
`The undersigned finds that at least the service by mail to Mr. Razavi is effective service. See, e.g., Certain
`Oil-Vpaing Cartridges, Components Thereof, & Prods. Containing the Same, Inv. No. 337-TA-1286,
`Order No. 38, EDIS Doc. ID 776463, at 4-5 (July 28, 2022).
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`13 Flumgio was served at the address that appears on its product boxes, Room 21, Unit A, Tin Wui
`Industrial Building, No. 3 Hing Wong Street, Tuen Mun, N.T., Hong Kong. Mem. at 9; Compl. at ¶ 53.
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`6
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`Flawless Vape Shop Inc. Flawless Vape Shop Inc. (“Flawless Vape Shop”) is a domestic
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`entity located in Anaheim, CA.14 Mot. at 9; Compl. at ¶ 60. The service package for Flawless
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`Vape Shop was delivered on July 19, 2024.15 EDIS Doc. ID 827527, Proof of Service Ex. 35 at
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`2.
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`Flawless Vape Wholesale & Distribution Inc. Flawless Wholesale & Distribution Inc.
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`(“Flawless Wholesale”) is a domestic entity located in Anaheim, CA.16 Mot. at 10; Compl. at ¶
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`61. The service package for Flawless Wholesale was delivered on July 19, 2024.17 EDIS Doc. ID
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`827527, Proof of Service Ex. 36 at 2.
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`VICA Trading Inc. d/b/a Vapesourcing. VICA Trading Inc. d/b/a Vapesourcing
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`(“Vapesourcing”) is a domestic entity located in Tustin, CA.18 Mot. at 10; Compl. at ¶ 63. The
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`service package for Vapesourcing was delivered on July 19, 2024.19 EDIS Doc. ID 827527,
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`Proof of Service Ex. 38 at 2.
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`14 Flawless Vape Shop was served at its registered business address, 5589 E Santa Ana Canyon Rd,
`Anaheim, CA 92807. Mot. at 9; Compl. at ¶ 60.
`15 The proof of service indicates that the label was created on 7/03/2024, but does not indicate when the
`package was shipped. The proof of delivery, however, indicates that it was successfully delivered on July
`19, 2024. EDIS Doc. ID 827527, Proof of Service Ex. 35 at 2.
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`16 Flawless Wholesale was served at its registered business address, 5589 E Santa Ana Canyon Rd,
`Anaheim, CA 92807. Mot. at 10; Compl. at ¶ 61.
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`17 The proof of service indicates that the label was created on 7/03/2024, but does not indicate when the
`package was shipped. The proof of delivery, however, indicates that it was successfully delivered on July
`19, 2024. EDIS Doc. ID 827527, Proof of Service Ex. 36 at 2.
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`18 Vapesourcing was served at its registered business address, 3045 Edinger Avenue, Tustin,
`CA 92780. Mot. at 10; Compl. at ¶ 63.
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`19 The proof of service indicates that the label was created on 7/03/2024, but does not indicate when the
`package was shipped. The proof of delivery, however, indicates that it was successfully delivered on July
`19, 2024. EDIS Doc. ID 827527, Proof of Service Ex. 38 at 2.
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`7
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`

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`iMiracle (Shenzhen) Technology Co., Ltd. iMiracle (Shenzhen) Technology Co., Ltd.
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`(“iMiracle”) is a foreign entity located in Shenzhen, China.20 Mot. at 10; Compl. at ¶ 17.
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`iMiracle admitted that its principal place of business is located at Room 1606, Building T5, No.
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`5035 Menghai Avenue, Nanshan District, Qianhai Cooperation Zone, Shenzhen Guangdong,
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`China 518052 in a verified response to the complaint in a co-pending investigation. See Certain
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`Disposable Vaporizer Devices, Inv. No. 337-TA-1381, EDIS Doc. ID No. 812394, Response to
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`the Verified Complaint at ¶ 52 (Jan. 22, 2024).21 Complainants attempted—unsuccessfully—to
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`serve iMiracle at this address, and Staff reports that counsel for iMiracle in the co-pending
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`investigation indicated they are not representing iMiracle in the current investigation. See Mem.
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`at 10; Staff Resp. at 3 n.2.
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`However, iMiracle—through counsel—appears as a signee on the Request to Deny
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`Provisional Acceptance of Complainants’ Motion for Temporary Relief (EDIS Doc. ID 824391),
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`submitted by the “signing Proposed Respondents,” id. at 1, and filed on June 25, 2024 prior to
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`institution of the investigation. See Staff Resp. at 3.
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`II.
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`ANALYSIS
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`Based on the current record as described above, the undersigned finds that each of the
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`Defaulting Respondents have received notice of the complaint and NOI. Setting aside iMiracle,
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`the proofs of service submitted by Complainants indicate successful service of the complaint and
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`notice of investigation at the principal place of business or, in the case of LCF Labs, at least to an
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`executive officer consistent with Commission Rule 201.16. 19 C.F.R. §§ 201.16(a)(1)-(3)
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`20 Vapesourcing was served at its registered business address, 3045 Edinger Avenue, Tustin,
`CA 92780. Mot. at 10; Compl. at ¶ 63.
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`21 iMiracle continues to participate in the 1381 investigation. See e.g., Joint Motion to Modify Certain Procedural
`Deadlines and Respondents’ Unopposed Motion to Modify Hearing Dates, EDIS Doc. ID 829527 (Aug. 14, 2024)
`(submission in 1381 investigation); see also Staff Resp. at 2-3.
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`8
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`(service shall be effected: (1) “[b]y mailing, delivering, or serving by electronic means a copy of
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`the document to the person to be served, to a member of the partnership to be served, to the
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`president, secretary, other executive officer, or member of the board of directors of the
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`corporation, association, or other organization to be served;” (2) “[b]y leaving a copy thereof at
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`the principal office of such person, partnership, corporation, association, or other organization;”
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`or (3) “[b]y using an express delivery service to send a copy of the document to the principal
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`office of such person, partnership, corporation, association, or other organization.”).
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`As to iMiracle, although service by express delivery was unsuccessful, Complainants and
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`Staff submit that iMiracle has had actual notice of this investigation, as evidenced by the filing of
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`a Request to Deny Provisional Acceptance of Complainants’ Motion for Temporary Relief
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`(EDIS Doc. ID 824391), which was filed on June 25, 2024. Mem. at Staff Resp. at 3. The
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`undersigned finds that iMiracle received actual notice of at least the complaint and Motion for
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`Temporary Relief. Similar participation has been deemed to be sufficient actual notice for a
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`show cause order to issue. See, e.g., Certain Child Carriers & Components Thereof, Inv. No.
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`337-TA-1154, Order No. 13, EDIS Doc. ID 679237, at 3 (June 24, 2029) (finding that entry of
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`counsel for a party evidenced actual notice); Certain Inkjet Cartridges With Printheads &
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`Components Thereof, Inv. No. 337-TA-723, Order No. 8, EDIS Doc, ID 433024, at 3 (Sept. 3,
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`2010) (“Moreover, it is clear that MicroJet has actual notice of this investigation. MicroJet
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`presented a motion to terminate the investigation based on the entry of a consent order. In Order
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`No. 7, that motion was denied for failure to comply with various Commission Rules. On August
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`19, 2010, counsel for MicroJet filed a Notice of Appearance in this investigation. The
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`submission of the motion and the notice of appearance both constitute evidence that MicroJet is
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`on notice of the investigation and HP’s allegations against MicroJet.”). Cf. Certain Industrial
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`9
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`Automation Sys. & Components Thereof Including Control Sys., Controllers, Visualization
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`Hardware, Motion & Motor Control Sys., Networking Equip., Safety Devs., & Power Supplies,
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`Inv. No. 337-TA-1074, Order No. 20, EDIS Doc. ID 640185, at 2 n.1 (granting motion for an
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`order to show cause, and noting that “a representative of [defaulting respondent] communicated
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`with [complainant] regarding the investigation . . . prior to institution”).
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`No Defaulting Respondent has responded to the complaint and the notice of
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`investigation, have entered an appearance, or otherwise demonstrated any intent to participate in
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`this investigation. Moreover, no Defaulting Respondent has responded to the instant motion and
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`is “deemed to have consented to the granting of the relief asked for in the motion.” See 19 C.F.R.
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`§ 210.15(c).
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`Accordingly, Complainants’ motion (1410-002) to show cause is hereby GRANTED.
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`Respondents Vapeonly Technology Co. Ltd.; iMiracle (Shenzhen) Technology; Nevera (HK)
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`Ltd.; Wonder Ladies Ltd.; Sailing South Ltd.; Marea Morada Ltd.; Social Brands, LLC; Palma
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`Terra Ltd.; Heaven Gifts International Ltd.; Shenzhen LC Technology Co., Ltd.; LCF Labs, Inc.;
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`Flumgio Technology Ltd.; Flawless Vape Shop Inc.; Flawless Vape Wholesale & Distribution
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`Inc.; and VICA Trading Inc. d/b/a Vapesourcing are ordered to show cause why they should not
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`be held in default for failing to respond to the complaint and notice of investigation no later than
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`the close of business on September 13, 2024. In the absence of any showing of good cause
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`within said time period, the undersigned will enter an Initial Determination of default against
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`Vapeonly Technology Co. Ltd.; iMiracle (Shenzhen) Technology; Nevera (HK) Ltd.; Wonder
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`Ladies Ltd.; Sailing South Ltd.; Marea Morada Ltd.; Social Brands, LLC; Palma Terra Ltd.;
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`10
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`Heaven Gifts International Ltd.; Shenzhen LC Technology Co., Ltd.; LCF Labs, Inc.; Flumgio
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`Technology Ltd.; Flawless Vape Shop Inc.; Flawless Vape Wholesale & Distribution Inc.; and
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`VICA Trading Inc. d/b/a Vapesourcing.
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`SO ORDERED.
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`Monica Bhattacharyya
`Administrative Law Judge
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`11
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`CERTAIN DISPOSABLE VAPORIZER DEVICES
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` Inv. No. 337-TA-1410
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`
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`PUBLIC CERTIFICATE OF SERVICE
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`I, Lisa R. Barton, hereby certify that the attached ORDER has been served via EDIS
`upon the Commission Investigative Attorney, Vu Bui, Esq., and upon the following parties as
`indicated, on September 3, 2024.
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`On Behalf of Complainants RAI Strategic Holdings, Inc., R.J.
`Reynolds Tobacco Company, R.J. Reynolds Vapor Company,
`and RAI Services Company:
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`David M. Maiorana
`JONES DAY
`901 Lakeside Avenue
`Cleveland, OH 44114
`Email: dmaiorana@jonesday.com
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`On Behalf of Respondent SV3, LLC d/b/a Mi-One Brands:
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`Daniel E. Yonan, Esq.
`STERNE, KESSLER, GOLDSTEIN & FOX, P.L.L.C.
`1101 K Street NW, 10th Floor
`Washington, DC 20005
`Email: dyonan@sternekessler.com
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`On Behalf of Respondents Breeze Smoke, LLC and Dongguan
`(Shenzhen) Shikai Technology Co., Ltd.:
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`Patrick J. McCarthy, Esq.
`GOODWIN PROCTOR LLP
`1900 N Street, NW Washington, DC 20036
`Email: PMcCarthy@goodwinlaw.com
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`Lisa R. Barton, Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
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`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`CERTAIN DISPOSABLE VAPORIZER DEVICES
`
` Inv. No. 337-TA-1410
`
`Certificate of Service – Page 2
`On Behalf of Respondents Pastel Cartel, LLC, American Vape
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`Company, LLC, Affiliated Imports, LLC:
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`David F. Nickel, Esq.
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1150 18th Street, N.W., Suite 775
`Washington, D.C. 20036
`Email: dnickel@fostermurphy.com
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`On Behalf of Respondent Bidi Vapor, LLC:
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`Charles C. Carson, Esq.
`BAKER & HOSTETLER LLP
`1050 Connecticut Avenue, NW, Suite 1100
`Washington, D.C. 20036-5403
`Email: ccarson@bakerlaw.com
`
`On Behalf of Respondent Shenzhen Han Technology Co.,
`Ltd.:
`
`Gary M. Hnath, Esq.
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006-1101
`Email: ghnath@mayerbrown.com
`
`On Behalf of Respondents Fewo Intelligent Manufacturing
`Ltd., Guangdong Cellular Workshop Electronics Technology
`Co., Ltd., Guangdong Qisitech Co., Ltd., and Zhuhai Qisitech
`Co., Ltd.:
`
`P. Andrew Riley, Esq.
`MEI & MARK LLP
`818 18th Street NW, Suite 410
`Washington, DC 20006
`Email: ariley@meimark.com
`On Behalf of Respondent Maduro Distributors, Inc. d/b/a The
`Loon and TheSy, LLC d/b/a Element Vape:
`
`Eric Allen Zelepugas, Esq.
`THOMPSON HINE LLP
`20 North Clark Street, Suite 3200
`Chicago, Illinois 60602-5093
`Email: Eric.Zelepugas@ThompsonHine.com
`
` ☐
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
`
`
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
`

`

`CERTAIN DISPOSABLE VAPORIZER DEVICES
`
` Inv. No. 337-TA-1410
`
`
`
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
`
`
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
`
`
` ☐
`
` Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
`
`
`
` ☐
`
` Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`
`Certificate of Service – Page 3
`
`On Behalf of Respondent Shenzhen Kangvape Technology
`Co., Ltd.
`
`Joseph V. Colaianni, Esq.
`FISH & RICHARDSON P.C.
`1000 Maine Avenue, S.W., Suite 1000
`Washington, D.C. 20024
`Email: colaianni@fr.com
`
`
`On Behalf of Respondent Shenzhen Yanyang Technology Co.,
`Ltd., Shenzhen Pingray Technology Co., Ltd., Shenzhen IVPS
`Technology Co., Ltd., and Kimsun Technology (HuiZhou)
`Co., Ltd.:
`
`Jason Xu, Esq.
`RIMON PC
`1050 Connecticut Ave NW, Suite 500
`Washington, DC 20036
`Email: jason.xu@rimonlaw.com
`
`
`
`
`On Behalf of Respondent Price Point Distributors Inc. d/b/a
`Price Point NY:
`
`Erik J. Dykema, Esq.
`BOCHNER PLLC
`1040 Avenue of the Americas, 15th Floor
`New York, New York 10018
`Email: erik@bochner.law
`
`
`Respondents:
`
`Vapeonly Technology Co. Ltd.
`19H Maxgrand Plaza
`No. 3 Tai Yau Street
`San Po Kong, Kowloon, Hong Kong
`
`
`iMiracle (Shenzhen) Technology Co., Ltd.
`Unit 3510-37, Luohu Business Center
`No. 2028 Shennan East Road
`
`
`
`

`

`CERTAIN DISPOSABLE VAPORIZER DEVICES
`
` Inv. No. 337-TA-1410
`
`Certificate of Service – Page 4
`Chengdong Community, Dongmen Street
`Luohu District, Shenzhen, China 518001
`
`
`
`
`
`
`Nevera (HK) Ltd.
`19H, Maxgrand Plaza
`No. 3 Tai Yau Street
`San Po Kong, Kowloon, Hong Kong
`
`
`
`
`Wonder Ladies Ltd.
`Sea Meadow House
`P.O. Box 116, Road Town
`Tortola, British Virgin Islands VG1110
`
`
`Sailing South Ltd.
`Sea Meadow House
`P.O. Box 116, Road Town
`Tortola, British Virgin Islands VG1110
`
`
`Marea Morada Ltd.
`Sea Meadow House
`P.O. Box 116, Road Town
`Tortola, British Virgin Islands VG1110
`
`
`Social Brands, LLC
`Beshoy Saad (registered agent)
`Suite 385
`9696 Skillman Street,
`Dallas, TX 75243
`
`
`
`
`
`
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`

`

`CERTAIN DISPOSABLE VAPORIZER DEVICES
`
` Inv. No. 337-TA-1410
`
`Certificate of Service – Page 5
`Palma Terra Ltd.
`Sea Meadow House P.O. Box 116
`Road Town, Tortola, British Virgin Islands
`
`
`
`
`
`
`
`
`
`
`Heaven Gifts International Ltd.
`19H, Maxgrand Plaza No.3 Tai Yau Street
`San Po Kong, Kowloon, Hong Kong
`
`
`
`
`
`
`
`
`
`
`
`Shenzhen LC Technology Co., Ltd.
`Room 301, 3rd Floor, Building 3
`Changyi Industrial Factory
`No. 1 Lirong Road, Xinshi Community
`Dalang Street, Longhua District
`Shenzhen, Guangdong Province, China 518109
`
`
`LCF Labs, Inc.
`895 S Rockefeller Avenue, Unit 103
`Ontario, CA 91761
`
`
`
`
`
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`
`
`
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`
`

`

`CERTAIN DISPOSABLE VAPORIZER DEVICES
`
` Inv. No. 337-TA-1410
`
`Certificate of Service – Page 6
`
`Flumgio Technology Ltd.
`Room 21, Unit A, Tin Wui Industrial Building
`No. 3 Hing Wong Street, Tuen Mun
`N.T., Hong Kong
`
`
`
`
`
`
`
`Flawless Vape Shop Inc.
`5589 E Santa Ana Canyon Rd
`Anaheim, CA 92807
`
`
`
`Flawless Vape Wholesale & Distribution Inc.
`5589 E Santa Ana Canyon Rd
`Anaheim, CA 92807
`
`
`
`
`
`VICA Trading Inc. d/b/a Vapesourcing
`3045 Edinger Avenue
`Tustin, CA 92780
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`☐ Via Hand Delivery
`☒ Via Express Delivery
`☐ Via First Class Mail
`☐ Other: Service to Be
`Completed by Complainant
`
`
`
`
`
`
`
`
`
`

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