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Plaintiff, Dexas International, Ltd. (“Dexas”), for its complaint against Defendants
Hangzhou Rena Pet Products Co., Ltd. (Hangzhou) and Midwest Marketplace OKC, Inc. dba
1. This is an action at law and in equity for patent infringement arising under the
Patent Act, 35 U.S.C. § 271 et seq., and for trademark infringement and unfair competition
2. Dexas is the creator of an innovative and popular line of pet care and pet travel
products known as Popware® for Pets. This line includes, among other distinctive designs, the
Dexas MUDBUSTER™ portable dog paw cleaner, which is at issue in this case. The
MUDBUSTER™ design is protected by United States Design Patent No. D799,126 (“the ‘126
3. Hangzhou and Heartland Tees are substantially copying without authorization the
Dexas distinctive MUDBUSTER™ design, and are manufacturing, importing, offering for sale,
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Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 2 of 16 PageID 2
and/or selling a product (Accused Product) that is confusingly similar to the MUDBUSTER™
product design. Heartland Tees also made an exact copy of a portion of a Dexas
MUDBUSTER™ advertising video showing the MUDBUSTER™ product and using the
MUDBUSTER™ trademark, and spliced it into a Heartland Tees advertising video that also
shows the Accused Product. The resulting Heartland Tees advertising video shows both the
Dexas MUDBUSTER™ product and trademark, and the Heartland Tees Accused Product, and
represents that they are the same product. Hangzhou and Heartland Tees also are using an image
of the Dexas MUDBUSTER Product in their Internet advertising and marketing for the Accused
Product. Hangzhou and Heartland Tees are infringing on the ‘126 Patent, infringing on the
MUDBUSTER™ trademark, and/or committing unfair competition, for which Dexas seeks
4. Dexas is a limited partnership with its principal place of business at 585 South
under the laws of Zhejiang Province, Mainland China, with a principal place of business at Rm.
503, Developing Building, Nanyuan Yuhang District, Hangzhou, Zhejiang, China (310000).
Tees (“Heartland Tees”) is a corporation organized and existing under the laws of the State of
Oklahoma, with a principal place of business at 3600 SW 123rd Ct, Oklahoma City, OK 73170.
competition, and false designation of origin. This action arises under the Patent Act, 35 U.S.C. §
1, et seq. and the Trademark Act of 1946, 15 U.S.C. § 1051, et seq. (“the Lanham Act”).
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Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 3 of 16 PageID 3
8. This Court has subject matter jurisdiction over this action pursuant to at least 28
9. The Court has personal jurisdiction over Hangzhou because Hangzhou has
purposefully used intermediators to sell one or more Accused Products in the State of Texas
through the stream of commerce and purposefully directed its activities at Texas residents and
the residents of this Judicial District by placing Accused Products into established distribution
channels with expectation that they would be sold throughout the United States, including Texas
and this Judicial District. Further, Hangzhou offers for sale Accused Products and uses images
of the Dexas MUDBUSTER™ product to advertise, market, and offer for sale the Accused
Product at: (all links in this complaint were last accessed on January 26, 2018).
https://www.aliexpress.com/item/New-Pet-Foot-Washer-Cup-Dog-Foot-Wash-Tools-Soft-
Gentle-Silicone-Bristles-Pet-Brush-Quickly/32829736721.html
and residents of the State of Texas and this Judicial District can and have viewed the Accused
Product at this website address. The Hangzhou website indicates that many Accused Products
have been sold and shipped to the United States, including at least one into the State of Texas and
this Judicial District. The website address indicates that the Accused Product can be shipped for
free into the United States, and Hangzhou therefore advertises and markets the Accused Product
with the knowledge and intent that it can be sold and shipped to the United States, including the
10. The Court has personal jurisdiction over Heartland Tees because Heartland Tees
advertises, markets, and offers for sale an Accused Product that look substantially similar to the
https://heartlandtees.com/products/pet-foot-washer-cup
and Heartland Tees uses images of the Dexas MUDBUSTER™ product and/or MUDBUSTER™
3
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 4 of 16 PageID 4
trademark to advertise, market, and offer for sale the Accused Product at:
https://www.youtube.com/watch?v=VQy6SQ8gZlY&feature=youtu.be and
https://heartlandtees.com/products/pet-foot-washer-cup
Both of these website locations can and have been accessed by residents of the State of Texas
and this Judicial District, and Heartland Tees has sold the Accused Product for delivery into the
State of Texas and this Judicial District. Heartland Tees advertises and markets the Accused
Product with the knowledge and intent that it be distributed and sold within the United States,
11. Venue is proper in this District against Hangzhou under 28 U.S.C. § 1391(c)(3)
because Hangzhou is a foreign corporation not resident in any district in the United States.
12. Dexas is a Texas-based designer and manufacturer of cutting boards, kitchen tools
and gadgets, storage clipboard cases, and pet care and pet travel products. Dexas provides these
13. Based on the design innovation of the popular Dexas Popware® collapsible
strainers and colanders kitchen products, Dexas created the Popware® for Pets line of pet care
and pet travel products. These products include the MUDBUSTER™ portable dog paw cleaner,
an adjustable pet feeder, collapsible travel cup, BrushBuster™ pet brush, collapsible kennel
14. Dexas invests great time and expense to bring their customers innovative and
well-designed products for their personal use. To protect this investment, a core component of
the Dexas business model is patent and intellectual property protection and enforcement.
15. On October 3, 2017, the United States Patent and Trademark Office duly and
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Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 5 of 16 PageID 5
legally issued Design Patent No. D799,126 entitled "Pet Paw Washer," ("the '126 Patent"). A
true and correct copy of the ‘126 Patent is attached hereto as Exhibit 1. The ‘126 Patent covers
the Dexas MUDBUSTER™ portable dog paw cleaner and all substantially similar copies.
16. Dexas is the exclusive licensee of the ‘126 Patent. The exclusive license includes
the right to manufacture, import, export, sell and offer for sale, products which are covered by
the ‘126 Patent, and all rights to sue, including but not limited to injunctive relief and recovery of
monetary damages for infringement, for any past or future infringement of the ‘126 Patent.
17. Dexas markets and advertises the MUDBUSTER™ portable dog paw cleaner
18. Heartland Tees advertises the Accused Product on the World Wide Web at:
https://www.youtube.com/watch?v=VQy6SQ8gZlY&feature=youtu.be
A still image from a marketing and advertising video posted, sponsored, and/or authorized by
https://www.youtube.com/watch?v=VQy6SQ8gZlY&feature=youtu.be
showing the Accused Product is set forth below and attached to this complaint as Exhibit 2.
5
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 6 of 16 PageID 6
19. An additional still image from the same Heartland Tees advertising video is set
forth below and attached to this complaint as Exhibit 3. This image depicts the Dexas
MUDBUSTER™ product that contains the design claimed in the ‘126 Patent. It also shows the
URL for Heartland Tees (www.heartlandtees.com) and the Dexas MUDBUSTER™ trademark.
Image from Heartland Tees Advertising Video showing Dexas MUDBUSTER™ Product
20. The still image from the Heartland Tees advertising video depicting the Dexas
MUDBUSTER™ product is, except for the text and red and blue squares added by Heartland
Tees, exactly the same as that shown on the Dexas MUDBUSTER™ advertising video at:
https://www.youtube.com/watch?v=H773Or9awDQ,
attached hereto as Exhibit 4. The still image from the Heartland Tees video is shown below left
and the still image from the Dexas MUDBUSTER™ video is shown below right.
6
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 7 of 16 PageID 7
21. As shown above, Heartland Tees made an exact copy of a portion of a Dexas
MUDBUSTER™ trademark, and then spliced it into a Heartland Tees advertising video that also
shows the Accused Product. The resulting Heartland Tees advertising video shows both the
Dexas MUDBUSTER™ product, the MUDBUSTER™ trademark, and the Heartland Tees
Accused Product, and represents that they are all the same product.
22. Heartland Tees also advertises the Accused Product on the World Wide Web at:
https://heartlandtees.com/products/pet-foot-washer-cup.
An image from this Heartland Tees website shows both the Accused Product and the Dexas
MUDBUSTER™ product. The image from the Heartland Tees website is set forth below and the
7
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 8 of 16 PageID 8
23. The website indicates that an image from Dexas MUDBUSTER™ product
advertising was copied and inserted into the Heartland Tees website. The image of the Dexas
MUDBUSTER™ product is shown under the “2 Step” reference just above the words “Gently
Rotate.” The image of the human hands holding a dog’s paw also is taken from a Dexas
MUDBUSTER™ product advertising image, but the Dexas MUDBUSTER™ product has been
replaced with the Accused Product. The image from the Dexas MUDBUSTER™ product
advertising at:
https://www.amazon.com/Dexas-MudBuster-Portable-Cleaner-
Large/dp/B01N52Z30T/ref=sr_1_1_sspa?ie=UTF8&qid=1516916127&sr=81spons&keywords=
paw+washer&psc=1,
24. Hangzhou advertises the Accused Product on the World Wide Web under the
https://www.aliexpress.com/item/New-Pet-Foot-Washer-Cup-Dog-Foot-Wash-Tools-Soft-
Gentle-Silicone-Bristles-Pet-Brush-Quickly/32829736721.html.
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Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 9 of 16 PageID 9
An image from this Hangzhou website shows the Accused Product. The image from the
Hangzhou website is set forth below and the full website page is attached to this complaint as
Exhibit 7.
25. The image also indicates that Hangzhou copied an image from Dexas
MUDBUSTER™ product advertising and inserted it in the Hangzhou website. The image of the
Dexas MUDBUSTER™ product is shown under the “2 Step” reference just above the words
“Gently Rotate.” The image of the human hands holding a dog’s paw also is taken from a Dexas
MUDBUSTER™ product advertising image, but the Dexas MUDBUSTER™ product has been
replaced by Hangzhou with the Accused Product. The image from the Dexas MUDBUSTER™
https://www.amazon.com/Dexas-MudBuster-Portable-Cleaner-
Large/dp/B01N52Z30T/ref=sr_1_1_sspa?ie=UTF8&qid=1516916127&sr=81spons&keywords=
paw+washer&psc=1,
also is set forth on the following page and attached to this complaint as Exhibit 6.
*****
9
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 10 of 16 PageID 10
26. The substantial similarity of the ‘126 Patented Design and the Accused Product
design is evidenced by Heartland Tees’ use of both designs in the advertising video to represent
one product and Hangzhou’s use of both designs in its web page advertising to represent one
product. Further, although the ‘126 Patented Design has a rippled/grooved edge on the side of
the lid and the Accused Product Design has a rippled/grooved edge on the top of the lid, the
appearance and location of the ripples/grooves on both the Patented and Accused Product
designs in the context of the overall designs are substantially the same. An ordinary observer,
giving such attention as a purchaser usually gives, would consider the two overall designs to be
27. Figure 1 of the ‘126 Patent is set forth on the following page.
*****
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Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 11 of 16 PageID 11
28. Hangzhou is infringing the ‘126 Patent by making, selling, offering for sale,
importing, and/or using an accused product with an overall design substantially similar to the
overall design claimed in the ‘126 Patent. Infringement is occurring because an ordinary
observer, giving such attention as a purchaser usually gives, would consider the two designs to
11
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 12 of 16 PageID 12
29. Hangzhou’s Accused Product is offered for sale and sold on the Internet at:
https://www.aliexpress.com/item/New-Pet-Foot-Washer-Cup-Dog-Foot-Wash-Tools-Soft-
Gentle-Silicone-Bristles-Pet-Brush-Quickly/32829736721.html
as shown in the attached Exhibit 7. Hangzhou also sells to U.S. distributors such as Heartland
Tees, who in turn import, offer for sale, and sell the infringing product in the United States at
V. COUNT I:
Patent Infringement (Hangzhou)
30. Dexas realleges and incorporates the allegations set forth in paragraphs 1 through
infringement of the ‘126 Patent by making, selling, offering for sale, importing, and/or using an
Accused Product with an overall design substantially similar to the overall design claimed in the
‘126 Patent. Infringement is occurring because an ordinary observer, giving such attention as a
purchaser usually gives, would consider the two designs to be substantially the same in light of
infringement as described above and will continue said acts of infringement unless permanently
12
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 13 of 16 PageID 13
35. Dexas has placed the required statutory marking and notice on all products made
36. Dexas realleges and incorporates the allegations set forth in paragraphs 1through
advertisements, marketing, promotions, offers to sell, sales, and distribution of the Accused
Product, in direct competition with Dexas, violate § 43(a) of the Lanham Act, 15 U.S.C. §
1125(a) and constitute trademark infringement, at least because Heartland Tees has used images
connection with the advertisements, marketing, promotions, offers to sell, sales, and distribution
of the Accused Product. Such uses are likely to cause consumer confusion as to the origin and/or
sponsorship/affiliation of the Dexas MUDBUSTER™ product and the Accused Product, at least
by creating the false and misleading impression that the Dexas MUDBUSTER™ product and the
Accused Product are the same product, and that the Dexas MUDBUSTER™ product is
manufactured by, sold by, authorized by, or otherwise associated with Heartland Tees.
product images and the Dexas MUDBUSTER™ trademark, including through reproductions,
copies, and/or colorable imitations thereof, has been intentional, willful, and malicious.
Heartland Tees’ bad faith is evidenced at least by Heartland Tees’ use of video footage produced
by Dexas and that contains the Dexas MUDBUSTER™ product and trademark.
39. Heartland Tees use of Dexas MUDBUSTER™ product images and trademark,
including through reproductions, copies, and/or colorable imitations thereof has caused and,
13
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 14 of 16 PageID 14
unless enjoined, will continue to cause substantial and irreparable injury to Dexas for which
Dexas has no adequate remedy at law, including at least substantial and irreparable injury to the
goodwill and reputation for quality associated with Dexas, and the Dexas MUDBUSTER™
40. Dexas is entitled to injunctive relief, and Dexas is also entitled to recover at least
Heartland Tees’ profits, Dexas’ actual damages, enhanced damages, costs, and reasonable
41. Dexas realleges and incorporates the allegations set forth in paragraphs 1through
sell, sales, distribution, and/or importing of the Accused Product, in direct competition with
Dexas, violate § 43(a) of the Lanham Act, 15 U.S.C. § 1125(a) and constitute unfair competition,
false advertising, and false designation of origin, at least because Hangzhou and Heartland Tees
have used images of the Dexas MUDBUSTER™ product in connection with the advertisements,
marketing, promotions, offers to sell, sales, and distribution of the Accused Product. Such uses
are likely to cause consumer confusion as to the origin and/or sponsorship/affiliation of the
Dexas MUDBUSTER™ product and the Accused Product, at least by creating the false and
misleading impression that the Dexas MUDBUSTER™ product and the Accused Product are the
same product, and that the Dexas MUDBUSTER™ product is manufactured by, sold by,
43. On information and belief, the use by Hangzhou and Heartland Tees of Dexas
14
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 15 of 16 PageID 15
imitations thereof, has been intentional, willful, and malicious. Heartland Tees’ bad faith is
evidenced at least by Heartland Tees’ use of video footage created by Dexas and that contains the
Dexas MUDBUSTER™ product and Hangzhou’s use of the Dexas MUDBUSTER™ product
44. The use by Hangzhou and Heartland Tees of Dexas MUDBUSTER™ product
images, including through reproductions, copies, and/or colorable imitations thereof has caused
and, unless enjoined, will continue to cause substantial and irreparable injury to Dexas for which
Dexas has no adequate remedy at law, including at least substantial and irreparable injury to the
goodwill and reputation for quality associated with Dexas, and the Dexas MUDBUSTER™
product.
45. Dexas is entitled to injunctive relief, and Dexas is also entitled to recover at least
Hangzhou’s and Heartland Tees’ profits, Dexas’ actual damages, enhanced damages, costs, and
reasonable attorney fees under at least 15 U.S.C. §§ 1125(a), 1116, and 1117.
WHEREFORE, Plaintiff prays for a judgment against Hangzhou and Heartland Tees as
follows:
d. That Hangzhou, its agents, servants and employees and all those in privity,
concert, or participation with any of them, be permanently enjoined from infringing U.S. Design
15
Case 3:18-cv-00224-L Document 1 Filed 01/29/18 Page 16 of 16 PageID 16
damages, costs, and reasonable attorney fees under at least 15 U.S.C. §§ 1125(a), 1116, and 1117.
h. That Hangzhou and Heartland Tees have engaged in unfair competition and false
damages, enhanced damages, costs, and reasonable attorney fees under at least 15 U.S.C. §§
k. An award of prejudgment and post judgment interest and costs to Dexas; and
l. Such other and further relief as the Court deems proper and just.
Dexas, pursuant to Rule 38(b) of the Federal Rues of Civil Procedure, demands a trial by
Respectfully submitted,
16
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 1 of 8 PageID 17
EXHIBIT 1
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 2 of 8 PageID 18
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 3 of 8 PageID 19
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 4 of 8 PageID 20
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 5 of 8 PageID 21
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 6 of 8 PageID 22
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 7 of 8 PageID 23
Case 3:18-cv-00224-L Document 1-1 Filed 01/29/18 Page 8 of 8 PageID 24
Case 3:18-cv-00224-L Document 1-2 Filed 01/29/18 Page 1 of 2 PageID 25
EXHIBIT 2
Case 3:18-cv-00224-L Document 1-2 Filed 01/29/18 Page 2 of 2 PageID 26
Image from Heartland Tees Advertising Video
Case 3:18-cv-00224-L Document 1-3 Filed 01/29/18 Page 1 of 2 PageID 27
EXHIBIT 3
Case 3:18-cv-00224-L Document 1-3 Filed 01/29/18 Page 2 of 2 PageID 28
Image from Heartland Tees Advertising Video showing Dexas MUDBUSTER™ Product
Case 3:18-cv-00224-L Document 1-4 Filed 01/29/18 Page 1 of 2 PageID 29
EXHIBIT 4
Case 3:18-cv-00224-L Document 1-4 Filed 01/29/18 Page 2 of 2 PageID 30
Dexas MUDBUSTER™ Video Image
Case 3:18-cv-00224-L Document 1-5 Filed 01/29/18 Page 1 of 5 PageID 31
EXHIBIT 5
Case 3:18-cv-00224-L Document 1-5 Filed 01/29/18 Page 2 of 5 PageID 32
796/products/1e2fafb25f715d6355239aee0ba64892_1024x1024.jpg?
3bcc0c015197df814a07b777407_f9d40f02-
m/s/files/1/1153/0796/products/d417bef1b52c207d99ff2e293d166f78_1024x1024.jpg?
(//cdn.shopify.com/s/files/1/1153/0796/products/05610c304b8264be25d92e3fec117bcd_1024x1024.jpg?
(//cdn.shopify.com/s/files/1/1153/0796/products/149b8193609a50e7270b48ba4b324383_1024x1024.jpg?
(//cdn.shopify.com/s/files/1/1153/0796/products/245e9051f9ce409de13d61f288a08022_1024x1024.jpg?
(//cdn.shopify.com/s/files/1/1153/0796/products/New-
(//cdn.shopify.com/s/files/1/1153/0796/products/New-
(//cdn.shopify.com/s/files/1/1153/0796/products/New-
(//cdn.shopify.com/s/files/1/1153/0796/products/aa8d23
(//cdn.shopify.com/s/files/1/1153/07
(//cdn.shopify.com
v=1508989372) v=1508989372) v=1508989372) Pet-Foot- Pet-Foot- Pet-Foot- b5e9-451d-9c4f- v=1508989372) v=1508989372)
Washer-Cup- Washer-Cup- Washer-Cup- 58caef98e1a4_1024x1024.jpg?
SIZE S
Color
Size Contact Us
S
Case 3:18-cv-00224-L Document 1-5 Filed 01/29/18 Page 3 of 5 PageID 33
Add to cart
39 People Are Looking At This Moment
0 0 32 14
DAYS HOURS MINUTES SECONDS
Description
The small washer is perfectly sized for smaller dogs: it measures 4.45 inches tall and 3.5 inches wide
To use, add a little water and hand sanitizer, insert the muddy paw, dab the paw dry,repeat for 3 more paws
Before touching furniture or carpets, remove the mud, sand, dirt, and ice from the dog's claws and quickly remove other harmful bacteria and chemicals
Rest assured that the dog will go outdoors, play in the park, run and walk, because the soft silicone brush can quickly remove dirt from the dog's paws.
Simple and easy to use, just rinse and keep on hand for next muddy encounter. BPA free
(
(//pinterest.com/pin/create/button/?
url=https://heartlandtees.com/products/pet-
foot-
washer-
& ' +
cup&media=//cdn.shopify.com/s/files/1/1153/0796/products/aa8d23bcc0c015197df81
(//www.facebook.com/sharer.php?
(//twitter.com/share?
b5e9- (//plus.google.com/share?
u=https://heartlandtees.com/products/pet-
text=Pet%20Foot%20Washer%20Cup&url=https://heartlandtees.com/products/pet-
451d- url=https://heartlandtees.com/products/pet-
foot- foot- 9c4f- foot-
washer- washer- 58caef98e1a4_1024x1024.jpg?
washer-
cup) cup) v=1508989372&description=Pet%20Foot%20Washer%20Cup)
cup)
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EXHIBIT 6
Case 3:18-cv-00224-L Document 1-6 Filed 01/29/18 Page 2 of 2 PageID 37
Dexas MUDBUSTER™ Product Advertising Image on Amazon.com
Case 3:18-cv-00224-L Document 1-7 Filed 01/29/18 Page 1 of 16 PageID 38
EXHIBIT 7
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Case 3:18-cv-00224-L Document 1-7 Filed 01/29/18 Page 3 of 16 PageID 40
Item specifics
Product Description
Pet Dog Stainless Steel Classic Double Blades Multi-purpose Pet Com Funny Cat Kitten Pet Pl
Curved Blade Comb Gr Side Pet Fur Dog Brush b Dog Hair Remover Br ay Tents Tunnel Playgr
ooming
USD 8.00Brush Cat Hair
8.00/piece Cat
USD Grooming
13.04 Deshedd
13.04/piece ush
USDGrooming Tools Co
6.63-8.53
6.63-8.53/piec ound
USD Toys Outdoor Fol
6.43-7.35
6.43-7.35/piec
Clipper Remove Float H ing Trimmer Tool Dog C e
mb Hair For Pet Supply e
dable Cat Tunnel Comb
air Comb Pet Supplies omb Pet Brush Rake Furminators inable Toys for Cat
Removable Pet Comb Pet Cat Brush Comb Pl New Pet Foot Washer C New Colorful ABS High-
Dog Hair Remove Exce ay Toy Plastic Scratch B up Dog Foot Wash Tool Grade Stable Durable 5
ss
USDHair6.35-8.17
Tools Comb Hai
6.35-8.17/piec ristles
USD 5.93Arch Self-Groom
5.93/piece sUSD
Soft 9.31
Gentle Silicone B
9.31/piece Meter Automatic Retra
USD 11.81
11.81/piece
e
r For Pet Supply Detac er Massager Scratcher ristles Pet Brush Quickl ctable Dog Traction Ro
hable Hair Clipper With Catnip Nailed to y Clean Paws Muddy Fe pe Leashes Pet Leads
Wall et
Items Description
Brand name: Hilou Pet
Color: Green/Blue/Pink
Material: Plastic/Silicone
Features: Funny/Portable/Easy to clean
Item Size
Case 3:18-cv-00224-L Document 1-7 Filed 01/29/18 Page 4 of 16 PageID 41
Item Pictures
Case 3:18-cv-00224-L Document 1-7 Filed 01/29/18 Page 5 of 16 PageID 42
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Shipping
1.We only send the order address that you confirmed. Please kindly check if it's correct. If you
have
not received your parcel within 45 days frompayment, please contact us. We will track the
express
and get back to you as soon as possible with a reply. Your satisfaction comes first!
2. Import duties, taxes and charges are not included in the item price or shipping charges.
These
charges are the buyer responsibility.
3. We can also deliver the item through express serive such as UPS, DHL, EMS ( about 3-10
working
days), you can contact us for the lowest espress fee.
Return Policy
1.You have 7 days to contact us and 30 days to return it from the date it was received. If this item
is
in your possession more than 7 days, it is considered to be used and WE WILL NOT ISSUE YOU
A
REFUND OR REPLACEMENT.
2.All returned items MUST BE in the original packaging and you MUST PROVIDE us with the
shipping
tracking number,specific reason for the return,and your po#.Shipping cost is bear by
buyer.Anyway,
if you have any question, do contact with us.
About Feedback
1.If you are satisfied with our goods,please give us Positive Feedback(5 stars) which is very
important
to us!
2.Please contact us before give netural(3 stars) feedback or negative(1-2 stars) feedback. We will
try
our best to solve the problems.
Company Information
Hangzhou Rena Pet Products Co., Ltd. Was established in 2008. Our company is located in Hangzhou, two hours'
drive from Shanghai and Ningbo port. Since then, We always specialize in producing all kinds of pet products. And we
have achieved a rapid growth in pet business now.
Our main products are included pet bed, petDocument
Case 3:18-cv-00224-L clothes, pet
1-7 toys
Filedand cat tree
01/29/18 in our
Page 14 ofown
16 factory. Now we have over 110
PageID 51
workers and 6000 square meters area. The production capability reaches 30pcs 40ft containers per month. On
another way, we also do trade business of all kinds of other pet products. They are included pet collar & leashes, pet
brushes, pet feeders, cat toys, small animal accessories, bird and fish accessories.
Good Quality, good service, good price and good credit are our business principle. Base on that, our products have been
sold to North American, European, Asia and Australia .Moreover, we have enjoyed a good reputation in these marketing.
For developing more business with our old and new customers, we have established our own sourcing and design
department for new pet items in every day.
Our aim is to be a world class supplier to wold class customers and to exceed our customer’s expections in quality,
delivery and cost through continuous improvement and customer interaction.
Case 3:18-cv-00224-L Document 1-7 Filed 01/29/18 Page 15 of 16 PageID 52
Packaging Details
More Products
Case 3:18-cv-00224-L Document 1-7 Filed 01/29/18 Page 16 of 16 PageID 53
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Case 3:18-cv-00224-L Document 1-8 Filed 01/29/18 Page 1 of 2 PageID 54
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VI. CAUSE OF ACTION %ULHIGHVFULSWLRQRIFDXVH
Design Patent Infringement, Trademark Infringement, Unfair Competition
VII. REQUESTED IN u &+(&.,)7+,6,6$CLASS ACTION DEMAND $ &+(&.<(6RQO\LIGHPDQGHGLQFRPSODLQW
COMPLAINT: 81'(558/()5&Y3 Injunction/money damages JURY DEMAND: u <HV u 1R
VIII. RELATED CASE(S)
(See instructions):
IF ANY -8'*( '2&.(7180%(5
'$7( 6,*1$785(2)$77251(<2)5(&25'
01/292018 /s/ Robert G. Oake, Jr.
FOR OFFICE USE ONLY
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