Emart Int'l v. Shenzhen Maitewei - Complaint

Case 2:20-cv-10641 Document 1 Filed 11/20/20 Page 1 of 15 Page ID #:1
1 Alan C. Chen (SBN 224420)

David L. Simson (SBN 287900)
2 RIMON, P.C.
2029 Century Park East, Suite 400N
3 Los Angeles, CA 90067
Telephone: (213) 375-3811
4 alan.chen@rimonlaw.com
david.simson@rimonlaw.com
5
Tony W. Wong (SBN 243324)
6 D&R I.P. Law Firm, APC
108 N. Ynez Avenue, Suite 213
7 Monterey Park, CA 91754
Telephone: (626) 571-9812
8 tonyw@dnriplaw.com
9 Attorneys for Plaintiff,
EMART INTERNATIONAL, INC.
10
11 UNITED STATES DISTRICT COURT
12 CENTRAL DISTRICT OF CALIFORNIA
13 EMART INTERNATIONAL, INC., Case No.: 2:20-cv-10641
14 Plaintiff, COMPLAINT FOR:
15
vs. 1. Declaratory Judgment of Invalidity of
16 the ʼ980 Design Patent;
SHENZEN MAITEWEI 2. Declaratory Judgment of
17 INVESTMENT AND
Noninfringement of the ʼ980 Design
18 DEVELOPMENT CO., LTD., dba Patent;
MOUNT DOG, and DOES 1-10, 3. Declaratory Judgment of
19 inclusive,
Unenforceability of the ʼ980 Design
20 Patent;
Defendants.
4. Intentional Interference with
21
Prospective Economic Advantage;
22 and
23 5. Unfair Competition Under California
Business and Professions Code
24 § 17200, et seq.
25
[JURY TRIAL DEMANDED]
26
27
28
COMPLAINT FOR DECLARATORY JUDGEMENT OF PATENT INVALIDITY

1 PRELIMINARY STATEMENT
2 Plaintiff EMART INTERNATIONAL, INC. (“EMART”) brings this action
3 against Defendant SHENZHEN MAITEWEI INVESTMENT AND
4 DEVELOPMENT CO., LTD., dba MOUNT DOG (“Maitewei”), for declaratory
5 judgment of (1) invalidity of U.S. Design Patent No, D881,980 (the “ʼ980 patent”)1,
6 (2) noninfringement of the ʼ980 patent, and (3) unenforceability of the ʼ980 patent;
7 (4) common law intentional interference with prospective economic advantage; and
8 (5) unfair competition under California Business and Professions Code § 17200, et
9 seq., and for such other relief as the Court deems just and proper.
10 THE PARTIES
11 1. Plaintiff EMART is a company organized under the laws of the state of
12 California with a place of business at 17800 Castleton Street, Suite 180, City of
13 Industry, CA 91748, in this judicial district.
14 2. On information and belief, Maitewei is a Chinese company having a
15 place of business at B003, 2F, Building 4 (International Electronic City), No. 2070
16 Shennan Middle Road, Fuqiang Community, Huaqiang North Street, Futian District,
17 Shenzhen, China.
18 3. On information and belief, Maitewei also operates a facility or place of
19 business at 12207 Los Nietos Road, Suite D, Santa Fe Springs, CA 90670, in this
20 judicial district.
21 4. On information and belief, Maitewei advertises and sells its products
22 using the “Mount Dog” brand name, and owns, operates, or otherwise controls the
23 “mountdogs.com” website. Shenzhen Maitewei Investment and Development Co.,
24 Ltd. is named in an “About Us” paragraph on that site and is listed in the site’s
25 Privacy Policy. Attached as Exhibit B is a true and correct copy of the Mount Dog
26 website home page; attached as Exhibit C is a true and correct copy of the site’s
27
28 1
A true and correct copy of the ʼ980 patent is attached as Exhibit A.
1
1 privacy policy, showing Mount Dog has an overseas address at 12207 Los Nietos
2 Road, Suite D, Santa Fe Springs, California 90670-6135.
3 5. On information and belief, Maitewei also owns, operates, or otherwise
4 controls a storefront on Amazon.com (“Amazon”), where it advertises and sells its
5 products using the “Mount Dog” brand name. Attached as Exhibit D is a true and
6 correct copy of a printout of the “MountDog” Amazon store.
7 6. The business address shown on the “MountDog” Amazon seller profile
8 is B001, 2F, Building 4, No. 2070, Shennan Middle Road, Fuqiang Community,
9 Huaqiang North Street, Futian District, Shenzhen, Guangdong 518000, China. A
10 true and correct copy of “MountDog” Amazon seller profile showing this address is
11 attached as Exhibit E.
12 JURISDISCTION AND VENUE
13 7. This court has subject matter jurisdiction over EMART’s request for
14 declaratory judgment under the Declaratory Judgment Act, 28 USC §§ 2201 and
15 2202. This action arises under the patent laws of the United States, 35 U.S.C. §§
16 100, et seq., which are within the subject matter jurisdiction of this Court under 28
17 U.S.C. §§ 1331 and 1338(a). This Court has supplemental jurisdiction over claims
18 asserted under California statutes and common law under 28 U.S.C. § 1367.
19 8. Personal jurisdiction exists over Maitewei because it has a place of
20 business in this judicial district, namely its facility in Santa Fe Springs, CA.
21 Personal jurisdiction further exists over Maitewei under at least under California’s
22 long arm statute, California Code of Civil Procedure § 410.10. Maitewei has
23 committed tortious acts of unfair competition and interference with prospective
24 economic advantage, which have caused and continued to cause injury to EMART
25 within the State. Maitewei has established minimum contacts with the forum such
26 that the Court’s exercise of jurisdiction will not offend traditional notions of fair
27 play and substantial justice. Maitewei conducts business throughout the United
28
2
1 States and actively transacts businesses in this judicial district, including the sale of
2 its products through the internet to California Residents.
3 9. Venue is proper in this judicial district pursuant to 28 U.S.C.
4 §§ 1391(b) and (c). Venue is proper in this district pursuant to 28 U.S.C. § 1391
5 because a substantial portion of the events giving rise to the claims alleged herein
6 occurred within this district, and personal jurisdiction exists over Defendants within
7 this district.
8 FACTUAL BACKGROUND
9 10. EMART sells high quality photography products including
10 photography softbox lighting products.2 EMART is top seller for photography
11 lighting and softbox products on Amazon.
12 11. On information and belief, EMART and Maitewei are competitors in
13 the business of selling photography softbox products, including on Amazon.
14 12. Amazon is an important sales channel for EMART’s photography
15 lighting and softbox products.
16 13. On Amazon, an IP rights holder (i.e., a patent owner) may file an
17 infringement notice against a product listing. Amazon will then remove the product
18 listing, and the seller or merchant has the burden of convincing Amazon to reinstate
19 it. According to its published policies, Amazon will reinstate a listing if the seller
20 provides a license to the allegedly infringed IP, or the rights holder retracts the
21 notice, or the seller provides a “court order demonstrating that your product is non-
22 infringing or that the asserted patent is invalid or unenforceable.” See Exhibit F
23 (true and correct copy of Amazon’s “Intellectual Property Policy for Sellers”).
24 Amazon make no guarantees of when (or if) a listing will be reinstated, even if the
25
26 2
A “softbox” is an enclosure for a light source that has reflective interior sides and a
27 front diffuser. It softens harsh lighting and reduces or eliminates shadows.
Softboxes are commonly used in studio product and portrait photography, and when
28 shooting “first-person” videos for websites such as YouTube or TikTok.
3
1 seller provides evidence or documentation showing that there is no infringement or

2 that the patent is invalid.3
3 14. On information and belief, on or before October 23, 2020, Maitewei
4 submitted infringement notices to Amazon alleging that EMART products infringed
5 the ʼ980 patent.
6 15. On information and belief, Maitewei has also submitted numerous
7 infringement notices to Amazon for many other competitors’ products including
8 softbox lighting products, on the basis that these products purportedly infringe
9 patents like the ʼ980 patent.
10 16. On October 23, 2020 and November 12, 2020, EMART received
11 infringement notices from Amazon that certain of its product listings had been
12 removed because they had been accused of infringing the ʼ980 patent by the “rights
13 owner”.
14 17. Maitewei is listed as the assignee (i.e., the “rights owner”) on the face
15 of the ʼ980 patent.
16 18. On October 24, 2020, EMART attempted to communicate via Email
17 with Maitewei using the email address in the infringement notice. In response,
18 Maitewei demanded a non-negotiable license fee in the amount of RMB
19 $2,000,000.00 (approximately USD $305,036.14 based on the exchange rate as of
20 November 17, 2020), in order for Maitewei to withdraw the infringement notice to
21 Amazon and license EMART for sales of products covered by the ‘980 Patent in the
22 United States.
23
24
3
25 A court in this district recently observed that Amazon’s policies place the burden
on the accused infringer, and absent court-ordered remedies, “allow anyone to
26 effectively shut down a competitor's business on [Amazon] simply by filing the
27 notice that the [competitor's] product allegedly infringes.” See Beyond Blond
Prods., LLC v. Heldman, No. CV205581DSFGSJX, 2020 WL 4782745, at *9 (C.D.
28 Cal. Aug. 14, 2020).
4
1 19. On information and belief, Maitewei chose to wrongfully accuse

2 EMART of infringing the ʼ980 patent during the peak holiday sales period to cause
3 as much business and reputational harm to EMART as possible. Maitewei’s conduct
4 is predatory, anti-competitive and takes unfair advantage of the business practices
5 established by Amazon to minimize its own exposure, at the expense of businesses
6 and/or merchants who operate in good faith.
7 20. Maitewei accused three of EMART’s most popular product packages
8 on Amazon (which include softboxes and several other components) of infringing
9 the ʼ980 patent:
10 • The “Emart 8.5 X 10 Ft Backdrop Support System, Photography Video
11 Studio Lighting Kit Umbrella Softbox Set Continuous Lighting For Photo Studio
12 Product, Portrait And Video Shooting Photography” offered for sale on Amazon
13 with an Amazon Standard Identification Number (“ASIN”) of B07GTBWHJH (the
14 “EMART Backdrop Kit”). A true and correct copy of an Amazon webpage on
15 which the EMART Backdrop Kit is offered for sale is attached as Exhibit G; true
16 and correct full-size copies of the product images on page 1 of Exhibit G are
17 attached as Exhibit J.
18 • The “Emart Softbox Lighting Kit Photo Studio Equipment Photography
19 Continuous Lighting 105W E27 Socket 50 x 70cm Reflectors 5500K Light Bulbs
20 for Product Portraits Shoot” offered for sale on Amazon with an ASIN of
21 B085973RRH (the “EMART Softbox Kit”). A true and correct copy of an Amazon
22 webpage on which the EMART Softbox Kit is offered for sale is attached as Exhibit
23 H; true and correct full-size copies of the product images on page 1 of Exhibit H are
24 attached as Exhibit K.
25 • The “Emart 8.5 x 10 ft Background Support System Kit,5500K
26 Backdrop Photography Continuous Photo Studio Light System with 24" x 24" Soft
27 Box for Photo Studio Product Portrait and Video Shooting Photography” offered for
28 sale on Amazon with an ASIN of B089SJB2C9 (the “Emart Background Kit”),
5
1 collectively with the EMART Backdrop Kit and the EMART Softbox Kit, the
2 “EMART Softbox Products”). A true and correct copy of an Amazon webpage on
3 which the EMART Background Kit is offered for sale is attached as Exhibit M; true
4 and correct full-size copies of the product images on page 1 of Exhibit M are
5 attached as Exhibit N.
6 21. Maitewei’s very allegations and accusations, however, demonstrate that
7 the ʼ980 patent is invalid because the EMART Backdrop Kit was publicly disclosed,
8 offered for sale, and in use by no later than October 19, 2018. See Exhibit O (listing
9 sales on Amazon during October, 2018). The EMART Backdrop Kit is invalidating
10 prior art to the ʼ980 patent, because the ʼ980 patent claims a priority date of
11 December 19, 2019, the date that Maitewei filed the patent application that later
12 issued as the ʼ980 patent—over a year after the EMART Backdrop Kit was already
13 on sale and in use.4
14 22. The ʼ980 patent is also rendered invalid by one of Maitewei’s own
15 products, marketed as “MOUNTDOG Softbox Lighting Kit Photography Studio
16 Light 20”x28” Professional Continuous Light System with E27 95W Bulbs 5500K
17 Photo Equipment for Filming Model Portraits Advertising Shooting” with an ASIN
18 of B07G32T189 (the “Maitewei Softbox Product”) was available for sale on
19 Amazon as of September 11, 2018, more than one year before the December 19,
20 2019 filing date of the ’980 patent. Attached as Exhibit I is a true and correct copy
21 of a printout of an Amazon webpage on which B07G32T189 is offered for sale; true
22 and correct full-size copies of the product images on page 1 of Exhibit I are attached
23 as Exhibit L.
24
25
26 4
35 U.S.C. § 102 provides in pertinent part that “A person shall be entitled to a
27 patent unless … the claimed invention was patented, described in a printed
publication, or in public use, on sale, or otherwise available to the public before the
28 effective filing date of the claimed invention.” 35 U.S.C. § 102(a)(1).
6
1 23. Therefore, the ʼ980 patent is invalid at least because of the prior public
2 disclosure, sale and use of the EMART Backdrop Kit and/or the Maitewei Softbox
3 Product. The ʼ980 patent fails to satisfy one or more of the conditions of
4 patentability set forth in Title 35 of the United States Code including but not limited
5 to 35 U.S.C. §§ 101, 102, 103, 112, and/or 171 and the related rules, regulations,
6 and laws.
7 24. In addition, none of the EMART Softbox Products infringes the ʼ980
8 patent (even if it were valid). For example, the EMART Softbox Products differ in
9 several ways from the claim of the ʼ980 patent, any one of which is sufficient to
10 demonstrate noninfringement—(1) the softbox itself has a different shape; (2) the
11 rear of the lightbulb holder has a different shape; (3) the height adjustment
12 mechanism on the stand uses cam clamps or levers, differently shaped than the
13 claimed knobs; and (4) the inline switch assembly on the power cord has a different
14 shape. No “ordinary observer”—or even a purchaser familiar with softbox
15 products—would be deceived into purchasing EMART’s products believing them to
16 embody the design claimed in the ʼ980 patent.
17 25. EMART plans and intends to continue to sell and promote its products.
18 But as discussed above, Maitewei has demonstrated its intent to enforce its (invalid)
19 ʼ980 patent. EMART is under a reasonable apprehension that Maitewei will sue
20 EMART, its customers, retailers and/or distributors for patent infringement, or that
21 Maitewei will continue to file baseless infringement notices with Amazon.
22 26. As a result of EMART’s softbox products being removed from
23 Amazon, EMART has suffered substantial damages and is continuing to suffer
24 substantial and potentially irreparable damages for each and every day that its
25 products are unavailable for purchase on Amazon.
26 27. For at least the reasons above, an actual and justiciable controversy has
27 arisen and exists between the parties regarding the validity of the ʼ980 patent and
28
7
1 regarding EMART’s alleged infringement of the ʼ980 patent by making, importing,

2 and selling its products including the EMART Softbox products.
3 FIRST CAUSE OF ACTION
4 (Declaratory Judgment of Invalidity of the ʼ980 Patent)
5 28. EMART incorporates the foregoing paragraphs by reference as though
6 fully set forth herein.
7 29. The design purportedly claimed in the ʼ980 patent does not qualify for
8 patent protection. For example and without limitation, the ʼ980 patent is invalid as
9 anticipated and/or obvious in view of the prior public use and sale of the EMART
10 Backdrop Kit and/or the Maitewei Softbox Product, at least because the EMART
11 Backdrop Kit was on sale at Amazon before December 19, 2019, and the Maitewei
12 Softbox Product was on sale at Amazon more than one year before December 19,
13 2019, the effective filing date of the application that became the ʼ980 patent.
14 30. As a result of Maitewei asserting the invalid ʼ980 patent via
15 infringement notices on Amazon, EMART has suffered damages that are
16 substantial, continuing, and potentially irreparable.
17 31. An actual controversy exists between EMART and Maitewei as to
18 whether the ʼ980 patent is valid.
19 32. EMART seeks and is entitled to a declaratory judgment that the ʼ980
20 patent is invalid and void for failure to satisfy one or more conditions of
21 patentability set forth in 35 U.S.C. §§ 101, 102, 103, 112 and/or 117. Without such
22 declaratory relief, EMART is and will continue to be irreparably harmed and
23 damaged.
24 SECOND CAUSE OF ACTION
25 (Declaratory Judgment of Noninfringement of the ʼ980 Patent)
28
8
1 34. EMART has not and does not infringe the ʼ980 patent directly or
2 indirectly, either literally or under the doctrine of equivalents, by making, importing,
3 or selling the EMART Softbox Products, for at least the reasons set forth above.
4 35. As a result of Maitewei baselessly asserting that EMART infringes the
5 ʼ980 patent via infringement notices on Amazon, EMART has suffered damages
6 that are substantial, continuing, and potentially irreparable.
7 36. There is an actual controversy, within the meaning of 28 U.S.C. §§2201
8 and 2202, between EMART and Maitewei concerning noninfringement of the ʼ980
9 patent.
10 37. EMART is therefore entitled to a declaratory judgment that it has not
11 and does not infringe the ʼ980 patent, directly or indirectly, literally or under the
12 doctrine of equivalents.
13 THIRD CAUSE OF ACTION
14 (Declaratory Judgment of Unenforceability of the ʼ980 Patent)
17 39. On December 19, 2019, when Maitewei filed the patent application that
18 later issued as the ʼ980 patent, Maitewei knew that the Maitewei Softbox Product
19 had been available for sale on Amazon since at least September 11, 2018.
20 40. Maitewei was aware of its duty of candor to the USPTO to disclose all
21 known and relevant prior art.
22 41. Maitewei knew that the Maitewei Softbox Product embodied the claims
23 of its patent application.
24 42. Maitewei knew that if the USPTO were aware of the Maitewei Softbox
25 Product, the USPTO would not issue a patent.
26 43. Maitewei made a deliberate decision not to disclose the Maitewei
27 Softbox Product to the USPTO and committed fraud upon the USPTO.
28
9
1 44. Maitewei’s conduct before the USPTO was inequitable, and the ʼ980
2 patent is unenforceable. See Therasense, Inc. v. Becton, Dickinson & Co., 649 F.3d
3 1276 (Fed. Cir. 2011).
4 45. As a result of Maitewei asserting the unenforceable ʼ980 patent via
5 infringement notices on Amazon, EMART has suffered damages that are
6 substantial, continuing, and potentially irreparable.
7 46. An actual controversy exists between EMART and Maitewei as to
8 whether the ʼ980 patent is enforceable.
9 47. EMART seeks and is entitled to a declaratory judgment that the ʼ980
10 patent is unenforceable due to Maitewei’s inequitable conduct before the USPTO.
11 Without such declaratory relief, EMART is and will continue to be irreparably
12 harmed and damaged.
13 FOURTH CAUSE OF ACTION
14 (Intentional Interference with Prospective Economic Advantage)
17 49. EMART and Amazon had an existing and ongoing economic
18 relationship that had the probability of future economic benefit to EMART from
19 consumers purchasing the EMART Softbox Products listed on Amazon.com.
20 50. Maitewei was aware of this relationship between EMART and
21 Amazon.
22 51. On October 23, 2020, Maitewei filed complaints with Amazon in
23 which it knowingly made false and misleading statements that the ʼ980 patent was
24 valid and was infringed by EMART. Maitewei made these statements despite
25 knowing that the ʼ980 patent was invalid based on, for example and without
26 limitation, prior public use and sale of the EMART Backdrop Kit and the Maitewei
27 Softbox Product.
28
10
1 52. Maitewei’s false and misleading statements disrupted EMART’s

2 relationship with Amazon: Amazon disabled the product listing for the EMART
3 Softbox Products, preventing EMART from selling the EMART Softbox Products
4 and causing other economic harm to EMART.
5 53. EMART’s economic harm is proximately caused by Maitewei’s false
6 and misleading statements, and this harm is substantial, continuing, and potentially
7 irreparable.
8 FIFTH CAUSE OF ACTION
9 (Unfair Competition and Deceptive Trade Practices Under
California Business and Professions Code §§ 17200, et seq.)
10
12 set forth fully herein.
13 55. Maitewei has engaged in unfair competition in violation of the
14 California Unfair Competition Law (“UCL”), California Business and Professions
15 Code § 17200 et seq. in one or more of the following ways:
16 a. By engaging in unlawful acts or practices including tortious
17 interference with prospective economic advantage as alleged in
18 EMART’s fourth cause of action, as well as by filing and pursuing in
19 bad faith objectively baseless infringement notices with Amazon
20 asserting that EMART was infringing a valid patent owned by
21 Maitewei, when in fact the ʼ980 patent was invalid, not infringed,
22 and/or unenforceable.
23 b. By filing and prosecuting the patent application that became the ʼ980
24 patent, while knowingly and intentionally withholding from the
25 USPTO disclosure of Maitewei’s own prior art products, such as the
26 Maitewei Softbox Product, in order to mislead the USPTO into issuing
27 the ʼ980 patent.
28
11
1 c. By engaging in unfair acts and practices that significantly threaten or

2 harm competition from EMART and other parties seeking to list the
3 same or substantially similar softbox lighting products on Amazon.
4 Maitewei has systematically filed infringement notices against
5 numerous competitors, attempting to eliminate competition from and
6 unfairly monopolize the marketplace.
7 56. As a result of Maitewei’s unfair competition, EMART has been injured
8 in fact and lost money or property, including without limitation lost sales of the
9 EMART Softbox Products.
10 57. Maitewei’s conduct has caused damages to EMART that are
11 substantial, continuing, and potentially irreparable. EMART and other parties
12 similarly situated have already sustained economic harm and continue to face the
13 real and imminent threat of continuing and future harm from Maitewei’s unfair
14 competition.
15 58. EMART is entitled to injunctive relief enjoining the unfair competition,
16 restitution and other appropriate equitable relief under UCL §§ 17203-04.
17 PRAYER FOR RELIEF
18 WHEREFORE, Plaintiff EMART respectfully request that the Court:
19 1. Issue a declaration that the claims of the ʼ980 patent are invalid;
20 2. Issue a declaration that EMART has not infringed and is not infringing,
21 either directly or indirectly, the claims of the ʼ980 patent;
22 3. Issue a declaration that the ʼ980 patent is unenforceable;
23 4. Order that Maitewei and any of its agents are restrained and enjoined from
24 filing or pursuing any infringement notices on Amazon.com claiming that
25 any of EMART’s products infringe the ʼ980 patent;
26 5. Order that Maitewei is restrained and enjoined from further unfair
27 competition;
28
12
1 6. Award to EMART its damages attributable to Maitewei’s unwarranted

2 infringement notices on Amazon and in an amount equal to compensate
3 EMART for its economic losses;
4 7. Award to EMART restitution in an amount equal to the value of the money
5 or property taken by Maitewei from EMART or in which EMART has a
6 vested interest;
7 8. Award to EMART its costs in this action against Maitewei;
8 9. Find that this is an exceptional case under 35 U.S.C. § 285;
9 10. Award to EMART its reasonable attorneys’ fees under 35 U.S.C. § 285; and
10 11. Order such other and further relief as this Court may deem just and proper.
11
12 Dated: November 20, 2020 By: /s/ Alan C. Chen
Alan C. Chen
13 David L. Simson
14 RIMON, P.C.
2029 Century Park East, Suite 400N
15 Los Angeles, California 90067
16
Tony W. Wong
17 D&R I.P. Law Firm, APC
108 N. Ynez Avenue, Suite 213
18 Monterey Park, CA 91754
19 Attorneys for Plaintiff,
EMART INTERNATIONAL, INC.
20
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13
1 DEMAND FOR JURY TRIAL

2
Pursuant to Federal Rule of Civil Procedure 38, Plaintiff EMART
3
INTERNATIONAL, INC. hereby demand a trial by jury on all of the claims in their
4
complaint that are triable by a jury.
5
6
Dated: November 20, 2020 By: /s/ Alan C. Chen
7 Alan C. Chen
David L. Simson
8
RIMON, P.C.
9 2029 Century Park East, Suite 400N
Los Angeles, California 90067
10
11 Tony W. Wong
D&R I.P. Law Firm, APC
12 108 N. Ynez Avenue, Suite 213
Monterey Park, CA 91754
13
Attorneys for Plaintiff,
14 EMART INTERNATIONAL, INC.
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your Account, you may be asked to enter certain information, such as: your
name, avatar, age, gender, address, telephone number and email address.
• Customer Support: When you contact us, you can provide us with
information about your use of the Services, including information about the
Mountdog electronics and/or consumer products (“Products”) that you own
and contact details, so that we can provide customer support. For example,
11/17/2020 Privacy 11/20/20
you can send an email to Customer Support that contains information about
our Mountdog H10 Recoloring performance, and other issues.
• Payment information; Third-Party Payment Processor: We use a third-party
payment processor (currently Paypal) to assist in securely processing your
personally identifiable payment information. When you place an order through
the Services, the credit card information that you provide is encrypted and
transmitted directly to Paypal. We do not store your credit card information
and do not control and are not responsible for Paypal or its collection or use
of your information. You may find out more about how Paypal stores and
uses your credit card information by accessing Paypal’s privacy policy.
Product Usage Information
• Product monitoring: We collect information about how you set up and use
our Products, such as: functions used; operations performed; time, frequency,
and duration of your activities within the Services, and any unique identifiers
associated with your Product. For example, we collect the time period you
connected the Product to the Application and the time of the last connection,
as well as what operations you used in the Account, settings, and other
functions in our Products.
• Services utilization: We collect information that our Products store and
report as a part of the Services, such as: when you use any Bluetooth wireless
11/17/2020 Privacy 11/20/20
headphones or earbuds, your Bluetooth name will be kept on the products to
make convenient pairing for your next use.
Device and Other Automatically Collected Information
• Device properties and operations: We collect certain information from and
about your smartphone, tablet, or personal computer (“Device”), such as:
Device number, model, hardware and software version, signal intensity,
Internet Protocol (IP) addresses, and other information. We also collect
information about the operations you perform on the Device, such as time,
frequency, and duration of use.
• Device signals: We collect information that your Device sends out or receives
to tailor the Services to our users in different regions, such as: geo-location, IP
addresses, and external hardware information from your Device about
surrounding Wi-Fi access points, beacons, and cell towers. You can enable
and disable communicating such information to us by adjusting your Device
security and privacy settings.
• Server logs: A server log is a list of the activities that a server performs.
Mountdog’s servers automatically collect and store in server logs certain
information, such as: your search queries, IP addresses, hardware settings,
browser type, browser language, the date and time of your request, referral
URL, and certain cookies that identify your browser or Account.
11/17/2020 Privacy 11/20/20
• Web beacons: A web beacon (also called a pixel tag or clear GIF) is
computer code that communicates information from your Device to a server.
Some of Mountdog’s Services and communications may contain embedded
web beacons that allow a server to read certain types of information from
your Device, such as: the number of people who have viewed certain content,
when you opened an email message, and your Device IP address. Web
beacons help Mountdog develop statistical information to provide better and
more personalized content.
• Cookies: Cookies are small text files that are sent to or accessed from your
web browser or your computer’s hard drive. A cookie typically contains the
name of the domain (internet location) from which the cookie originated, the
“lifetime” of the cookie (i.e., when it expires) and a randomly generated unique
number or similar identifier. A cookie also may contain information about
Device, such as: user settings, browsing history, and activities conducted
while using the Services.
——————————————————————
Our Services use the following cookies:
o Strictly necessary cookies, which are required for the operation of the
Services. Without them, for example, you would not be able to use your
Account.
11/17/2020 Privacy 11/20/20
o Analytical/performance cookies, which allow Mountdog to recognize and
count the number of visitors, learn how visitors navigate the Services, and
improve the Services.
o Functionality cookies, which Mountdog uses to recognize you when you
return to the Services.
To learn more about cookies and web beacons, visit
www.allaboutcookies.org.
——————————————————————
• Analytics services: Mountdog also uses analytics services, such as Google
Analytics, to collect and analyze your information. Generally analytics services
do not identify individual users. Many analytics services allow you to opt out
of data collection. For example, to learn more about Google Analytics
practices and to opt out, visit www.google.com/settings/ads or by
downloading the Google Analytics opt-out browser add-on at
https://tools.google.com/dlpage/gaoptout.
California Do Not Track Disclosure
Unless legally required, we do not commit to honoring “Do Not Track” signals
in your browser because honoring it would prevent much of the tracking and
disclosures described in this Privacy Policy.
11/17/2020 Privacy 11/20/20
Third-Party Information
We collect and use information obtained from Facebook, Google, Amazon,
and other accounts you use to login to the Services (“Third-Party Accounts”),
such as: your name, your user name or handle, birth date, picture, and other
details you may have on your Third-Party Account profile. We do not have
access to your Third-Party Account passwords.
Children’s and Minors’ Privacy
• About the protection of juveniles’ personal information. The company
attaches great importance to the protection of juveniles’ personal information.
If you are a juvenile under the age of 16 (according to the legal requirements
of EU member states, the minimum age must not be less than 13 years old),
you must obtain written consent from your parent or legal guardian before
using this product and service. This product and service will protect the
personal information of juveniles in accordance with the relevant EU laws and
regulations.
• The Services are not directed to or intended for use by minors. Consistent
with the requirements of applicable law, if we learn that we have received any
information directly from a minor, we will take steps to delete or destroy that
information. California minors: While the Services are not intended for anyone
under the age of 18, if you are a California resident who is under age 18 and
11/17/2020 Privacy 11/20/20
you are unable to remove publicly-available content that you have submitted
to us, you may request removal by contacting us at: info@mountdogs.com.
When requesting removal, you must be specific about the information you
want removed and provide us with specific information, such as the URL for
each page where the information was entered, so that we can find it. We are
not required to remove any content or information that: (1) federal or state law
requires us or a third party to maintain; (2) was not posted by you; (3) is
anonymized so that you cannot be identified; (4) you don’t follow our
instructions for removing or requesting removal; or (5) you received
compensation or other consideration for providing the content or information.
Removal of your content or information from the Service does not ensure
complete or comprehensive removal of that content or information from our
systems or the systems of our service providers. We are not required to delete
the content or information posted by you; our obligations under California law
are satisfied so long as we anonymize the content or information or render it
invisible to other users and the public.
Can you withdraw your consent to our collection and/or use of information?
You may withdraw your consent to collect, use, and/or disclose your
personally identifiable information held or controlled by us by submitting a
request to info@mountdogs.com or following the below directions on deleting
your Account. Based on the extent to which you withdraw your consent, the
11/17/2020 Privacy11/20/20
Case 2:20-cv-10641 Document 1-3 Filed Policy - Mount Page
Dog 10 of 15 Page ID #:49
functionality of your Account, Products, and Services may be affected,
including loss of access or use of your Account, Products, and/or Services.
What do we use your information for?
Any of the information we collect from you may be used in one of the
following ways:
• To process transactions: We use your information to process payments you
make through the Services.
• To send periodic emails: The email address you provide for order processing
or for your Account may be used to send you information and updates
pertaining to your order, in addition to receiving occasional company news,
updates, related Product or Services information, including sending you
updates to our terms and policies and other important messages from time
to time. We may also send you marketing and promotional communications
we believe might be relevant to your interests.
• Our service: We operate and provide services, including providing customer
support and improving, repairing, and customizing the Services. We use your
information to understand how people use and to evaluate and improve the
Services. Furthermore, we use your information to research, develop, and test
new services, Products, and features, as well as perform troubleshooting
activities. We also use your information to respond to you when you contact
11/17/2020 Privacy11/20/20
us. We use cookies to operate, provide, improve, understand, and customize
the Services.
• Security and privacy: We use your information to verify Account details and
activity. We also use your information to promote the security and privacy of
the Services, such as investigating suspicious activities or violations of our
terms.
• Advertising and business information: We may show advertisements to you
and others for our Products and third-party products based on the
information we have collected from you, such as: what you have installed,
accessed, used, and purchased.
• Accessing Third-Party Accounts: We use your information, including Third-
Party Account information, to permit your Products and the Services to
access Third-Party Accounts. These Third-Party Accounts may allow you to
share personal information through our Services, such as Facebook posts or
pictures. Because this kind of information can be public, you should exercise
care in what you choose to submit to Third-Party Accounts. Please adjust
your Third-Party Account privacy settings appropriately.
How is this information shared?
• Third-party providers: We share your information with third-party providers
that we work with to help us operate, provide, analyze, improve, understand,
11/17/2020 Privacy11/20/20
customize, support, and market the Services.
• Third-party services: When you use third-party services, such as through
Third-Party Accounts that integrate with the Products and Services, they may
receive your information. When you use third-party services, their own terms
and privacy policies will apply to your use of these services.
• Regulatory and legal issues: We may also release your information to third
parties when we believe it is appropriate to comply with the law, enforce our
terms and policies, or protect ours or others’ rights, property, or safety.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your
information when you place an order or enter, submit, or access your
information. We offer the use of a secure server. All supplied personally
identifiable payment information is transmitted via Secure Socket Layer (SSL)
technology. After a transaction, your credit card information will not be stored
on our servers.
How can you manage information about you, including your Account?
We provide you with the ability to review, manage, or delete your information.
• Changing your email, nickname, and more: You can review and change your
Account profile information by logging in to your Account and visiting your
11/17/2020 Privacy11/20/20
Account settings page.
• Unsubscribe: If at any time you would like to manage your communications
settings, such as unsubscribe from receiving emails, we include detailed
unsubscribe instructions at the bottom of each email. You may also
unsubscribe by logging in to your Account and visiting your Account settings
page.
• Deleting your Account: If you want to delete your Account, you may do so on
your Account settings page. Deleting your Account will remove the personally
identifiable information associated with your Account.
How long will the data be stored?
We store your information until we no longer need it to provide the Services,
as described in this Privacy Policy, or until you delete your Account as
described above, depending on which comes first.
Third-Party Links
Occasionally, at our discretion, we may include links to third-party websites on
our Services. These third-party websites have separate and independent
privacy policies. Please use these third-party websites with caution. We have
no responsibility or liability for the content and activities of these linked
websites.
11/17/2020 Privacy11/20/20
Changes to our Privacy Policy
Mountdog reserves the right to revise and update this Privacy Policy from
time to time. All changes are effective immediately when we post them, as
dated above, and apply to the Services thereafter. Your continued use of the
Services after the time the changes are posted will indicate your acceptance
of those revised changes, so please check this Privacy Policy periodically for
updates.
How can you contact Mountdog with questions?
If you have any questions or concerns, there are a few ways you can contact
us.
Email Us: info@mountdogs.com
Services
Ring Light
SoftBox
Overseas warehouse
address：12207 LOS NIETOS Backdrop stand
RD STE D SANTA FE
Accessories
11/17/2020 Privacy11/20/20
SPRINGS, CA 90670-6135 Privacy-policy
United States
Transportation
B2B: policy
suppliers@mountdogs.com
Return & Exchange
SERVICE: Policy
info@mountdogs.com
Free-product-
Phone: 0755-85270587 testing
   
© Copyright 2012 – 2020 | Mount Dog by AllisMen | All rights reserved | Powered by Mount Dog
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11/17/2020 Case 2:20-cv-10641 Document 1-4Amazon.com:
Filed 11/20/20
MOUNTDOG: Page
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MOUNTDOG
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MountDog 14" Ring Light

$
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Dear Customer,
Customer Service Phone: 1-892-847-
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Your suggestion will always be listened.
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Detailed Seller Information
Business Name:ailaisimanshenzhenkejiyouxiangongsi
Business Address:
B001, 2F, Building 4, No. 2070, Shennan Middle Road,
Fuqiang Community, Huaqiang North Street, Futian District,
Shenzhen
Guangdong
518000
CN
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“ My only complaint is that the assembly directions are not that clear when it
30 90 12 Lifetime
comes to raising the height from the leg portion. ” days days months
By Barbara B on November 17, 2020. Positive 100% 100% 96% 98%
“ Quick delivery, good price ” Neutral 0% 0% 1% 1%
By Judy Chitwood on November 17, 2020. Negative 0% 0% 3% 2%
“ Great quality and perfect size ” Count 59 160 956 2,463
By Palmeira on November 17, 2020.
“ Seems to work great! ”
By David Sherrill on November 17, 2020.
“ Ordered the product Thursday evening received it Saturday. ”
By Vance T. on November 17, 2020.
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11/17/2020 Case 2:20-cv-10641 Document
Intellectual1-6 Filed
Property Policy11/20/20 PageSeller
for Sellers - Amazon 2 of 6 Page ID #:65
Central
English
English Sign in Sell on Amazon
This article applies to selling in: United States
Help / Policies, agreements, and guidelines / Program Policies / Intellectual Property

Policy for Sellers
Intellectual Property Policy for

Sellers
This policy provides an overview of intellectual property (IP) rights and some
common IP concerns that might arise when selling on Amazon. When you
sell on Amazon:
You must comply with all federal, state, and local laws and Amazon
policies applicable to your products and product listings
You may not violate the IP rights of brands or other rights owners
Violating this policy may result in loss of selling privileges or other legal
consequences.
Important: This policy is not legal advice. You should consult a lawyer if
you have a specific question about your IP rights or the IP rights of
others.
There are 3 main types of IP rights:
Copyrights are legal protections for original works of authorship

Trademarks are legal protections for a word, symbol, design, or
combination of the same that a company uses to identify goods and
services
Patents are legal protections for inventions
Amazon’s IP enforcement
Responding to an IP infringement notice. If you receive a notice or
warning for infringement and you believe the rights owner or Amazon
https://sellercentral.amazon.com/gp/help/external/201361070 1/5
11/17/2020 Case 2:20-cv-10641 Document
Central
made an error, you may appeal or dispute the claim.
Type of Actions you may take

notice or
warning
For a Reply to the notification you received and let us know that
product you you have never listed the reported product. We will
never listed investigate to determine if an error occurred.
on Amazon
If you have If you have a license or other agreement that allows you to
an use the IP identified in the notice, contact the rights owner
established who submitted the complaint to request a retraction. Your
relationship content may be reinstated if we receive a retraction from
with the the rights owner.
rights owner
Trademark Use the Account Health Dashboard present in your selling

or account to provide an invoice or Order ID that
Counterfeit demonstrates the authenticity of the product. We will then
infringement re-evaluate the notice and your content may be reinstated.
on the
product or
packaging
Trademark Modify the product detail page or pages to ensure they do

or not infringe the trademark and then submit your appeal
Counterfeit by going to the Account Health page.
infringement
on the OR
product
detail page If you believe your listing was removed in error, you may
submit your appeal by going to the Account Health page.
Please provide supporting documentation (e.g., letter of
authorization, licensing agreement). We will then re-
evaluate the notice, and your content may be reinstated.
Patent Reply to the notification you received, with specific

infringement reasons as to why you believe a mistake was made. You
may also provide a court order demonstrating that your
product is non-infringing or that the asserted patent is
invalid or unenforceable.
11/17/2020 Case 2:20-cv-10641 Document
Central
Type of Actions you may take

notice or
warning
Copyright You may file a counter-notice under the Digital Millennium

infringement Copyright Act. The counter-notice must be sent to the
email provided in your copyright warning and must
include:
Your physical or electronic signature. You can sign
electronically by typing your name with an indication
that it is intended to be a signature: “/s/ Seller Name.”
Identification of the material that has been removed or
to which access has been disabled, and the specific
location where the material appeared before it was
removed or access was disabled. An ASIN is generally
sufficient.
A statement under penalty of perjury that you have a
good-faith belief that the material was removed or
disabled as a result of error or misidentification of the
material to be removed or disabled.
Your name, address, and telephone number, and a
statement that you consent to the jurisdiction of the
Federal District Court for the judicial district in which
your seller address is located; or, if you are located
outside the United States, to the jurisdiction of the
United States District Court for the Western District of
Washington, and that you will accept service of process
from the person who provided notification of alleged
copyright infringement or an agent of such person.
Multiple warnings of IP infringement. If you have received multiple

warnings of IP infringement and you believe you are selling non-infringing
products, submit an appeal via Seller Central with the following
information:
A list of the allegedly infringing ASINs and at least one of the following,
as applicable:
a. Invoices proving the authenticity of your products (you may remove

pricing information); OR
b. Amazon order IDs demonstrating product authenticity; OR
11/17/2020 Case 2:20-cv-10641 Document
Central
c. An authorization letter from the rights owner (cannot be a forwarded

email); OR
d. A court order finding that your product does not infringe the asserted
IP, or that the asserted IP is invalid or unenforceable.
Account suspension. If your account has been suspended because of

notices of IP infringement against your products or content, you can
provide us with a viable Plan of Action. To learn more, refer to Create a
plan of action to reinstate selling privileges
You should send your Plan of Action via your account dashboard or reply
to the account suspension notification that you received. We will evaluate
your Plan of Action and determine if your account may be reinstated. Note
that Amazon terminates the accounts of repeat infringers in appropriate
circumstances.
Sellers are expected to follow the law. Amazon takes claims of IP

infringement seriously. Even if a seller is infringing IP without knowledge,
we will still take action and the seller’s account might receive a warning or
be suspended. You should consult an attorney for help to ensure that you
have the right procedures in place to prevent IP infringement.
Intellectual Property Policy for Sellers

Intellectual Property Policy for Sellers - FAQ about Copyrights
Intellectual Property Policy for Sellers - FAQ about Trademarks
Intellectual Property Policy for Sellers - FAQ about Patents
Need more help?
See more on Seller Central
Visit Seller Forums
11/17/2020 Case 2:20-cv-10641 Document
Central
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Start Selling On Amazon
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11/16/2020 Case 2:20-cv-10641 Document
EMART 1-7
Emart 8.5 X 10 FiledSupport
Ft Backdrop 11/20/20 Page 2 of 6
System: Amazon.co.uk: Page
Camera ID #:71
& Photo
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Subm EMART Emart 8.5 X 10 Currently unavailable.

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11/16/2020 Case 2:20-cv-10641 Document
EMART 1-7
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the height of light stand
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maximize light spread.
Package List, [2] 24"x24"
Softbox, [1] 8.5 x 10ft
Backdrop Stand Support
System, [3] 6x9 ft Muslin
Backdrop(Black, White and
Green), [6]Backdrop Spring
Clamps, [4] Backdrop Clip
Holder, [4] 5500K CFL
Daylight Bulb, [2]Lamp
Holder, [2] 33inch
Translucent Umbrella, [4]
7ft Light Stand, [1] 43" 5 in
1 Reflector. [1] Carrying Bag
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Support System and Background Stand 2.6Mx3M Background Lighting Backdrop Kit - 4 LED Video Light with
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11/16/2020 Case 2:20-cv-10641 Document
EMART 1-7
Camera ID #:73
& Photo
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Find answers in product info, Q&As, reviews
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Product information
Technical Details Additional Information
Item Package Dimensions L x 83.6 x 45.7 x 21.8 ASIN B07GTBWHJH

WxH centimetres
Manufacturer reference EM-ULK45BSK
Package Weight 15.2 Kilograms
Date First Available 18 Jun. 2019
Brand EMART
Customer Reviews 50 ratings
Colour Ligth red 4.5 out of 5 stars
Part number EM-ULK45BSK Warranty & Support
Amazon.com Return Policy: Regardless of your statutory right of

withdrawal, you enjoy a 30-day right of return for many products. For
exceptions and conditions, see Return details.
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Product description
Emart 8.5 x 10 ft Backdrop Support System, Photography Video Studio Lighting Kit Umbrella Softbox Set Continuous Lighting for Photo Studio Product,
Portrait and Video Shooting Photography
Customer Questions & Answers

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Top reviews
4.5 out of 5
11/16/2020 Case 2:20-cv-10641 Document
EMART 1-7
Camera ID #:74
& Photo
50 global ratings Top reviews from United Kingdom
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4 star 16%
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1 star 7%
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11/16/2020 Case 2:20-cv-10641
Emart Softbox Document
Lighting Kit Photo 1-8Photography
Studio Equipment Filed 11/20/20 Page
Continuous Lighting 2 of
105W E279Socket
Page 50 xID #:77
70cm Reflectors 5500K Li…
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Electronics › Camera, Photo & Video › Lighting & Studio › Lighting › Light Controls & Modifiers › Soft Boxes
Subm Emart Softbox Lighting Kit Photo Studio Currently unavailable.

Equipment Photography Continuous Lighting
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105W E27 Socket 50 x 70cm Reflectors Select delivery location
Subm 5500K Light Bulbs for Product Portraits

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Subm Brand: EMART Share
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We don't know when or if this item will be back in stock.
Subm
TURNED YOUR ROOM INTO PHOTO BOOTH - Emart 20" x
28" studio softbox kit is made of professional granular
Subm silver film reflector with nylon soft cover, which softens
hard light and eliminates shadows. Easy to fold and store.
Sandbag bags included in softbox kit to make it more
stable. It is suitable for portrait photography shooting,
Roll over image to zoom in studio video, etc.
ENERGY BULB - Saving bulb-use standard socket, 105W
110V CFL, low working temperature, energy saving, long
service life up to 8000 hours. Provide a good photography
environment for your work. Studio light softbox can be
rotated 210 degrees freely to give you with the best angle
of illumination.
HIGH QUALITY SANDBAG - Has lining rubber with double
zippers, you can put it on the tripod to make soft box
lighting kit more stable. You can use it even outdoors.
NOTE: Sandbag is empty and needs to be filled by yourself,
such as sand and stone.
ADJUSTABLE LIGHT STAND - The light stand can be freely
adjusted from 32 inch to 78 inch. Lock designed makes the
softbox stand not easy to fall and affect your shooting
mood. High-quality aluminum alloy is light but sturdy and
stable. The assembly kit can be completed in about 5
minutes.
PACKING INCLUDE : (2) x 20" x 28" Studio Softbox, (2) x
Light Stand, (2) x 105W CFL Bulb, (2) x Sandbags, (1) x
Carrying Bag. BUY WITH CONFIDENCE: 12 MOUTHS
WARRANTY, 24 HOURS SERVICES, do our best to make you
satisfied.
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11/16/2020 Case 2:20-cv-10641
105W E279Socket
Page 50 xID #:78
Emart 8.5 x 10 ft GEEKOTO Softbox GIJUANRING 2 Packs LED Pixel G1s RGB Video GSKAIWEN L
Backdrop Support Lighting, Video Softbox, Photography Light Light, Built-in 12W Photography
System, Photography Photo Softbox, Studio Dimmable Bi-Color Rechargeable Battery Lighting Kit A
Video Studio Lighting… Lights 51cmx71cm, Ph... Video Studio Lighting… LED Camera Light… Light with Li
50 165 4 1,020
CDN$ 263.13 CDN$ 110.99 CDN$ 128.99 CDN$ 99.99 CDN$ 109
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11/16/2020 Case 2:20-cv-10641
105W E279Socket
Page 50 xID #:79
Product details
Parcel Dimensions : 69.85 x 20.32 x 20.32 cm; 4.24 Kilograms
Date First Available : April 2 2020
Manufacturer : Emartinc
ASIN : B085973RRH
Manufacturer reference : EM-SBK5070
Product Description
Emart Softbox Photography Lighting Studio Lights Kit, 20 x 28'', 1000 Watt Continuous Light Equipment System for
Camera Photo Portrait Video Lighting
11/16/2020 Case 2:20-cv-10641
105W E279Socket
Page 50 xID #:80
Ceramic Mouth Resistance High 5500K CFL Light Bulb Heavy Duty Sandbag 78" Light Stand
Temperature Daylight balanced pure white light, save Material: nylon Aluminum alloy construction
Selection of high temperature ceramics, not energy up to 80%.Equivalent to 450W
incandescent bulb(Total Output: 1000W) Each pouch: 10" x 11" Max height: 78"
easy to aging, insulation property good heat
faster to use longer
Color: Black Min height: 32"
Each sandbag rated for 25lbs Folded height: 29
11/16/2020 Case 2:20-cv-10641
105W E279Socket
Page 50 xID #:81
2 x 78" Professional Quality Aluminum Adjustable Light Stand
Aluminum alloy construction
Solid safety 3 legs stages
Standard top stud(1/4" screw tip on the stem )
Height adjustable: 32" to 78"
2 x Light Holder with Softbox Reflector
Ultimate soften light stream and remove shadow to make perfect shooting
Silver internal face can minimize light loss and maximize light spread
White soft cover strengthens the effect of soft light
- E26/E27 Light bulb holder
Made of high impact plastic and aluminum
On/off switch
210 Degree adjustable angle to control your light
Cord & Plug included
Customers who bought this item also bought Page 1 of 11
11/16/2020 Case 2:20-cv-10641
105W E279Socket
Page 50 xID #:82
Emart Full Spectrum Emart 8.5 x 10 ft Photo Heavy Duty Muslin Neewer 6 x 9FT / 1.8 x Julius Studio
Light Bulb, 2 x 105W Backdrop Stand, Clamps 4 1/2 inch 6 2.8M PRO Photo Studio Grey Chroma
5500K CFL Daylight for Adjustable Photography Pack 100% Pure Muslin Video Photog
Photography Photo… Muslin Background… 8,623 Collapsible Backdrop… Studio Fabric
704 6,173 CDN$14.99 10,153
2 offers from 4 offers from CDN$30.99 CDN$26.99
CDN$108.99 CDN$109.63

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Emart 8.5 x 10 ft GEEKOTO Softbox Pixel G1s RGB Video GSKAIWEN LED Light RGB LED Vid
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CDN$ 263.13 CDN$ 110.99 CDN$ 99.99 CDN$ 109.99 CDN$ 399
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11/16/2020 Case 2:20-cv-10641
Amazon.com Document
: MOUNTDOG Softbox 1-9
Lighting Kit Filed 11/20/20
Photography Page
Studio Light 20"X28" 2 of 16Continuous
Professional Page Light
ID #:86
System with E27 95…
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MOUNTDOG Softbox Lighting $69.99

Kit Photography Studio Light & FREE Shipping. Details
& FREE Returns
20"X28" Professional
Continuous Light System with Arrives: Monday, Nov 23 Details
Fastest delivery: Friday, Nov 20

E27 95W Bulbs 5500K Photo Order within 20 hrs and 13 mins
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Size: 2 Softbox today with Fast, FREE
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1 Softbox with New Corn
Bulbs Add an Accessory:
$45.99 Adobe Creative Cloud
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1 Softbox with Two Bulbs (Photo... $9.99
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【2 Softbox】: 2pcs 20 x 28inch MountDog softbox
ultimately soften light stream and remove shadow to Add gift options
make perfect shooting; Silver internal face to
Select delivery location
minimize light loss and maximize light spread, with
E27 socket,you can directly connect light
https://www.amazon.com/MOUNTDOG-Photography-Professional-Continuous-Advertising/dp/B07G32T189/ref=sr_1_1?dchild=1&keywords=B07G3… 1/15
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:87
bulbs,fluorescent lamps or slave flash to offer the Add Li
light.
【Energy Efficient Bulbs】: 2 x 95W Energy saving
compact fluorescent spiral bulb, in total to save New & Used (2) from
energy up to 80% and life time approx 10000 hours. $54.99 + FREE Shipping
With 6500K color temperature, providing a good
photographic environment.
【210° Rotatable Head & Adjustable Light Stand】: Share
angle can be 270°adjustable lamp holder, which can
suit for different perfect shooting with 1/4-inch Have one to sell?
Standard Screw Thread Tip. It still comes with 2 Sell on Amazon
adjustable light stand that can be fold to 27'' or
expand to 80''. Make you use it better.
【Suitable for Various Photography】: It is ideal for $10 off coupon
general photography including portraits, group

shots, glamour and product photography. This
softbox is light weight and easy to set up and take
anywhere you want.
【High Quality Material】: Softbox light reflector Brighter content
made of professional particulate silver film reflective & affordability,
660 bi-color LED
fabric with nylon white screen soften the hard light
and eliminate object shadows. One-piece opening Neewer 2 Pieces Bi-color 660 LED Video
and folding easy to use and store. 110-130V bulb Light and Stand Kit…
socket.The soft box can diffuse light and provide the 1,217
soft light beam to eliminate shadows and take $169.69
perfect pictures. Sponsored
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Subm MOUNTDOG Photography Studio Softbox

Lighting Kit Continuous Lighting System
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Subm $99.99
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This item: MOUNTDOG Softbox Lighting Kit Photography Studio Light 20"X28" Professional Continuous Light System… $69.99
Emart Photo Video Studio 10Ft Adjustable Background Stand Backdrop Support System Kit with Carry Bag $48.99
Cheaplights - Heavy Duty Muslin Clamps 4 1/2 inch 6 Pack $7.79
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:88

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Product Description
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:89
MOUNTDOG Studio Light, Photo Equipment Studio Softbox for Portrait Video and Shooting
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:90
Support:
After purchasing our Mountdog Softbox, our team will provide you with the most professional service.If the product has any defects or you have any dissatisfaction, please let us
know and we will solve it for you.
2 x 95W 110V Photo Bulb
210°Rotate
The product with an independent locking knob, the studio softbox can rotate 210° to suit at
different angles perfect photo shoot with 1/4-inch Standard Screw Thread Tip. 3-section column
design, collapsing down to 66cm and extending up to 200cm. Constructed from aluminum alloy,
the light stand features exceptional strength.
Studio Lights
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:91
1 softbox kit 1 softbox kit with new corn 2 softbox kit 3 softbox kit
bulb
Bulbs 95W X 2 80W X 1 95W X 2 95W X 3
Bulb Voltage & Socket 110V,E27 110V,E27 110V,E27 110V,E27
Softbox 1 1 2 3
Softbox Size 20X28 INCH 20X28 INCH 20X28 INCH 20X28 INCH
Stand Height 27IN-80IN 27IN-80IN 27IN-80IN 27.5IN-80IN
Plug Standard US Plug Standard US Plug Standard US Plug Standard US Plug
Rotatable Head 210° 210° 210° 210°
Stand Conecter Original Original Original Original
Carrying bag ✓ ✓ ✓ ✓
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:92
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Customer Rating (4670) (2167) (3958) (4670)
Price $
6999 $
6999 $
6999 $
4699
Shipping FREE Shipping. Details FREE Shipping. Details FREE Shipping. Details FREE Shipping. Details
Sold By MountDog ESDDI STORE Hpusn MountDog
Product information
Size:2 Softbox
Package Dimensions 27 x 8.5 x 8.5 inches Warranty & Support
Item Weight 8.88 pounds Product Warranty: For warranty information about this product, please
click here
ASIN B07G32T189
Feedback
Item model number 8595761916
Customer Reviews 4,670 ratings
4.5 out of 5 stars
Best Sellers Rank #1 in Lighting Soft Boxes
Is Discontinued By Manufacturer No
Date First Available September 11, 2018
Manufacturer MOUNTDOG
Product guides and documents

User Manual [PDF ]
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
Photography Page
ID #:93
Videos Page 1 of 2
Videos for this product
6:01 4:33 3:04

MOUNTDOG 1350W - Thoughts MOUNTDOG Softbox Lighting Kit Mountdog Softbox Review MountDog 2 so
and Unboxing Photography Studio Light 20"X2…
Buyer Roger Seng Mark J Draper MountDog
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$109.99 $179.99 $159.99 $69.99 $69.99
Customer questions & answers

Have a question? Search for answers
Question: Seller: Why don't you fix the title instead of letting it remain misleading? Each bulb is 135w, not
5 1350w.
votes
Answer: I magnified the picture above and it does seem to say "135W" on the CFL bulb, but I am STILL
suspicious and here's why:
I have a CFL photographic bulb that is a 300W equivalent, that emits 4200 lumens, according to
the box, and consumes 68W. That bulb is HUGE--the box is 10-1/2 inches high. … see more
By BookChief on April 15, 2019
See more answers (3)
Question: This was $58 before the deal. What gives?

3
Answer: like the picture show, all include, 3 softbox kit and 3 bulbs
votes
By MountDog SELLER on October 8, 2018
Question: Is this lighting white cooler or does it have a yellow tint _making it more warm ?
2
Answer: It's very white (cooler) and also very bright.
votes
By MountDog SELLER on August 23, 2018
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
: MOUNTDOG Softbox Lighting 1-9 Filed 11/20/20
Kit Photography PageProfessional
PageLight
ID System
#:94 with E27 95…
Question: Im looking to take pictures inside my home based studio. Would these lights work to take pictures
2 if i have no sunlight from outside?
votes
Answer: Yes. I’m a photographer for pet and have travelled to various indoor shelters to photograph the
animals. These lights worked well where there is no or little natural light.
By Charleszetta W. on November 1, 2018
See more answered questions (344)
Customer reviews Customer images
4.5 out of 5
4,670 global ratings
5 star 73%
4 star 14%
3 star 6% See all customer images
2 star 3% Read reviews that mention

1 star 4%
easy to assemble put together highly recommend easy to set
softbox job done easy to put cheaply made great price
great value get what you pay top heavy gets the job light bulb
By feature
Easy to assemble 4.5

Top reviews
Top reviews
For beginners 4.5
Value for money 4.4

Top reviews from the United States
See more
James
Best cheap lights

Reviewed in the United States on January 9, 2019
Review this product Size: 3 Softbox Verified Purchase
Share your thoughts with other customers I got these because i'm poor. They got me down to iso 200 1/60 and f/4 in a pitch black room.
They are cheap cheap cheap lights so don't expect much but if you are very careful with them
Write a customer review they will be good. The softboxes are great, I had ordered a 50 dollar lightin kit from limo
studio with the umbrellas for 50 bucks and they didn't do anything. I was at iso 640 at best
with those, in a lit room! the 35 dollars is a bit more considering it like 65% more to jump
from 50 to 85 but it was worth it for the image quality. Don't buy these expecting something
professional and easy to use. The lights will fall down if you're not careful! Move slowly and
maybe get some sandbags. IMO These are the best cheap lights you can get if you're on a
budget. The next level lights are 200 dollars. They might have better stands and be brighter
but they cost twice as much.
133 people found this helpful

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11/16/2020 Case 2:20-cv-10641
Amazon.com Document
PageLight
ID System
#:95 with E27 95…
It’s good for beginners who just need a little extra light for their
projects/clients.
Reviewed in the United States on March 12, 2019
Size: 1 Softbox with Two Bulbs Verified Purchase
It came as described and had two large lightbulbs, a carrying bag and it’s cover to turn it into a
soft box. It was also a good buy for the price.
I do makeup so I mostly needed it for application and I paired it with my ring light and
together they give me the light I need. I took a pic of one of my clients with just the soft box
light to give you an idea of the lighting in pics and that was only done with my IPhone 7plus
(not sure if that matters) and the light without its cover in an upstairs loft. Since I’m no
photographer I wouldn’t know what they’d need to make it better outside of the reviews I
read stating they had to purchase different lightbulbs to achieve the brightness and look they
wanted. However, it works well enough for applying makeup and taking phone pics but I’d
definitely say if you want brighter results and you plan using it alone, making YouTube vids or
taking pics to sell items online etc ... then you’d have to pair it with another light or get
brighter lightbulbs just as the photographers mentioned for bright results.
Helpful Comment Report abuse
Kristin
You need this

You need this light! Hosted a New Year’s Eve party at my house last night and all I did was buy
this light and Mylar balloons and I turned my spare room into a photo booth. Everyone asked
me where I got it. I am not a vlogger or instagram model. I had no reason to buy this other
than the fact that I don’t have great lighting in my spare bedroom and wanted a good light
source for the photos. This is the best $40 I’ve ever spent. So worth it. And the photos came
out amazing. We all used our iPhones. The balloons were more expensive than the light!!! It
looks so professional and it’s so easy to assemble. It also collapses for easy storage and comes
with a nice carrying case. Don’t hesistate. Just buy it.
Rachel
Awesome Lighting!
Reviewed in the United States on September 20, 2018
This lighting is perfect for my dark apartment. I’m able to do my YouTube videos again!
Bradley S Cline
https://www.amazon.com/MOUNTDOG-Photography-Professional-Continuous-Advertising/dp/B07G32T189/ref=sr_1_1?dchild=1&keywords=B07G… 10/15
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
PageLight
ID System
#:96 with E27 95…
Easy install and clear picture result!

Reviewed in the United States on September 13, 2018
Nice equipment, easy to install
and use, the picture quality is sooo
differ t with and without! Left one
is without, right one is with. I am
the Deisgner from Milanblocks,
buying this light ball specially for
my photos in the future. I like this
light color is day light, not warm
light which won’t afffect my bags
color at all!
0:00
Thomas M.
Good first studio light!

Reviewed in the United States on November 28, 2018
I’ve been into photography for over 14 years and finally wanted to start putting together a
mini studio in my home. I’ve been looking at lighting for a while and after reading reviews on
the Mountdog soft box lighting kit, I thought I’d give it a try. For the price of this kit, it is way
worth it! The light goes together quite easily, though the directions that came with it could of
been a little better, yet I figured it out and had it together in under 10 mins. The bulbs are
quite huge but are very bright and once the white cover is attached it gave off an awesome
soft white light. The light it provides is substantial for being just 1 bulb. I like that it came with
a spare bulb as it may be fun trying to find replacements but I’m not sure, it’s just such an odd
sized light to me, but like I said this is my first continuous soft box kit so maybe bulbs are
usually this large. I will say the light stand feels very light and that it might not hold, but I
haven’t had any issues with it drooping. It holds the box in whatever angle I put it at. I’m very
pleased with this light and plan to order a few more in the future as I put my studio together.
Nice job Mountdog!!
Ryan k Nell
Great product for the money!

Size: 2 Softbox Verified Purchase
I ordered this kit in mid December because I wanted to start shooting indoor portraits. This kit
is as advertised. Easy to set up and take down. Comes in a carry bag which makes it portable
to take for location shooting. Great starter kit for the beginner photographer or anyone who
needs great lighting for still images or video. I enclosed a sample from my first test shoot with
this kit. Thank You Mountdog!
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
PageLight
ID System
#:97 with E27 95…
Mark E. Smith
Constant lighting worked great

Reviewed in the United States on February 17, 2019
These constant light softboxes worked for the purpose I purchased them for. The prive was
excellent compared to others listed. The "umbrella" part of the softbox is lined in silver, thick
material and will produce harsh light if that is what you are going for. The white translucent
cover softens the light as expected without any major "hotspots". There was no light leakage
from the softbox except out the front as there should be. The bulbs are on the "bright white"
end of the spectrum so they will remove the yellow incandescent coloring depending on how
far they are away from the subject.
See all reviews
Top reviews from other countries
Jason Ha
Great Lighting System

Reviewed in Canada on June 15, 2019
I'm new to photography and one of the first thing you learn about is how you control lighting
which makes a huge difference in your shots. So, I knew I need to purchase a Softbox kit, but
wasn't sure which one and took a chance on this one. And I wasn't disappointed.
I do most of my shooting at home and at my friends place, so the bag makes it easy to take
out, assemble and dissemble. The kit comes in a neatly package in a zipper bag which make it
very portable. I keep everything in the original package when I need to transport it. Especially,
the Styrofoam for the light bulbs which keeps them secure and protected. It comes with 3 cool
white bulbs which is so sweet to have an extra bulb. I really can't complain about getting an
extra bulb.
The only thing I was worried about from other reviews was that the Softbox was top heavy
and easily tip-over. When I settled up the kit, I didn't have that issue. I even extend the
Softbox to it's maximum height (about 6ft) and didn't have a problem with it falling over. I can
see
Read
howmore
others may have that issue, if they didn't keep the tripod leg to the front.
Report abuse
Unboxing Syndrome
Very satisfied
I was surprised by the lamps size
They are huge. Three lamps and two stands
Very easy to assemble and they are very useful
The stands are professional and can go very long and u can change the angle of the light the
way u want
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
PageLight
ID System
#:98 with E27 95…
You should be more careful with

the white cover that reflect the
light cuz its thin to make better
reflection
Report abuse
abhijit biswas
Below standard/ not good/ very bad for professional photographer

Reviewed in Canada on September 25, 2019
Very very low quality ever I bought from amazon. Ultralight and thin, stands are not good,
softboxes are not good, the boom is very very bad, thin. It can be broken at any time. very low
light. I am using Canon 5D Mark IV, Canon 85mm f/1.2 L II lens but light is not sufficient. You
can not control light (low/ high). It occupies much space than led light. It's not for a
professional photographer.
Price is cheap. According to price this product is not bad.
This is a real neutral review.
Report abuse
Fisherman's Wife
Affordable solution for my needs.

I love the compact size of each softbox.
I have a small kitchen and one softbox is fitting great there when I make my cooking videos.
I'm using both softboxes to create Instagram photos.
The bulbs are bright, just it takes a couple of minutes until they kick in the full power.
I wish the softbox had a dimmer, but that option exists in the more expensive models that are
out of my budget for now.
Installation is quick and easy.
Report abuse
Xavier Sotelo
Excellent product and value for the money

Lightweight yet sturdy I was pleasantly surprised when I received this product. It is pretty
straightforward to set up and sufficiently bright enough for my purposes. Everything packs
11/16/2020 Case 2:20-cv-10641
Amazon.com Document
PageLight
ID System
#:99 with E27 95…
neatly into the carrying bag and literraly only takes minutes to set up. Excellent value for the
money. I highly recommend this product to anyone in need of professional lighting for their
studio.
Report abuse
See all reviews
4 stars and above Page 1 of 11

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11/19/2020 Case 2:20-cv-10641
EmartDocument 1-13 Support
8.5 x 10 ft Background FiledSystem
11/20/20
Kit,5500K:Page 2 of 6Camera
Amazon.co.uk: Page ID #:125
& Photo
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Camera & Photo › Accessories › Photo Studio & Lighting › Lighting › Diffusers, Filters & Reflectors › Soft Boxes
Subm Emart 8.5 x 10 ft Currently unavailable.

Background Support
Subm
System Kit,5500K Deliver to France
Subm Backdrop Photography

Add to List
Continuous Photo
Subm
Studio Light System Share
Subm with 24" x 24" Soft

Box for Photo Studio
Subm
Product Portrait and
Subm Video Shooting
Photography
Visit the EMART Store
The kit includes: [2] 24"x24"

Softbox, [1] 8.5 x 10ft
Backdrop Stand Support
System, [1] 6x9 ft Muslin
Backdrop(Green), [2]
Backdrop Spring Clamps,
[2] 5500K CFL Daylight
Bulb, [2] 7ft Light Stand, [1]
Roll over image to zoom in
Carrying Bag for Soft box
Simple to set up: Good first
starter studio lighting kit
for professional/home
studio. Include everything
basic you need to start.
Easy to set up and use.
NOTE: 12 MONTHS
WARRANTY FOR
MANUFACTURING DEFECTS
High-quality softbox: his
24" x 24 " softbox lighting
kit ultimate soften light
stream and remove shadow
to make perfect shooting. 2
x 105W CFL light bulbs,
5500K pure white daylight,
provide the bright and
accurate colors, to capture
the most real picture. High-
quality stone embossed
https://www.amazon.co.uk/EMART-Backdrop-Photography-Lighting-Continuous/dp/B089SJB2C9/ 1/5
11/19/2020 Case 2:20-cv-10641
11/20/20
& Photo
reflective fabric to make the
light more intense
Backdrop Stand System Kit:
The photo lighting studio
kit is a professional support
with Adjustable Height( Min
3 ft - Max 8.5 ft ) and
Width( Min 5 ft - Max 10 ft )
Aluminum Alloy
Construction with 6x9ft
green backdrop screen（All
edges are carefully finished
preventing tears in the
material, and should it
become stained ) The
photography lighting kit is
durable and portable, can
be assembled in a few
minutes. Two sawtooth
spring clamps help you
secure in any direction.
Suitable for Various
Photography: The lighting
kit for photography is ideal
for use in studios. Whether
it's portrait shooting,
fashion photo shoots,
children's photo shoots or
still life shots, this
photography kit is easy to
create the perfect lighting
for indoors shooting,
making photos more
attractive
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Product information
Technical Details Additional Information
Item Package Dimensions L x 80.2 x 33.8 x 17.4 ASIN B089SJB2C9

WxH centimetres
Manufacturer reference EM-BSG-SBK105
Package Weight 18.3 Pounds
Date First Available 14 Sept. 2020
Brand EMART
Warranty & Support
11/19/2020 Case 2:20-cv-10641
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Part number EM-BSG-SBK105
Amazon.com Return Policy: Regardless of your statutory right of
withdrawal, you enjoy a 30-day right of return for many products. For
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Feedback
Product description
Emart 8.5 x 10 ft Background Support System Kit, 5500K Backdrop Photography Continuous Photo Studio Light System with 24"x24" Soft Box for Photo
Studio Product, Portrait and Video Shooting Photography
Sponsored
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Emart Int&#39;l v. Shenzhen Maitewei - Complaint

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Case 2:20-cv-10641 Document 1 Filed 11/20/20 Page 1 of 15 Page ID #:1

1 Alan C. Chen (SBN 224420)

COMPLAINT FOR DECLARATORY JUDGEMENT OF PATENT INVALIDITY

1 seller provides evidence or documentation showing that there is no infringement or

1 19. On information and belief, Maitewei chose to wrongfully accuse

1 regarding EMART’s alleged infringement of the ʼ980 patent by making, importing,

1 52. Maitewei’s false and misleading statements disrupted EMART’s

1 c. By engaging in unfair acts and practices that significantly threaten or

1 6. Award to EMART its damages attributable to Maitewei’s unwarranted

1 DEMAND FOR JURY TRIAL

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Emart Int'l v. Shenzhen Maitewei - Complaint

Emart Int'l v. Shenzhen Maitewei - Complaint