Hong Kong Leyuzhen Technology Co. Limited v. The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 1:25-cv-21899-GAYLES
HONG KONG LEYUZHEN
TECHNOLOGY CO. LIMITED
Plaintiff,
v.
THE INDIVIDUALS, CORPORATIONS,
LIMITED LIABILITY COMPANIES,
PARTNERSHIPS AND UNINCORPORATED
ASSOCIATIONS IDENTIFIED IN
SCHEDULE “A” HERETO
Defendants.
_________________________________________/
CONSENT JUDGMENT
WHEREAS, Plaintiff Hong Kong Leyuzhen Technology Co., Ltd., (“Plaintiff”), and
Defendant Quanzhou Yichao Trading Co., Ltd d/b/a LaiyiVic (“Defendant”), have agreed to
finally resolve the above-captioned litigation (the “Litigation”), including Plaintiff’s claim
concerning the copyrighted photograph or photographs asserted against Defendant in the First
Amended Complaint (collectively, the “Works”).
THIS COURT HEREBY FINDS that it has subject-matter jurisdiction over the Litigation
and personal jurisdiction over Defendant based on Defendant’s express consent to the Court’s
jurisdiction for purposes of this Consent Judgment.
THIS COURT FURTHER FINDS that Defendant is liable for copyright infringement
based on Defendant’s admission that Defendant’s unauthorized use and publication of the Works
infringed Plaintiff’s copyright in the Works.
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IT IS HEREBY ORDERED that:
1. 	Defendant, its officers, agents, servants, employees, attorneys, and other persons in
active concert or participation with Defendant are PERMANENTLY ENJOINED
from using, reproducing, publicly displaying, distributing, publishing, or creating
derivative works from the Works without Plaintiff’s prior written authorization.
2. 	Pursuant to the parties’ settlement agreement, judgment is entered in favor of
Plaintiff and against Defendant in the amount of Twenty-Five Thousand United
States Dollars ($25,000.00) (the “Settlement Amount”), payable in accordance with
the timing and other terms of the Settlement Agreement. Execution on this Consent
Judgment is stayed unless and until Defendant commits a payment default under
the Settlement Agreement, and any execution shall be limited to the unpaid balance
excluding recovery of attorney fees and costs. The Parties expressly waive post-
judgment interest under 28 U.S.C. § 1961 on the Settlement Amount.
3. 	Defendant acknowledges that Plaintiff is the rightful owner of the Works.
4. 	Each party shall bear its own attorney’s fees and costs.
5. 	The Court retains jurisdiction to enforce the Settlement Agreement and this Consent
Judgment.
DONE AND ORDERED in Chambers at Miami, Florida, this 7th day of August, 2026.
________________________________
DARRIN P. GAYLES
UNITED STATES DISTRICT JUDGE
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The foregoing Consent Judgment has been agreed and consented to by the parties:
August 5, 2026
By: /s/ William R. Brees
William R. Brees (Bar No. 98886)
BAYRAMOGLU LAW OFFICES LLC
1540 West Warm Springs Road, Suite 100
Henderson, NV 89014
Tel: (702) 462-5973 Fax: (702) 553-3404
gokalp@bayramoglu-legal.com
William@bayramoglu-legal.com
Counsel for Plaintiff
August 5, 2026
By: /s/ Ziqi Yu
Ziqi Yu
Fla. Bar No. 1044119
5794 Bird Rd., Unit 554
Miami, FL 33155
Tel: (415) 519 5274
procollider@pm.me
Benjamin Solter
Admitted pro hac vice
Cross-Border Counselor LLP
7755 Center Ave., Suite 1100
Huntington Beach, CA 92647
Tel: (781) 752 6369
bensolter@cbcounselor.com
Wesley E. Johnson
Admitted pro hac vice
Cross-Border Counselor LLP
105 W. Madison, Suite 2300
Chicago, IL 60602
Tel: (312) 752 4828
wjohnson@cbcounselor.com
Case 1:25-cv-21899-DPG Document 110 Entered on FLSD Docket 08/07/2026 Page 3 of 3