Puzhen Life v. Xiamen Mingtai Creative Houseware - Complaint

Case 2:21-cv-00151-BSJ Document 2 Filed 03/11/21 PageID.
3 Page 1 of 22
Mark A. Miller (#9563)

miller.mark@dorsey.com
Elliot J. Hales (#16684)
hales.elliot@dorsey.com
DORSEY & WHITNEY LLP
111 S. Main Street, Suite 2100
Salt Lake City, UT 84111
Telephone: (801) 933-7360
Facsimile: (801) 933-7373
Attorneys for Puzhen Life Co. Ltd.
IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH, CENTRAL DIVISION
PUZHEN LIFE CO., LTD, a Hong Kong

company,
Plaintiff,
COMPLAINT FOR DESIGN PATENT
v. INFRINGEMENT AND TRADE DRESS
INFRINGEMENT
XIAMEN MINGTAI CREATIVE
JURY TRIAL DEMANDED
HOUSEWARE CO., LTD, a Chinese
company, and XIAMEN MEETA Case No.: 2:21-cv-00151-BSJ
CREATIVE HOUSEWARE CO, LTD., a
Chinese company Judge Bruce S. Jenkins
Defendants.
Plaintiff Puzhen Life Co., Ltd. (“Puzhen” or “Plaintiff”) hereby brings the present action
against Defendants Xiamen Mingtai Creative Houseware Co., Ltd., d/b/a HiiTii (“Xiamin
Mingtai”), and Xiamen Meeta Creative Houseware Co. Ltd., d/b/a HiiTii (“Xiamin Meeta;”
collectively, “Defendants” or “HiiTii”) and alleges as follows:
4825-7818-0218\1
Case 2:21-cv-00151-BSJ Document 2 Filed 03/11/21 PageID.4 Page 2 of 22
NATURE OF THE ACTION AND SUMMARY OF RELIEF SOUGHT
1. This action has been filed by Plaintiff to address Defendants’ manufacture, use,
sale, and offer of sale of essential oil diffusers featuring Plaintiff’s trade dress and patented
designs through at least www.amazon.com and www.alibaba.com (the products, described more
fully below, are referred to herein as “Defendants’ Infringing Products”). Plaintiff has been and
continues to be irreparably damaged through Defendants’ use of Plaintiff’s trade dress and
patented designs and seeks injunctive and monetary relief.
PARTIES
2. Puzhen is a Hong Kong company with its principal place of business in Shatin
District, Hong Kong.
3. Xiamen Mingtai is a Chinese company doing business domestically as HiiTii,
with a principal place of business at No. 1502, Huizan Nan Erli, Lianqian Street, Siming District,
Xiamen, Fuijan, 361100 China. See EXHIBIT 1.
4. Xiamen Meeta is a Chinese company doing business domestically as HiiTii with a
principal place of business at Room 301, Block C, Building 2, Haoli Building No., 151, Yuehua
Road, Huli District, Ciamen, Fuijan, 361006 China. See EXHIBIT 2.
5. Upon information and belief, Defendants have common ownership.
JURISDICTION AND VENUE
6. This Court has original subject matter jurisdiction over the claims in this action
pursuant to the Patent Act, 35 U.S.C. § 1, et seq., 28 U.S.C. § 1338(a) and (b), and 28 U.S.C. §
1331.
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7. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400, and this
Court may properly exercise personal jurisdiction over Defendants by virtue of at least the
following acts:
a. Defendants have directly targeted business activities toward consumers in Utah
and caused harm to Plaintiff’s business interests within this Judicial District. For
example, Defendants have targeted sales to Utah residents by offering the
Infringing Products on multiple fully interactive and commercial websites,
including at least www.amazon.com and www.alibaba.com, to residents of Utah
who visit these websites. Defendants are committing tortious acts in Utah, are
engaging in interstate commerce, and each has wrongfully caused Plaintiff
substantial injury in the State of Utah. For instance, and as explained more fully
below, one of Puzhen’s largest private label clients is Young Living Essential
Oils, located at 1538 W Sandalwood Dr. Lehi, UT 84043. Puzhen’s relationship
with Young Living, and its ability to sell its products to a Utah company, is
irreparably injured as a result of Defendants’ sale and offer of sale of the
Infringing Products.
b. Defendants import their products into the United States for subsequent delivery to
consumers in the United States, including Utah. See EXHIBIT 3.
c. Defendant’s products are sold at www.amazon.com and www.alibaba.com, each
of which accept payment in U.S. dollars.
d. On information and belief, thousands of web users from the United States
(including the State of Utah) visit Defendants’ product pages for the Infringing
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Products each month, and many hundreds of those visitors purchase the Infringing
Products and have them shipped to their homes, including homes in Utah.
FACTUAL BACKGROUND
8. Founded in Hong Kong in 1995, Puzhen has grown to become an industry-
leading, international marketer and supplier of aroma diffusion products and accessories.
Puzhen’s products are enormously popular at least because of Puzhen’s thoughtful approach to
the appearance, operation, quality, and dependability of its innovative aroma diffusion products.
9. Puzhen products are distributed and sold throughout the United States, including
through Puzhen’s web site, www.puzhen.com. A picture of some of the aroma diffusion
products available at www.puzhen.com are shown below.
Puzhen Sha (large)
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Puzhen Sha (small)
Puzhen Yun
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10. In addition to the aroma diffusion products above, each marketed under Puzhen’s
own brand name, Puzhen manufactures products which are sold under private labels. For
example, the Young Living Aria™ is pictured below and is advertised at
https://www.youngliving.com/en_US/products/aria-ultrasonic-diffuser. This product is the
private label version of the Puzhen Yun.
Young Living Aria
11. Young Living is a Utah company, and Puzhen ships its private label products to
Young Living at its Utah facilities.
12. Puzhen’s aroma diffuser products are widely recognized by consumers by their
unique designs. Aroma diffusers fashioned with Puzhen’s unique designs are associated with the
quality and innovation that the public has come to expect from Puzhen. Puzhen uses these
designs in connection with the marketing of its products, including the designs disclosed in U.S.
Design Patent No. D553,231 (the ’231 patent”), attached to this Complaint as EXHIBIT 4.
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13. Puzhen is the lawful assignee of all right, title and interest in and to the ’231
patent. The ‘231 patent was lawfully issued on October 16, 2007, listing Dong-Sheng Li as an
inventor. Figures disclosing the patented design of the ’231 patent are below
Front view Perspective view
14. It is apparent, when comparing images of the Puzhen Yun and the Young Living
Aria™ with the figures of the ’231 patent, that the Shun and Aria™ products are the commercial
embodiments of the design disclosed in the ’231 patent.
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Puzhen Yun and Young Living Aria Plaintiff’s ’231 Design
DEFENDANTS’ INFRINGING ACTS—DESIGN PATENT INFRINGEMENT
15. Defendants offer Infringing Products that are clear knockoff versions of the
Puzhen Yun and Young Living Aria™ on www.amazon.com and www.alibaba.com, each of
which is a fully interactive, commercial website allowing for domestic visitors, including Utah
residents, to view the Infringing Products, learn more about them, purchase the Infringing
Products, and have them shipped to their homes, including in Utah.
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16. Defendants’ Infringing Products are known variously as the “HiiTii Wood Base
Ultrasonic Essential Oil Diffuser” or “MEETA customized nebulizer amazon manufactures
essential oil scent aroma diffuser.” See EXHIBIT 5. This product, as it is marketed on
www.amazon.com, is depicted below to the left. See EXHIBIT 6. This product, as it is
marketed on www.alibaba.com, is shown to the right. See Ex. 5.
HiiTii Infringing Products
17. As used herein, “Infringing Product” should be understood to include each and
every product offered for sale, sold, used, or imported by Defendants and which substantially
resembles those pictured above, including but not limited to the products advertised at
https://hiitii.en.alibaba.com/productgrouplist-824208777-
1/Wood_Diffuser.html?spm=a2700.shop_pl.41413.27.a42f3df5sLWGGu&filterSimilar=true&fil
ter=null. See Ex.5.
18. Defendants are engaged in designing, manufacturing, importing, advertising,
promoting, distributing, selling, and/or offering for sale Defendants’ Infringing Products
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throughout the United States and in this judicial district. Defendants offer the Infringing
Products to residents of the United States at least on www.amazon.com and www.alibaba.com.
As of the date of the filing of this Complaint, Defendants offer the Infringing Products for sale at
https://www.amazon.com/HiiTii-Ultrasonic-Essential-Diffuser-
Humidifier/dp/B081WVZSBF/ref=sr_1_2?crid=1F56ZXHII9ZJA&dchild=1&keywords=hiitii+
wood+base+ultrasonic+essential+oil+diffuser&qid=1614965104&sprefix=hiitii+wood%2Caps%
2C382&sr=8-2 (see Ex. 6) and https://hiitii.en.alibaba.com/productgrouplist-824208777-
1/Wood_Diffuser.html?spm=a2700.shop_pl.41413.27.a42f3df5sLWGGu&filterSimilar=true&fil
ter=null (Ex. 5.).
19. Plaintiff’s investigator visited the Amazon.com product page for the Infringing
Products and purchased an Infringing Product from a Utah address for shipment to that Utah
address. See Ex. 3.
20. Defendant’s Infringing Products are studied imitations of the Puzhen Yun and/or
the Young Living Aria™, and each infringes the ornamental design for an aroma diffuser
disclosed in the ’231 patent, as shown below.
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Defendants’ Infringing Products Plaintiff’s ’231 Design
21. Upon information and belief, Defendants are well aware of the extraordinary
success of Plaintiff’s aroma diffuser designs and the high-quality products associated therewith.
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22. Defendants, without any authorization, license, or other permission from Plaintiff,
have used Plaintiff’s patented designs in connection with the making, using, offering to sell,
selling, or importing of Defendants’ Infringing Products into the United States.
23. In January 2021, Plaintiff wrote a cease and desist letter to Defendant Xiamen
Meeta (see EXHIBT 7), informing it that its Infringing Product infringed the ’231 patent, and
Plaintiff described the basis for that allegation. To date, Defendant Xiamen Meeta has not
responded to this letter, nor has it ceased sale and offer of sale of Defendant’s Infringing
Products.
24. On information and belief, Defendant Xiamen Mingtai has also been made aware
of Plaintiff’s cease and desist letter by virtue of the common ownership of the Defendants.
25. Since at least receipt of Plaintiff’s cease and desist letter, Defendants’ use of
Plaintiff’s designs in the making, using, offering to sell, selling, or importing of the Infringing
Products is willful and/or in reckless disregard of Plaintiff’s ’231 patent rights.
26. Defendants’ willful infringement of Plaintiff’s designs in connection with the
making, using, offering to sell, selling, or importing of Defendants’ Infringing Products is
irreparably harming Plaintiff.
27. Plaintiff is entitled to a preliminary injunction under 35 U.S.C. § 283 prohibiting
Defendants from further making, using, importing, selling and offering for sale the Infringing
Product, and any other product that infringes the ’231 patent.
28. Plaintiff is entitled to recover all monetary damages caused by Defendants’
infringing conduct under 35 U.S.C. § 284. Plaintiff is further entitled to Defendants’ profits
from its unlawful, infringing sales of Defendants’ Infringing Products under 35 U.S.C. § 289.
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29. Defendants’ willful infringement entitles Plaintiff to enhanced damages and
attorneys’ fees and costs along with prejudgment interest under 35 U.S.C. §§ 284, 285.
DEFENDANT’S INFRINGING ACTS—TRADE DRESS INFRINGMENT
30. To distinguish Puzhen’s products from other aroma diffusion products, Puzhen’s
aroma diffusion products have consistently been and are uniquely configured. Puzhen’s Yun and
Young Living Aria™ aroma diffusion products are two examples of such uniquely configured
products. As may be seen below, Puzhen’s Yun and Young Living Aria™ aroma diffusion
products include in combination, inter alia, a flat-topped and flat-bottomed convex base with a
smooth finish and a flat, thick outer circumference; the products include a glass half-dome inset
centrally within the circumference of the base and which extends in all directions to sit flush
within the circumference of the base; a wide-mouthed, flanged aroma diffusion outlet extending
from the half-dome at an angle roughly 45 degrees above the plane of the top of the wooden
base.
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31. The Puzhen Yun and Young Living Aria™ designs, including the elements listed
above, are more than an assemblage of functional parts. They are combined in a manner that,
individually and as a whole, constitute non-functional trade dress that is entitled to trade dress
protection under the Lanham Act.
32. Puzhen has enjoyed considerable success in marketing its aroma diffusion
products cloaked with this distinctive trade dress.
33. Through considerable investment, advertising, marketing, and sales, the public
has come to know and associate products cloaked in Puzhen’s trade dress as originating from a
single manufacturer.
34. On information and belief, Defendants copied the design of Puzhen’s Yun aroma
diffuser and/or Young Living’s Aria™ diffuser when it designed and manufactured Defendants’
Infringing Products and presently market, advertise, offer for sale, and sell Defendants’
Infringing Products.
35. As may be seen below, Defendants’ Infringing Products infringe on Puzhen’s
trade dress and design rights by, inter alia, misappropriating the flat-topped and flat-bottomed
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convex base with a smooth finish and a flat, thick outer circumference; the glass half-dome inset
within the circumference of the base; a wide-mouthed, and a flanged aroma diffusion outlet
extending from the half-dome at an angle roughly 45 degrees above the plane of the top of the
wooden base.
36. Defendants’ copying of Puzhen’s trade dress and design is an attempt to trade off
the goodwill that Plaintiff has established manufacturing, marketing, and selling aroma diffusers
cloaked its distinctive trade dress.
37. By offering Defendants’ Infringing Products for sale and selling the Infringing
Products, Defendants infringe Puzhen’s trade dress rights. The trade dress of Defendants’
Infringing Products—the total product and overall impression of the product, its size, shape,
configuration, and design—has caused confusion and is likely to continue to cause confusion in
the marketplace regarding whether Puzhen is the source of Defendants’ Infringing Products, or
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whether Puzhen sponsors, endorses or is otherwise affiliated with Defendants’ Infringing
Products.
38. On information and belief, Defendants knowingly and intentionally copied the
trade dress and design of Puzhen’s Yun and/or Young Living’s Aria™ aroma diffusers in an
attempt to take unfair advantage of and trade off the reputation and goodwill of Puzhen, which
has been established since at least the introduction of the Puzhen Yun and Young Living Aria™
aroma diffusion products to the market.
39. Puzhen has not licensed or approved Defendants’ use or misappropriation of
Puzhen’s trade dress or design.
40. Since at least receipt of Plaintiff’s cease and desist letter, Defendants’ use of
Plaintiff’s designs in the making, using, offering to sell, selling, or importing of the Infringing
Products is willful and/or in reckless disregard of Plaintiff’s rights.
41. Defendants’ willful infringement of Plaintiff’s trade dress rights in connection
with the making, using, offering to sell, selling, or importing of Defendants’ Infringing Products
is irreparably harming Plaintiff.
42. Plaintiff is entitled to a preliminary injunction prohibiting Defendants from
further making, using, importing, selling and offering for sale the Infringing Product, and any
other product that infringes Puzhen’s trade dress rights.
43. Plaintiff is entitled to recover all monetary damages caused by Defendant’s
infringing conduct. Plaintiff is further entitled to Defendants’ profits from its unlawful,
infringing sales of products cloaked in Puzhen’s trade dress.
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44. Defendants’ willful infringement of Puzhen’s trade dress entitles Plaintiff to
enhanced damages and attorneys’ fees and costs along with prejudgment interest.
FIRST CLAIM FOR RELIEF

Patent Infringement of the ’231 Patent Under 35 U.S.C. § 271
45. Plaintiff hereby re-alleges and incorporates by reference the allegations set forth
in the preceding paragraphs.
46. Defendants make, use, offer for sale, sell, and/or import into the United States for
subsequent sale or use Defendants’ Infringing Products which infringe directly and/or indirectly
the ornamental design claimed in the ‘231 Patent.
47. Defendants have infringed the ‘231 Patent through the aforesaid acts, and will
continue to do so unless enjoined by this Court.
48. Defendants’ wrongful conduct has caused Puzhen to suffer irreparable harm
resulting from the loss of its lawful patent rights to exclude others from making, using, selling,
offering for sale and importing the patented inventions.
49. Puzhen is entitled to injunctive relief pursuant to 35 U.S.C. § 283.
50. Puzhen is entitled to recover damages adequate to compensate for the
infringement, including Defendants’ profits pursuant to 35 U.S.C. § 289.
51. Puzhen is entitled to recover any other damages, enhanced damages, attorneys’
fees, and costs as appropriate pursuant to 35 U.S.C. §§ 284, 285.
SECOND CLAIM FOR RELIEF

Trade Dress Infringement—Lanham Act § 43(a)
52. The foregoing paragraphs are incorporated by reference as if set forth here in full.
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53. Based at least on its distinctive design, as well as extensive advertising,
promotion, and sales of aroma diffusers in the United States, the consuming public accepts and
recognizes the Puzhen trade dress, and it has become an asset of substantial value as a source
identifier for Puzhen’s innovative products, and its goodwill. As a result of Puzhen’s efforts,
customers associate the distinctive Puzhen product design with Puzhen.
54. Puzhen is the owner of all right and title to its distinct trade dress found in the
Puzhen Yun and Young Living Aria™.
55. Puzhen is entitled to legal protection of its trade dress under § 43(a) of the
Lanham Act, which trade dress include in combination, inter alia, a flat-topped and flat-bottomed
convex base with a smooth finish and a flat, thick outer circumference; the glass half-dome inset
within the circumference of the base; a wide-mouthed, and a flanged aroma diffusion outlet
extending from the half-dome at an angle roughly 45 degrees above the plane of the top of the
wooden base; and the aroma diffusers’ overall shape and appearance.
56. Notwithstanding Puzhen’s preexisting valid and enforceable rights in the Puzhen
trade dress, Defendants used Puzhen’s trade dress without license, permission, or approval.
Defendants’ unauthorized use of the Puzhen trade dress includes selling and offering for sale
Defendants’ Infringing Products in the United States, including on its Amazon.com and
Alibaba.com. In addition, Defendants have featured the Infringing Product design—which
includes Puzhen’s unique trade dress—prominently on in its marketing materials.
57. Defendant has so closely imitated and/or copied Puzhen’s trade dress that there is
a likelihood of confusion among the consuming public as to the source, origin, or sponsorship of
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Defendants’ Infringing Products. The consuming public has believed and is likely to erroneously
believe that Defendant’s products come from Puzhen or are licensed or sponsored by Puzhen.
58. By using Puzhen’s trade dress in Defendants’ Infringing Products and related
advertising, as alleged above, Defendants have infringed upon Puzhen’s trade dress and
goodwill.
59. On information and belief, Defendants’ copying of Puzhen’s trade dress was
intentional, and in bad faith. Defendants intended to create aroma diffusion devices that are
confusingly similar in appearance to Puzhen’s aroma diffusion products and intended to market
its knockoff products in direct competition with Puzhen to consumers searching for Puzhen’s
products.
60. Defendants’ Infringing Products and Puzhen’s aroma diffusion products are
strikingly similar, substantially duplicated, substantially identical, remarkably similar, essentially
duplicated and/or closely imitated.
61. Defendants’ acts of trade dress infringement have caused and continue to cause
damages and injury to Puzhen.
62. Puzhen may recover for damages an award to compensate Puzhen for the injuries
and damages it has sustained as a result of Defendants’ conduct which violates § 43(a) of the
Lanham Act.
63. Because Defendants’ acts were intentional, willful, and/or deliberate, Plaintiffs
are entitled to an award of treble damages under § 43(a) of the Lanham Act.
64. Puzhen is entitled to an award of Defendants’ profits under the Lanham Act, 15
U.S.C. § 1117(a).
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65. Puzhen is entitled to an award of pre-judgment interest for damages sustained as a
result of the Defendants’ wrongful conduct.
66. Defendants’ wrongful, malicious, fraudulent, deliberate, willful, intentional and/or
incredible conduct makes this case an exceptional case, entitling Plaintiff to an award of
attorneys’ fees and costs under the Lanham Act. 15 U.S.C. § 1117(a).
67. Puzhen has no adequate remedy at law, has suffered and continues to suffer
irreparable harm as a result of Defendants’ acts, and is therefore entitled to a preliminary and
permanent injunction to enjoin Defendants’ wrongful conduct.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for the following relief:
1. That Defendants, their officers, agents, servants, employees, attorneys,
confederates, and all persons acting for, with, by, through, under, or in active concert with them
be temporarily, preliminarily, and permanently enjoined and restrained from:
a. importing, offering for sale, or selling any products not authorized by Puzhen and
that include any reproduction, copy or colorable imitation of Plaintiff’s trade dress
and/or the designs claimed in the ’231 patent;
b. aiding, abetting, contributing to or otherwise assisting anyone in infringing upon
Plaintiff’s trade dress rights and/or the ’231 patent; and
c. effecting assignments or transfers, forming new entities or associations or
utilizing any other device for the purpose of circumventing or otherwise avoiding
the prohibitions set forth in Subparagraphs (a) through (b) supra
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2. That Defendants, within fourteen (14) days after service of judgment with notice
of entry thereof upon it, be required to file with the Court and serve upon Plaintiff a written
report under oath setting forth in detail the manner in which Defendants have complied with
paragraph 1, (a) through (c), supra;
3. Awarding Puzhen such damages as it shall prove at trial against Defendants that
are adequate to compensate Puzhen for willful infringement of Puzhen’s ’231 patent, and all of
the profits realized by Defendants, or others acting in concert or participation with Defendants,
from Defendants’ unauthorized use and infringement of Puzhen’s ’231 Patent;
4. Awarding Puzhen such damages as it shall prove at trial against Defendants that
are adequate to compensate Puzhen for willful infringement of Puzhen’s trade dress rights, and
all of the profits realized by Defendant, or others acting in concert or participation with it, from
Defendant’s unauthorized use and infringement of Puzhen’s trade dress rights;
5. That Puzhen be awarded from Defendants, as a result of Defendants’ willful use
of the Puzhen’s designs, three times Puzhen’s damages therefrom and three times Defendants’
profits therefrom, after an accounting, pursuant to 35 U.S.C. § 284 and/or § 43(a) of the Lanham
Act;
6. That Plaintiff be awarded its reasonable attorneys’ fees and costs; and
7. Award any and all other relief that this Court deems just and proper.
Plaintiff Puzhen demands a jury trial pursuant to Fed. R. Civ. P. 38(b) on all claims,
defenses and counterclaims so triable.
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Dated: March 11, 2021 Respectfully submitted,
/s/ Mark A. Miller

Mark A. Miller (#9563)
miller.mark@dorsey.com
Elliot J. Hales (#16684)
hales.elliot@dorsey.com
DORSEY & WHITNEY LLP
111 South Main Street, Suite 2100
Salt Lake City, UT 84111-2176
(801) 933-4082
ATTORNEYS FOR PLAINTIFF
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JS 44 (Rev. 10/20) Case 2:21-cv-00151-BSJ CIVIL COVER
Document SHEET
2-1 Filed 03/11/21 PageID.25 Page 1 of 2
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Puzhen Life Co., Ltd. Xiamen Mingtai Creative Housewares Co., Ltd., et al
(b) County of Residence of First Listed Plaintiff N/A - Hong Kong County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Mark A. Miller; Dorsey & Whitney LLP; 111 S. Main St.,

Suite 2100; Salt Lake City, UT, 84111; (801) 933-4068
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government ✖ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability ✖ 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
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Conditions of
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V. ORIGIN (Place an “X” in One Box Only)
✖ 1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Design patent infringement under 35 U.S.C. § 271; trade dress infringement under 15 U.S.C. §1125 (Lanham Act § 43(a))
VI. CAUSE OF ACTION Brief description of cause:
Design patent infringement under 35 U.S.C. § 271; trade dress infringement under 15 U.S.C. §1125 (Lanham Act § 43(a))
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. yes; unspecified JURY DEMAND: ✖ Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
03/10/2021 Mark Miller Digitally signed by Mark Miller
Date: 2021.03.10 15:54:00 -07'00'
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 2:21-cv-00151-BSJ Document 2-1 Filed 03/11/21 PageID.26 Page 2 of 2
JS 44 Reverse (Rev. 10/20)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.
V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service.
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
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EXHIBIT 3
3/9/2021 Case 2:21-cv-00151-BSJ Document 2-4 Track
Filed 03/11/21 PageID.35 Page 2 of 4
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EXHIBIT 4
EXHIBIT 5
3/9/2021 Case 2:21-cv-00151-BSJ Document
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3/9/2021 Case 2:21-cv-00151-BSJ Document
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EXHIBIT 6
3/9/2021 Case 2:21-cv-00151-BSJ
Amazon.com Document
: HiiTii Wood Base Ultrasonic Essential 2-7 Filed
Oil Diffuser 03/11/21
Air Humidifier, PageID.48
200 ml Glass Oil DiffuserPage 2 Office
for Home of 10Hotel : Beauty
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About this item Ships from Daroma Life
EFFECTIVE: This essential oil diffuser uses ultrasonic Sold by Daroma Life
technology to break down the mixture of essential oils

Roll over image to zoom in and water into millions of microparticles, and Add to List
effectively disperses the micro-particles into the air.
AROMATHERAPY: These millions of tiny particles of
essential oil and water mixture suspended in the air, Share
help to eliminate odor, relieve fatigue, create a relaxed
atmosphere for you and benefit from aromatherapy. Have one to sell?
MODE/ LIGHT: 4-hour continuous mode, 8-hour “30s
Sell on Amazon
on/ 30s off cycles” intermittent mode(200mL). Seven
colors of light can cycle through gradients, or be set to
one color. Touch sensitive switch, easy to operate.
Automatic shut off when there is no water left in the
water tank.
VERSATILE/ QUIET: Light and mist can be controlled
separately. It can be an essential oil diffuser,
humidifier or night light. And this diffuser runs very
quiet and can be used in many places, such as living
room, bedroom, office, yoga room, hotel and other
places.
Pura Smart Home Fragrance
MAINTAIN: Please don’t add more than 200 ml of
Device Starter Pack (Simply…
water. Regularly clean the inner wall of the water tank $
68.00
of the diffuser with a cleaning sponge or cotton gauze
soaked with rubbing alcohol.
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3/9/2021 Case 2:21-cv-00151-BSJ
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This item: HiiTii Wood Base Ultrasonic Essential Oil Diffuser Air Humidifier, 200 ml Glass Oil Diffuser for… $89.99 ($89.99 / 1 Count)
LEMON + Co. 150 ml Cool Mist Air Humidifier Ultrasonic Aroma Essential Oil Diffuser for Office, Home… $34.99
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3/9/2021 Case 2:21-cv-00151-BSJ
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Product Description
High Efficiency
Advanced ultrasonic technology breaks down the mixture of essential oils and water into millions of
microparticles, and effectively disperses the micro-particles to moisturize and refresh the air in your
personal spaces.
Spa Work Sleep Yoga
Waterless & Wireless Waterless & Wireless Waterless Battery Operated Waterless Battery Operated
Essential Oil Nebulizer Essential Oil Nebulizer Black Essential Oil Diffuser White Essential Oil Diffuser Pink
Lavender
3/9/2021 Case 2:21-cv-00151-BSJ
Amazon.com Document
Product details
Package Dimensions : 8 x 7.2 x 7.2 inches; 2.4 Pounds
Item model number : HTP-AD403
UPC : 824006801306
Manufacturer : HiiTii
ASIN : B081WVZSBF
Best Sellers Rank: #111,322 in Health & Household (See Top 100 in Health & Household)
#690 in Aromatherapy Diffusers
Customer Reviews:
144 ratings
Videos
Videos for this product Videos for related products
0:55 7:11 4:09

How to Use This Ultrasonic 8 Best Essential Oil Diffusers for The 10 Best Smart Diffusers Top 10 Best
Essential Oil Diffuser? 2021 Diffusers
HiiTii BESTGADGETS Ezvid Wiki Top 10 Zone
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Ultrasonic Essential Oil Mist Air Humidifier Ultrasonic Oil Diffuser, 200ml Real Essential Oil Diffuser, 5 in 1
Diffuser Air Humidifier, 200 Aroma Essential Oil Diffuser Wood Base, The 2021 Ultrasonic Aromatherapy
ml Glass Oil Diffuser for for Office, Home, Bedroom, Upgrade. Ultrasonic Fragrant Oil Humidifier
Home Office Hotel Living Room, Study, Yoga, Aromatherapy Scent Air Vaporizer, Timer and Auto-
Spa; Glass Cover with Nebulizing Room Humidifier Off Safety Switch
Multiple Lighting Options Home Office Gift
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Customer (144) (2128) (502) (20411)

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IHADA Glass Essential LEMON + Co. 150 ml ArOmis Aromatherapy Stadler Form Jasmine Aroma Humidifier for P
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4.3 out of 5
144 global ratings
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4 star 12%
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Top reviews from the United States
3/9/2021 Case 2:21-cv-00151-BSJ
Amazon.com Document
Laurie Collins
Great diffuser!
Reviewed in the United States on February 16, 2020
Verified Purchase Early Reviewer Rewards (What's this?)
I bought this diffuser for my mom and she loves it!! Sometimes the sensors can be a little difficult
to press but it diffuses for a very long time and I like how it has a lot of different colors to choose
from. Shipping took a while but it was well worth the wait!! Definitely would recommend if you are
looking for a more affordable alternative to the young living aria diffuser.
21 people found this helpful
Helpful Report abuse

Brooklyn Botany Eucalyptus Essential Oil …
70
$
15.95 Shop now Amazon Customer
highly recommend
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Reviewed in the United States on July 10, 2020
Verified Purchase
These is my first diffuser I never heard of one before until I saw one in the staff office.... so it
made me buy one I choose these because is easy to use and clean... I like that it comes with
essential oils...but I bought some at Walmart too just in case...these is my 5 time using it I had a
bit of a problem using a cedar wood essential oils it clogged and polluted my diffuser so my
diffuser didn’t work for a day ... then after 2 days of using back again it works now so I’m happy
with it... definitely buy these diffuser is worth the money ... so one thing I’ll tell you guys is to be
careful when using cedar wood with lavender together it will clogged or pollute your diffuser if
you let it sit there for awhile with the oils in there.... so don’t do that so that’s my review I hope
these helps you guys if it do then give it a thumbs up thanks .
julie r.
Worked for one day.

Worked for one day then wouldn't turn back on.
Amazon Customer
Not what I was expecting

I am having a hard time getting the lights to work correctly. When it turns off after 4 hrs the red
light comes on. I set it for no light when I go to bed.
Several times when I turn it on it makes a loud grinding noise. I have to turn it off and back on.
Christian green
Perfect dupe for the YL aria diffuser!

Reviewed in the United States on November 19, 2020
Verified Purchase
I bought this diffuser after falling in love with the young living aria diffuser. It’s always out of stock
and sells for $300 so that also played a roll in my decision to purchase this diffuser. Had it for a
week or so and it works great! Easy to clean out also!
3/9/2021 Case 2:21-cv-00151-BSJ
Amazon.com Document
joseph
Great product, unfortunately, the glass cracked after a couple weeks

Verified Purchase
Shipping took a long time but it was worth it when it finally arrived. I really loved this diffuser
because it was a pretty solid YL Aria dupe, however, after only using it for over a month the
glass cracked. I've used it exactly as intended and it works great except that I noticed it cracked
while it was diffusing normally. There were not any nicks or imperfections in the glass that I could
see prior and I've always handled it very carefully, setting it on a towel when refilling the water
even. So I'm not sure why the glass could have cracked but I'm super bummed because it was
such a pretty diffuser and long-awaited.
One person found this helpful
Jenn Brook
Horrible. DO NOT BUY.

Reviewed in the United States on March 1, 2021
Verified Purchase
I order this on November 10th, it arrived January 11th. I’ve used it maybe 8 times since I
received it. It’s pretty, I like the color changing aspect, the wood and glass combo was exactly
what I was hoping for decor wise. HOWEVER, what I wasn’t expecting is that it would start
sweeping water all over my furniture. In inspecting today there was a massive puddle that had
been there sometime. At first I wasn’t sure how it happened, so I filled the diffuser to the fill line,
started it and took a quite minute to watch it turn on. It started leaking everywhere.
This was expensive, took an absurd amount of time to arrive and broke almost immediately.
Save yourself the trouble and purchase an alternate brand. What a disappointment.
Mama X
Cute little diffuser

Reviewed in the United States on December 22, 2020
Verified Purchase
Cute little diffuser. But we ordered two and have still only received one. The other is stuck
somewhere in shipping void.
See all reviews
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3/9/2021 Case 2:21-cv-00151-BSJ
Amazon.com Document
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3/9/2021 Case 2:21-cv-00151-BSJ
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EXHIBIT 7

Puzhen Life v. Xiamen Mingtai Creative Houseware - Complaint

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Case 2:21-cv-00151-BSJ Document 2 Filed 03/11/21 PageID.

Mark A. Miller (#9563)

Attorneys for Puzhen Life Co. Ltd.

IN THE UNITED STATES DISTRICT COURT

PUZHEN LIFE CO., LTD, a Hong Kong

collectively, “Defendants” or “HiiTii”) and alleges as follows:

NATURE OF THE ACTION AND SUMMARY OF RELIEF SOUGHT

patented designs and seeks injunctive and monetary relief.

District, Hong Kong.

3. Xiamen Mingtai is a Chinese company doing business domestically as HiiTii,

Xiamen, Fuijan, 361100 China. See EXHIBIT 1.

4. Xiamen Meeta is a Chinese company doing business domestically as HiiTii with a

Road, Huli District, Ciamen, Fuijan, 361006 China. See EXHIBIT 2.

5. Upon information and belief, Defendants have common ownership.

JURISDICTION AND VENUE

a. Defendants have directly targeted business activities toward consumers in Utah

example, Defendants have targeted sales to Utah residents by offering the

Infringing Products on multiple fully interactive and commercial websites,

including at least www.amazon.com and www.alibaba.com, to residents of Utah

engaging in interstate commerce, and each has wrongfully caused Plaintiff

Oils, located at 1538 W Sandalwood Dr. Lehi, UT 84043. Puzhen’s relationship

irreparably injured as a result of Defendants’ sale and offer of sale of the

consumers in the United States, including Utah. See EXHIBIT 3.

c. Defendant’s products are sold at www.amazon.com and www.alibaba.com, each

of which accept payment in U.S. dollars.

8. Founded in Hong Kong in 1995, Puzhen has grown to become an industry-

products available at www.puzhen.com are shown below.

Puzhen Sha (large)

Puzhen Sha (small)

example, the Young Living Aria™ is pictured below and is advertised at

https://www.youngliving.com/en_US/products/aria-ultrasonic-diffuser. This product is the

private label version of the Puzhen Yun.

Young Living Aria

Young Living at its Utah facilities.

Front view Perspective view

embodiments of the design disclosed in the ’231 patent.

Puzhen Yun and Young Living Aria Plaintiff’s ’231 Design

DEFENDANTS’ INFRINGING ACTS—DESIGN PATENT INFRINGEMENT

Products, and have them shipped to their homes, including in Utah.

Ultrasonic Essential Oil Diffuser” or “MEETA customized nebulizer amazon manufactures

www.amazon.com, is depicted below to the left. See EXHIBIT 6. This product, as it is

marketed on www.alibaba.com, is shown to the right. See Ex. 5.

HiiTii Infringing Products

ter=null. See Ex.5.

18. Defendants are engaged in designing, manufacturing, importing, advertising,

Products to residents of the United States at least on www.amazon.com and www.alibaba.com.

2C382&sr=8-2 (see Ex. 6) and https://hiitii.en.alibaba.com/productgrouplist-824208777-

ter=null (Ex. 5.).

address. See Ex. 3.

disclosed in the ’231 patent, as shown below.

Defendants’ Infringing Products Plaintiff’s ’231 Design

selling, or importing of Defendants’ Infringing Products into the United States.

Products is willful and/or in reckless disregard of Plaintiff’s ’231 patent rights.

26. Defendants’ willful infringement of Plaintiff’s designs in connection with the

making, using, offering to sell, selling, or importing of Defendants’ Infringing Products is

irreparably harming Plaintiff.

27. Plaintiff is entitled to a preliminary injunction under 35 U.S.C. § 283 prohibiting

28. Plaintiff is entitled to recover all monetary damages caused by Defendants’

29. Defendants’ willful infringement entitles Plaintiff to enhanced damages and

DEFENDANT’S INFRINGING ACTS—TRADE DRESS INFRINGMENT

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