CIVIL CASE NO. 25-cv-5837

FoxMind Canada Enterprises Ltd. v. APROAT, et al.

NOTICE TO DEFENDANTS

Notice of Lawsuit and Service of Summons, Complaint and Order to Show Cause

We are legal counsel to FoxMind Canada Enterprises Ltd. (“Plaintiff” or “FoxMind”).  This letter serves as notice that a lawsuit has been filed by FoxMind against you (“Defendant”) in the United States District Court for the Southern District of New York, Case No. 25-cv-5837 (JSR) (“Lawsuit”). All relevant documents can be accessed and downloaded below.

On July 16, 2025, the Court entered an ex parte Temporary Restraining Order, Order Restraining Merchant Storefronts and Defendants’ Assets with the Financial Institutions, Order to Show Cause Why a Preliminary Injunction Should Not Issue, Order Authorizing Bifurcated and Alternative Service and Order Authorizing Expedited Discovery against Defendants (“TRO”).

Pursuant to the Order, Defendant is Ordered to appear before Hon. Jed S. Rakoff in Courtroom 14B of the United States District Court for the Southern District of New York, located at 500 Pearl Street, New York, New York on Monday, July 28, 2025 at 2:00 p.m. EST, and show cause why a preliminary injunction should not issue against Defendant (“Show Cause Hearing”).

Please be advised that Defendant’s failure to appear at the Show Cause Hearing may result in the imposition of a preliminary injunction against you, which may extend throughout the length of the Lawsuit.

Please also be aware that if Defendant fails to respond to the Complaint within twenty-one (21) days from the date of this letter, it will be in default, and the Court can issue a default judgment against Defendant awarding financial damages and a permanent injunction.

Since we represent FoxMind, we are unable to provide you with legal advice. Accordingly, we strongly advise that you retain an attorney to assist you in this Lawsuit.

Further, in order to engage in any communications regarding the Lawsuit, including any settlement discussions and/or questions, you or your attorney MUST respond to this notice VIA EMAIL at mail@ipcounselors.com OR VIA THE MESSAGE BOX ON THIS LAWSUIT WEBSITE: http://www.ipcounselorslawsuit.com/foxmind-aproat/. Please clearly identify the name of your User Account in the subject line of any and all emails or in the message box, and include your preferred email address or the contact information for your attorney to use for all future communications.

Copies of the Summons, Complaint and exhibits thereto, and the Order along with all supporting papers thereof, are available to view or download below.

DOWNLOADS

SUMMONS (PDF/234KB)Download
COMPLAINT & Exhibits B – C (PDF/749KB)Download
Exhibit A to the COMPLAINT and Exhibit A to Levine Declaration  (PDF/82MB)Download
Temporary Restraining Order & Schedule A (PDF/368KB)Download
Memorandum of Law (PDF/460KB)Download
Declaration of David Capon & Exhibits A – B (PDF/732KB)Download
Declaration of Melissa J. Levine & Exhibits A – C (PDF/391KB)Download
Preliminary Injunction Order (PDF/522KB)Download

DOWNLOAD ALL

Download all files together in zip format (ZIP/25.14MB)Download All

CONTACT US

Please contact us using the form below
*IMPORTANT: Be sure to clearly state the name of your Storefront in all emails to us. Thank you!








Epstein Drangel LLP

One Grand Central Place, 60 East 42nd Street, Suite 1250, New York, NY 10165
Phone: (212) 292 5390 | Fax: (212) 292 5391 | E-Mail: mail@ipcounselors.com