Dear Amazon Legal & Intellectual Property Department, I act as legal counsel for Mr. Zhang Guanyong, the lawful proprietor of the European Union Registered Design No. 015117871-0002, titled “Headbands”, duly registered and granted by the European Union Intellectual Property Office (EUIPO) on 25 September 2025. This letter constitutes a formal notice of infringement under applicable EU law, German national law, and Amazon platform policies. 1. Rights Ownership The above-mentioned EU registered design is valid and enforceable throughout all EU Member States, including Germany. My client, Zhang Guanyong, is the exclusive owner of all rights conferred by the registration. My client’s genuine product link: http://www.wellbrilliant.com/headbands-23595848 2. Infringing Activity Identified It has come to our attention that the Amazon.de seller: Seller Name: FINNG Seller ID: A149KZ1RDVH061 is offering and marketing an infringing product under the following listing: ASIN: B0FSQZ5412 Infringing Link: https://www.amazon.de/dp/B0FSQZ5412 The product displayed in this listing reproduces the same overall visual impression as my client’s registered EU design and is offered without any licence, consent, or authorisation. 3. Legal Basis for the Complaint A. European Union Law The seller’s actions constitute infringement under Council Regulation (EC) No. 6/2002 on Community Designs, including but not limited to: Article 19(1) – Granting the registered design holder the exclusive right to use the design and to prevent any third party from using it without consent Article 10 – Scope of protection covering any design that does not produce a different overall impression Article 89 – Enforcement measures and remedies in cases of infringement B. German National Law The conduct further violates the German Design Act (Designgesetz), in particular: § 38 – Exclusive rights of the registered design owner § 42 – Infringement through unauthorised manufacture, offering, marketing, or importation C. Amazon Platform Policies The infringing listing is also in breach of Amazon’s policies, including: Amazon Intellectual Property Policy – Prohibition of listing products that infringe registered designs Amazon Anti-Counterfeiting Policy – Prohibiting unauthorised use of protected intellectual property Obligation to remove infringing content upon notification by the rights holder or authorised representative 4. Formal Request to Amazon On behalf of the rights holder, we hereby formally request that Amazon: 1. Immediately remove and disable the infringing listing ASIN: B0FSQZ5412 from Amazon.de 2. Conduct an internal investigation and apply appropriate enforcement measures against Seller ID: A149KZ1RDVH061 3. Confirm removal in writing once enforcement action has been completed 5. Reservation of Rights Should this matter not be resolved promptly and effectively, my client reserves the right to initiate legal proceedings before the competent German District Court (Landgericht) or the EU Community Design Courts, seeking all available remedies, including injunctive relief, damages, and legal costs, without further notice. 6. Rights Holder & Legal Representative Contact Details Rights Holder:Zhang Guanyong Address: Duisburg, North Rhine-Westphalia, Germany Legal Representative: Paul B. Johnson, Attorney at Law Law Office of Paul B. Johnson Address: 8483 S 1275 E, Sandy, UT 84094, USA Phone: (801) 719-5229 Evidence of ownership, including the EUIPO Design Registration Certificate, is attached for your reference. We trust Amazon will act promptly and in accordance with EU law, German law, and its own platform rules. Yours faithfully, Paul B. Johnson Attorney for the EU Design Owner EU Registered Design No. 015117871-0002 Amazon Design Right Infringement Complaint – Evidence List EU Registered Design Certificate ① ② Screenshot of infringing product listing on Amazon ③ Infringing Seller Information ④ Side-by-side comparison of original vs. infringing product My design Infringing product My design Infringing product Screenshot of our company's product page ⑤ POWER OF ATTORNEY ⑥ SATEMENT ⑦