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Defendant's business was located. Dill v. Berquist Construction Co. states, "In the absence of a voluntary submission to the authority of the court, compliance with the statutes governing service of process is essential to establish that court's personal jurisdiction over a defendant. When a defendant challenges that jurisdiction by bringing a motion to quash, the burden is on the plaintiff to prove the existence of jurisdiction by proving, inter alia, the facts requisite to an effective service." (Dill v. Berquist Construction Co. (1994) 24 Cal.App.4th 1426, 1439-1440.) Tentatively, the Court plans to GRANT, Defendant Yinming Liu's motion to vacate the default and default judgment entered against Yinming Liu. The Court notes that this order does not apply to the other Defendants, as no other Defendants moved to vacate default/judgment.

/ / The Court is inclined to GRANT attorney's fees and appropriate costs but observes that the amount requested by plaintiff's counsel--more than $115,000--is far outside the range of awards that this Court has given in dozens upon dozens of other similar motions. The Court further notes that the amount requested is far beyond what similarly situated manufacturers in cases with nearly identical procedural histories have requested. The Court will hear from plaintiff's counsel why the request in this case is so far out the heartland of requests in nearly identical cases.

The Court is not inclined to apply a multiplier. The plaintiff has failed to point to any aspect of this case that was novel or required a special level of skill or experience. As noted above, the Court's view is that the demand is, on its face, excessive. The Court's inclination, governed by its experience in previous cases, having handled hundreds of similar cases, is to grant a total award closer to $30,000, plus costs. / / / Case Number: 24NNCV04795 Hearing Date: September 10, 2026 Dept: E / / / / / / The Court is inclined to GRANT the ex parte application, which appears to be unopposed. / / / /