- 15 A B A 64. D4 has its place of business in Shanghai City. D4 was the B shipper named on the packages containing the purchases made of C D E F infringing products from the Glamulet websites as set out in the 1st affidavit of Elms. 65. Also, as set out at para 106 of the 1st affidavit of Elms, a paralegal of the Shanghai office of the plaintiffs’ solicitors visited C D E F the Shanghai addresses of D4 on 7 December 2015 but was unable to find G H I J any signage to suggest that any of the defendants operated from the Shanghai addresses. 66. The evidence filed on behalf of D1, D2, D5 and D6 is contained in the affirmations of Qian Zhenhua (“Qian”) who is the manager G H I J of D1 and D2. He has been authorized by D1, D2, D5 and D6 to file his K affirmations on behalf of them. L L 67. M N O P Q R K Qian said that D1 was incorporated in Hong Kong “as online shoppers from the rest of the world prefer to deal with a Hong Kong company by credit card or Paypal”. 68. Qian’s evidence is that the Glamulet’s main place of business and operation centre is not in Hong Kong but in Shanghai. 69. Qian also denies that D2 is in the business of marketing jewellery. His evidence is that D2 has at all material times been in the M N O P Q R business of marketing and promoting hair extension products. S S T T U U V V