United States v. Hou, 1:25-cv-02719

The United States brought a civil action against Yizhao Hou (aka Harvey Hou) and entities YDH Express Inc. and YDH Int’l Inc., alleging ongoing mail fraud and conspiracy to commit mail fraud.
Investigations by the U.S. Postal Inspection Service between June 2022 and April 2024 found counterfeit postage at defendants’ warehouses.
Defendants previously signed voluntary discontinuances in 2022, promising to stop using counterfeit postage, but investigations indicated ongoing violations.
In 2025, random inspections at the defendants’ warehouse found no physical parcels, but data from Customs and Border Protection showed continued high parcel volumes being shipped to the warehouse.
The Court found probable cause for ongoing mail fraud activity and risk of irreparable harm to the Postal Service if defendants continued operations unchecked.
The Court granted a temporary restraining order (TRO) barring defendants from mailing parcels, conspiring to commit mail fraud, and required preservation of shipping records, pending a preliminary injunction hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable Cause for Mail Fraud	Defendants are actively committing/conspiring to commit mail fraud.	Not stated (ex parte).	Probable cause exists for ongoing mail fraud.
Irreparable Harm	Continued fraud causes untraceable losses to the USPS.	Not stated (ex parte).	Irreparable harm shown if relief is not granted.
Likelihood of Success on Merits	Evidence indicates violation; past agreements ignored by defendants.	Not stated (ex parte).	Plaintiff likely to succeed on the merits.
Notice to Defendants	Immediate order needed to prevent spoliation and further fraud.	Not stated (ex parte).	Ex parte TRO warranted to prevent further harm.

United States v. William Savran & Assocs., 755 F. Supp. 1165 (E.D.N.Y. 1991) (presumption of irreparable harm when statutory conditions under 18 U.S.C. § 1345 are met)