When a Chinese factory refuses to release molds, tooling, dies, product files, or samples after a sourcing relationship breaks down, the record should prove who paid for the tooling and who has the right to control it.
Collect tooling invoices, purchase orders, mold-fee receipts, ownership clauses, design-file records, and communications about who may use or move the tooling.
Document the factory address, warehouse location, photos, serial numbers, sample runs, export history, and refusal-to-release messages.
Decide whether the case needs damages, return of property, injunction planning, Hague service, or coordinated China-side counsel before filing.
A mold or tooling dispute often combines contract, property, trade-secret, and supply-chain leverage issues. The buyer may need proof that it paid for the tooling, that the manufacturer agreed not to use it for others, and that the factory still controls the item.
Collect tooling purchase orders, mold-fee invoices, wire records, design files, CAD ownership notes, sample approvals, production run records, quality inspection reports, release demands, refusal messages, and any non-use or exclusivity terms.
The entity that took payment may not be the entity holding the mold. Before translating a complaint for Hague service, counsel should compare the contract seller, factory, exporter, affiliated manufacturer, and address records so the right defendants and remedies are named.
Do not frame the dispute only as “the factory has my mold.” Preserve the payment, ownership, design, possession, and refusal records so counsel can evaluate damages, injunction strategy, service validity, and recovery leverage.
Possibly. The strongest case usually needs tooling ownership terms, payment records, possession evidence, jurisdiction facts, defendant identity, and a realistic enforcement or recovery strategy.
Tooling invoices, wire records, purchase orders, contract clauses, design files, sample approvals, factory communications, and release demands can help show who paid for and controlled the tooling.
If the manufacturer or trading company is in mainland China, valid Hague service and consistent translated exhibits help protect motion practice, default posture, settlement leverage, and recovery planning.