XYZ Limited v. Seller Associations: Strategic Dismissal in Tray Table Patent Campaign
Updated on Dec. 12, 2025 | Written by Patsnap Team
In a strategic conclusion to a notable enforcement action, the patent infringement case XYZ Limited v. The Partnerships and Unincorporated Associations Identified on Schedule A ended not with a ruling on the merits, but with a voluntary dismissal by the plaintiff. Filed in the U.S. District Court for the Northern District of Illinois (Case No. 1:24-cv-07649), the action by Shenzhen Super Top Innovation Technology Limited (doing business as XYZ Limited) against numerous online sellers was dismissed without prejudice after 414 days . This outcome provides a clear window into the calculated, often multi-phase nature of modern patent enforcement against diffuse online marketplaces. For patent attorneys and R&D leaders, this case underscores that the filing of a lawsuit can be an opening tactical move rather than a direct path to trial, with significant implications for managing litigation risk and cost.
Case Summary
| Field | Details |
|---|---|
| Case Name | Shenzhen Super Top Innovation Technology Limited (XYZ Limited) v. The Partnerships and Unincorporated Associations Identified on Schedule A |
| Case Number | 1:24-cv-07649 |
| Court | Illinois Northern District Court (District Court) |
| Filing/Closure | Filed Aug. 26, 2024 |
| Outcome | Voluntarily dismissed without prejudice by the plaintiff under FRCP 41(a)(1)(A)(i). |
| Patents | U.S. Design Patent D1,014,118 S (Tray Table) and U.S. Utility Patent 11,452,371 B1 (Sofa Frame) . |
| Products | Sofa tray tables (also called couch trays or sofa shelves) with features like a 360° rotating phone holder . |
| Plaintiff Counsel | Law Firm: Concord & Sage PC |
| Defendant Counsel | Not available (Defendant associations had not filed an answer or appeared by counsel at dismissal). |
| Termination Basis | Voluntary Dismissal |
Case Overview
The Parties: The plaintiff, Shenzhen Super Top Innovation Technology Limited, is a China-based company specializing in designing and selling innovative tray tables for sofas and chairs . The defendants were a group of anonymous online sellers, typical in “Schedule A” litigation, who were allegedly selling similar products on e-commerce platforms.
The Patent(s) at Issue: The asserted intellectual property included two U.S. patents:
- U.S. Design Patent No. D1,014,118 S: Titled “Tray Table,” this patent protects the ornamental design of the product.
- U.S. Utility Patent No. 11,452,371 B1: Titled “Sofa Frame,” this patent likely covers functional aspects of the tray table’s assembly, structure, or mounting mechanism .
You can view the details of these patents on the USPTO Patent Public Search tool.
Legal Representation: The plaintiff was represented by Concord & Sage PC, a firm with notable experience in intellectual property and representing Chinese rights holders in U.S. district courts . This case highlights a common enforcement model, and you can analyze similar litigation patterns on Patsnap Eureka IP.
Litigation Timeline & Procedural History
The case was filed on August 26, 2024, in the Illinois Northern District Court, a favored venue for intellectual property cases against online sellers due to its established procedures. Public docket information, which can be accessed via PACER or CourtListener [External Link to CourtListener], indicates the plaintiff sought but faced challenges in obtaining a Temporary Restraining Order (TRO) early in the case .
💡 Key Insight: The reported initial denial of a TRO is a critical procedural hurdle. Success on a TRO motion requires a strong showing of immediate, irreparable harm. This early setback can significantly influence a plaintiff’s cost-benefit analysis for continuing the lawsuit.
Chief Judge Edmond E. Chang presided. The case concluded 414 days later when the plaintiff filed a Notice of Voluntary Dismissal under Federal Rule of Civil Procedure 41(a)(1)(A)(i), before the defendants had served an answer or motion for summary judgment.
The Verdict & Legal Analysis
Outcome: Strategic Voluntary Dismissal
The plaintiff unilaterally dismissed the entire action without prejudice. This means the claims are not adjudicated on their merits, and the plaintiff is legally permitted to refile the same claims against the same parties in the future.
Legal & Strategic Analysis
This outcome is a classic feature of large-scale enforcement campaigns rather than an admission of a weak case. Several strategic motivations likely contributed:
- Cost-Benefit Recalibration: After initial proceedings, the cost of litigating against numerous, often unresponsive defendants may outweigh the potential recovery.
- Enforcement Goals Partially Met: The lawsuit itself, and any associated take-down notices sent to platforms, may have already cleared significant infringement from the marketplace.
- Portfolio & Strategy Repositioning: The plaintiff may have decided to re-file a more targeted action or shift focus to newer patents. In fact, the same plaintiff filed a new 2025-cv-12598 case for tray table patents with a different law firm, indicating an ongoing, adaptive enforcement campaign .
The legal basis was purely procedural, hinging on the defendants’ failure to answer. For patent holders, this underscores the tactical flexibility of FRCP 41. For accused infringers, it highlights that a dismissal without prejudice does not provide permanent safe harbor from future suits. Understanding the nuances of patent validity and claim construction is essential for both sides in such disputes. To research the strength of patent portfolios involved in such cases, you can use tools like Patsnap Eureka IP.
Industry & Competitive Implications
This case is a textbook example of a Schedule A “SAD” (Single-Action Against Defaulters) litigation common in e-commerce. Its lifecycle reflects a broader industry trend where lawsuits are tools for market correction and negotiation.
💡 Key Insight: A voluntary dismissal is not a defeat. It can be a strategic reset. For R&D and product teams, this pattern means that a competitor’s withdrawn lawsuit does not guarantee your product is safe; a new, refined action may follow.
For online sellers, this environment makes rigorous Freedom to Operate (FTO) analysis and understanding supply chain IP indemnities critical. As shown in a separate but instructive case from the same court, defendants who actively challenge jurisdiction or the plaintiff’s evidence can sometimes achieve full dismissal with prejudice .
For all players, this case reinforces that the Illinois Northern District Court remains a central battleground for online product patent infringement disputes. Tracking these litigation trends is vital, a task for which a platform like Patsnap Eureka IP is well-suited.
Key Takeaways
- ⚖️ For Patent Attorneys: A voluntary dismissal without prejudice under FRCP 41 is a standard strategic tool in mass-enforcement campaigns. It preserves claims while controlling cost, but requires careful timing before defendant responses.
- 🔬 For R&D & Product Teams: The prevalence of this litigation model makes proactive FTO and prior art searches non-negotiable for any physical product sold online. Design-arounds should be considered.
- 📊 For IP Professionals: Enforcement is often a campaign, not a single battle. Monitor for sequential filings by the same plaintiff, potentially with different patents or law firms, as seen here .
- ⚖️ For Defendants: Proactive defense, including challenging jurisdiction or willful infringement allegations, can be effective. Default judgments are common, but successful challenges are possible .
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To explore similar patent litigation cases, track global enforcement trends, or conduct deep patent landscape analysis, start your research on Patsnap Eureka IP.
