Dongguan Fangde v. Schedule A Defendants: Metal Hook Design Patent Dismissed in 35 Days
Dongguan Fangde Network Technology Co., Ltd. brought a design patent infringement action in the Northern District of Illinois over USD1005088S, a design patent covering a metal hook. The plaintiff voluntarily dismissed all defendants without prejudice after just 35 days — before any defendant filed an answer or summary judgment motion.
A rapid Schedule A enforcement action ends before any defendant responds
On August 8, 2025, Dongguan Fangde Network Technology Co., Ltd., a Chinese technology company, filed a patent infringement complaint in the U.S. District Court for the Northern District of Illinois before Judge Steven C. Seeger. The action targeted the broad class of defendants identified on Schedule A — an enforcement mechanism commonly used against e-commerce sellers — asserting infringement of USD1005088S, a U.S. design patent covering the ornamental appearance of a metal hook.
The case closed on September 12, 2025, just 35 days after filing. Plaintiff invoked Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure to dismiss all causes of action against all defendants, noting that no defendant had filed an answer or motion for summary judgment. The dismissal notice specified that each party would bear its own attorney’s fees and costs, and confirmed that no defendants remained in the case upon filing.
A 35-day lifecycle is notably short even by the compressed standards of Schedule A e-commerce enforcement cases, which often resolve quickly through settlement or default. The public record does not disclose whether the dismissal followed private settlements, a failure to identify viable defendants, or a strategic reassessment. The ‘without prejudice’ characterisation — confirmed in the verdict text — preserves Fangde’s right to refile against the same parties in future, though the record does not indicate whether this option is likely to be exercised.
Filing to Voluntary dismissal in 35 days
35 days — resolved significantly faster than the median N.D. Ill. patent case
Voluntarily dismissed: what the Rule 41 filing means for both parties
Rule 41(a)(1)(A)(i): dismissal as of right before any response
Under Federal Rule of Civil Procedure 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order if no defendant has served an answer or motion for summary judgment. That threshold was met here — no defendant had responded. This makes the dismissal self-executing: it takes effect upon filing and requires no judicial approval, which explains the case’s unusually brief 35-day lifespan.
No court order requiredThe public record confirms dismissal — but the effect on re-filing warrants scrutiny
The verdict text explicitly states dismissal ‘without prejudice,’ meaning the plaintiff retains the right to refile against the same defendants in future. A ‘with prejudice’ dismissal would permanently bar refiling. The distinction is commercially significant: without-prejudice dismissals in Schedule A cases sometimes follow confidential settlements or defendant identification issues, and do not necessarily signal the plaintiff has abandoned enforcement of the underlying patent.
Without prejudice confirmedDefendants exit without adjudication — but exposure may not be over
Because no defendant filed a responsive pleading, no party obtained a merits ruling, a declaratory judgment of non-infringement, or an invalidity finding. Schedule A defendants who were identified but not served, or who were served but did not respond, face the possibility of refiling. The without-prejudice nature of the dismissal means the design patent USD1005088S remains enforceable and the plaintiff retains full standing to pursue future actions.
No merits adjudicationDesign patent enforcement via Schedule A: a pattern worth monitoring
This case is consistent with a common N.D. Illinois enforcement strategy: file against a broad class of e-commerce defendants, obtain a TRO or asset freeze if possible, and resolve quickly — often before any defendant formally appears. The swift voluntary dismissal, with each side bearing its own costs, suggests the action achieved its purpose or became unviable early. E-commerce sellers in the metal hardware and accessories category should treat this as a signal that USD1005088S is being actively enforced.
E-commerce enforcement patternFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dongguan Fangde Network Technology Co., Ltd. | Company | Chinese network technology company — holder of design patent USD1005088S for a metal hookSearch in Eureka ↗ |
| Defendant | The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A | Individual | Schedule A e-commerce sellers: unnamed individuals, corporations, LLCs, partnerships, and unincorporated associationsSearch in Eureka ↗ |
| Plaintiff counsel | Abby Marie Neu | Attorney | Counsel for Dongguan Fangde Network Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Keaton David Smith | Attorney | Counsel for Dongguan Fangde Network Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Michael Mitchell | Attorney | Counsel for Dongguan Fangde Network Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Ryan Evan Carreon | Attorney | Counsel for Dongguan Fangde Network Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Shengmao Mu | Attorney | Counsel for Dongguan Fangde Network Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Whitewood Law, PLLC | Law Firm | Representing Dongguan Fangde Network Technology Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Steven C. Seeger | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) — a unilateral, as-of-right mechanism available only when no defendant has served a responsive pleading. The explicit confirmation that ‘no defendants remain in the case’ closes the docket entirely. Critically, the text specifies dismissal ‘without prejudice,’ preserving the plaintiff’s ability to refile. The cost-bearing clause — each party bearing its own fees — is consistent with standard voluntary dismissal practice and does not suggest any underlying settlement payment was recorded in the public docket.
USD1005088S — Ornamental design for a metal hook
USD1005088S is a U.S. design patent, filed under application number US29/893595, protecting the ornamental appearance of a metal hook. Design patents grant a 15-year term of protection from grant and cover only the visual characteristics shown in the patent drawings — not the functional aspects of the product. The ‘USD’ prefix confirms this is a granted design patent. In the e-commerce hardware accessories market, design patents on commodity-adjacent items like hooks are frequently asserted against online sellers on platforms such as Amazon and Alibaba.
For the metal hook and hardware accessories sector, USD1005088S represents a meaningful enforcement asset in the hands of a Chinese manufacturer seeking to protect its product design in the U.S. market. The Schedule A enforcement model — targeting multiple unnamed sellers simultaneously — is a cost-effective strategy to suppress copycat listings across e-commerce platforms. Competitors and private-label sellers offering visually similar metal hooks should treat this patent as an active enforcement risk, particularly given the without-prejudice dismissal that leaves the plaintiff free to refile.
Should your product team run an FTO against USD1005088S?
Any company sourcing, importing, or listing metal hooks — or visually similar hardware accessories — for sale in the U.S. market should assess their exposure to USD1005088S. This is particularly relevant for Amazon, Walmart Marketplace, and Shopify sellers whose product imagery or physical design could be compared against the patent’s drawings. The without-prejudice dismissal in this case means the patent holder retains full enforcement rights and has demonstrated a willingness to litigate in N.D. Illinois.
PatSnap Eureka’s FTO Search Agent can rapidly map USD1005088S against your product’s visual design, identify prior art that may support a validity challenge, and benchmark the patent’s drawings against existing commercial designs. For Schedule A targets — where asset freezes can occur with little warning — a pre-emptive FTO review is a low-cost hedge against a high-impact enforcement event. Eureka’s design patent analytics also surface related design filings from the same applicant, revealing broader portfolio risk.
Run a freedom-to-operate analysis on USD1005088S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois
Explore comparable design patent infringement actions filed against Schedule A e-commerce defendants in the Northern District of Illinois federal court.
What this case signals for the design patent enforcement IP landscape
Short-lifecycle Schedule A cases are not routine filings — they carry specific risks and opportunities for both enforcement targets and design patent holders.
Without-prejudice dismissal keeps enforcement options alive for Fangde
The plaintiff’s right to refile against the same Schedule A defendants is preserved. E-commerce sellers in the metal hook and hardware accessories space who believe they were on the original Schedule A should assess their exposure to USD1005088S before assuming this matter is closed.
No defendant response means no invalidity record was created
Because no defendant filed an answer, counterclaim, or IPR petition, the patent exits this litigation without any invalidity arguments on the public record. The design patent USD1005088S remains unchallenged and fully enforceable — a stronger posture for future enforcement rounds.
Dongguan v Individuals — key questions answered
Dongguan Fangde filed a design patent infringement action in the Northern District of Illinois on August 8, 2025, asserting USD1005088S against unnamed Schedule A e-commerce defendants. The plaintiff voluntarily dismissed all defendants without prejudice on September 12, 2025 — 35 days after filing — under Rule 41(a)(1)(A)(i), with each party bearing its own costs. No defendant had filed a responsive pleading before dismissal.
A without-prejudice dismissal means the plaintiff retains the right to refile the same claims against the same defendants in future. Defendants received no merits ruling, no finding of non-infringement, and no invalidity determination. They remain exposed to re-litigation if the plaintiff chooses to refile. The dismissal does not extinguish the enforceability of USD1005088S.
USD1005088S is a U.S. design patent (application no. US29/893595) held by Dongguan Fangde Network Technology Co., Ltd. It protects the ornamental appearance of a metal hook. Design patents cover visual characteristics only — not function — and carry a 15-year term from grant. The patent has been used in at least one Schedule A enforcement action in N.D. Illinois.
The Schedule A mechanism allows a plaintiff to file a single complaint against a large number of unnamed e-commerce sellers, identified only on a confidential schedule filed with the court. This is efficient for targeting multiple allegedly infringing listings simultaneously. N.D. Illinois is a preferred venue for such actions due to its familiarity with the procedure and its willingness to grant ex parte TROs and asset restraining orders early in litigation.
Yes. Because the dismissal was explicitly without prejudice under Rule 41(a)(1)(A)(i), Dongguan Fangde preserves the right to refile against the same defendants. However, a second voluntary dismissal of the same claims against the same parties would operate as a dismissal with prejudice under the ‘two-dismissal rule’ in Rule 41(a)(1)(B). The public record does not indicate whether refiling is planned.
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