Dongguan Guardian Technology v. Schedule A Defendants: Watch Case Design Patent Dismissed
Dongguan Guardian Technology Co., Ltd. filed suit in the Northern District of Illinois asserting design patent USD1002391S — covering a watch case — against a broad class of unnamed e-commerce defendants. The action lasted just 36 days before plaintiff voluntarily dismissed without prejudice under Rule 41(a)(1)(A)(i), with no defendant having filed any responsive pleading.
Schedule A watch case design suit ends in swift voluntary dismissal
On 18 August 2025, Dongguan Guardian Technology Co., Ltd., a Dongguan-based technology company, filed a design patent infringement action (Case No. 1:25-cv-09869) in the U.S. District Court for the Northern District of Illinois before Judge April M. Perry. The complaint asserted U.S. Design Patent USD1002391S — application number US29/824538 — which covers the ornamental design of a watch case. Defendants were named collectively as ‘The Corporations, Partnerships, and Unincorporated Associations Identified on Schedule A,’ a pleading format common in e-commerce enforcement campaigns targeting multiple online sellers simultaneously.
On 23 September 2025, just 36 days after filing, plaintiff’s counsel at Valley & Summit Law filed a notice of voluntary dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), dismissing the action without prejudice. The filing expressly confirmed that no defendant had filed an answer, motion for summary judgment, or any other responsive pleading — the procedural precondition that permits a plaintiff to dismiss unilaterally as of right. Because the dismissal was entered without prejudice, the public record leaves open whether plaintiff reached informal resolutions with some defendants or simply elected to withdraw for tactical reasons.
A 36-day lifecycle is consistent with Schedule A enforcement campaigns that use the threat of early injunctive relief to prompt quick settlements or capitulation before defendants formally appear. The absence of any defendant counsel of record and the lack of a cost or fee order suggests either that no defendant engaged litigation counsel in time, or that any resolution occurred outside court filings entirely. What drove the specific decision to dismiss — settlement, inability to identify or serve defendants, or a strategic reset — is not disclosed in the public record.
Filing to Voluntary dismissal in 36 days
36-day case duration — well below the district median for IP actions, suggesting an early strategic resolution
Voluntarily dismissed: what the Rule 41 withdrawal means for both sides
Rule 41(a)(1)(A)(i): plaintiff’s right to dismiss before any response
Under Federal Rule of Civil Procedure 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order simply by filing a notice — but only before the defendant serves an answer or a motion for summary judgment. Here, no defendant filed any responsive pleading, so Dongguan Guardian exercised this right unilaterally. The court itself took no substantive action on the merits.
No court merits rulingDismissed without prejudice — but the record is silent on why
A dismissal without prejudice means plaintiff retains the right to refile the same claims against the same defendants in the future, subject to any applicable statute of limitations. A dismissal with prejudice, by contrast, would bar refiling permanently. Here, the notice expressly states ‘without prejudice.’ The public record does not disclose whether this reflects an out-of-court settlement, a tactical pause, or a decision to pursue different defendants — those distinctions remain unknown from the filed documents alone.
Refiling remains possibleDefendants face no judgment — but exposure may persist
Because the case was dismissed without prejudice and no defendant entered an appearance, no defendant obtained a merits ruling, a finding of non-infringement, or any fee award. This means defendants cannot rely on this dismissal as a shield against a future suit on the same patent. Sellers of watch cases covered by USD1002391S should treat this outcome as a temporary reprieve rather than a permanent resolution of their IP exposure.
No non-infringement findingSchedule A tactics: speed and uncertainty remain the plaintiff’s leverage
Schedule A enforcement campaigns — where dozens of unnamed e-commerce defendants are sued simultaneously — are designed to generate early TRO applications, asset freezes, and settlement pressure before defendants can organise a defence. A rapid voluntary dismissal without prejudice is consistent with this playbook: patent holders may secure informal resolutions with individual sellers without creating public precedent. Remaining defendants and competing watch case sellers should monitor USD1002391S for renewed enforcement activity.
Watch for refilingFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dongguan Guardian Technology Co., Ltd. | Company | Consumer electronics design IP holder — holder of USD1002391S (watch case ornamental design)Search in Eureka ↗ |
| Defendant | The Corporations, Partnerships, and Unincorporated Associations Identified on Schedule A | Individual | Anonymous e-commerce sellers identified on Schedule A — unnamed corporations, partnerships, and associationsSearch in Eureka ↗ |
| Plaintiff counsel | Mingzi Ouyang | Attorney | Counsel for Dongguan Guardian Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Valley & Summit Law | Law Firm | Representing Dongguan Guardian Technology Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge April M. Perry | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The voluntary dismissal notice confirms compliance with the strict procedural prerequisites of Rule 41(a)(1)(A)(i): no defendant had filed an answer, a motion for summary judgment, or any other responsive pleading. This phrasing is legally significant — it establishes that plaintiff acted as of right, requiring no court approval. The court entered no substantive order and made no findings on infringement, patent validity, or claim scope. For defendants, the absence of a merits ruling means no estoppel or non-infringement finding was created. For the patent, USD1002391S remains fully enforceable and unreviewed by any court.
USD1002391S — Ornamental Design for a Watch Case
U.S. Design Patent USD1002391S, filed under application number US29/824538, protects the ornamental appearance of a watch case — the external housing that encases a watch movement or smart watch module. Design patents in the United States protect only non-functional aesthetic elements: the specific shape, configuration, and surface ornamentation as depicted in the patent drawings. Unlike utility patents, design patents do not protect the underlying functionality of the product. The scope of USD1002391S is therefore defined entirely by the visual impression conveyed by its figures.
Watch case designs are a high-volume enforcement category, particularly against e-commerce sellers who source from manufacturers offering near-identical aesthetic variants of popular designs. A single design registration like USD1002391S can be asserted against dozens or hundreds of online listings simultaneously via Schedule A complaints. For competitors and OEM suppliers in the watch accessories and wearables space, this patent represents a meaningful clearance risk — particularly for products that replicate the silhouette, bezel geometry, or surface detailing depicted in the USD1002391S drawings. Validity challenges via USPTO ex parte reexamination or IPR (if a utility counterpart exists) may be available avenues for affected parties.
Should your product team run an FTO against USD1002391S?
Any company designing, importing, or selling watch cases — particularly through Amazon, eBay, Walmart Marketplace, or similar platforms — should assess whether its products fall within the ornamental scope of USD1002391S. Schedule A plaintiffs typically target visual similarities that would strike an ordinary observer as substantially the same. Products that share the same general silhouette, bezel shape, or surface detailing as the patented design carry meaningful infringement risk, even if sourced from a different manufacturer or sold under a different brand name.
PatSnap Eureka’s FTO Search Agent allows product and IP teams to map USD1002391S’s visual claim scope against your current and planned watch case designs, identify prior art that may limit the patent’s enforceable scope, and flag related design families that could affect your clearance position. Eureka also tracks new litigation filings citing this patent, so you receive early warning before a Schedule A complaint names your platform storefronts.
Run a freedom-to-operate analysis on USD1002391S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in consumer electronics and wearables
Cases citing design patents on watch cases and wearable accessories filed in the Northern District of Illinois follow recognisable Schedule A enforcement patterns — see comparable actions below.
What this case signals for the watch case and wearables design IP landscape
Schedule A campaigns around consumer electronics design patents are accelerating. This case illustrates how quickly enforcement cycles can turn.
Design patents on consumer electronics move fast — prepare before you receive a complaint
This case opened and closed in 36 days, faster than many defendants can even retain counsel. Companies selling watch cases or wearable accessories on e-commerce platforms should conduct proactive FTO searches against active design patents like USD1002391S before listing products, not after receiving a complaint.
Voluntary dismissal without prejudice is not clearance — monitor for refiling
A Rule 41(a)(1)(A)(i) dismissal without prejudice leaves the plaintiff’s claims fully intact. Any seller named on the Schedule A — or a successor Schedule A — in a refiled action faces the same legal exposure. IP monitoring tools that track new filings citing USD1002391S or its application number US29/824538 are essential for ongoing risk management.
Dongguan v Corporations — key questions answered
USD1002391S is a U.S. design patent filed under application number US29/824538 that protects the ornamental design — the visual appearance — of a watch case. In Case No. 1:25-cv-09869, Dongguan Guardian Technology asserted this patent against unnamed e-commerce sellers. The case was voluntarily dismissed without prejudice after 36 days.
A voluntary dismissal without prejudice means Dongguan Guardian ended the case without any court ruling on the merits, and retains the right to refile the same claims in the future. No finding of infringement or non-infringement was made. The defendants received no legal protection against a subsequent suit on the same patent.
The public record does not disclose the reason. A Rule 41(a)(1)(A)(i) dismissal is available as of right before any defendant files a responsive pleading. Common drivers in Schedule A cases include out-of-court settlements with individual sellers, strategic resets to refile against a different defendant list, or inability to complete service. No cost or fee order was entered, suggesting no defendant formally engaged counsel.
Yes. Because the dismissal was entered without prejudice, plaintiff’s claims are not extinguished. Dongguan Guardian — or any future assignee of USD1002391S — could refile against the same or different defendants subject to the applicable statute of limitations. Sellers of watch cases that resemble the patented design should not treat this dismissal as a clearance event.
The case was filed in the U.S. District Court for the Northern District of Illinois (Case No. 1:25-cv-09869) and assigned to Judge April M. Perry. The case closed on 23 September 2025 following plaintiff’s voluntary dismissal notice, before any substantive judicial rulings were issued.
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