Dongguan Guardian Technology v. Schedule A Defendants — Watch Case Design Patent Dismissed in 17 Days
Dongguan Guardian Technology Co. Ltd. filed suit in the Northern District of Illinois asserting design patent USD1002391S covering a watch case apparatus against a raft of unnamed online sellers. The case was voluntarily dismissed under Rule 41(a)(1) just 17 days after filing, with each party bearing its own costs and none of the defendants ever appearing.
Short-lived Schedule A design patent action ends before any defendant appears
On 9 December 2024, Dongguan Guardian Technology Co. Ltd. filed a patent infringement action in the U.S. District Court for the Northern District of Illinois (Case No. 1:24-cv-12613) before Judge Sunil R. Harjani. The complaint asserted design patent USD1002391S — filed under application number US29/824538 and covering a watch case apparatus — against an undisclosed roster of defendants collectively described as ‘The Partnerships and Unincorporated Associations Identified on Schedule A,’ a common multi-defendant format used in e-commerce enforcement campaigns targeting online marketplace sellers.
On 26 December 2024 — a mere 17 days after filing — the plaintiff filed a Rule 41(a)(1) voluntary dismissal, moving to dismiss all causes of action against the Schedule A defendants. The dismissal motion states that each party shall bear its own attorneys’ fees and costs. The filing notes that none of the listed defendants had appeared, filed an answer, or filed a motion for summary judgment, confirming that dismissal under Rule 41(a)(1) was procedurally available without court approval. The basis of termination is recorded as ‘Voluntary dismissal.’
A 17-day lifecycle is notably brief even by the compressed standards of Schedule A enforcement actions, which often see early voluntary dismissals once defendants settle or when plaintiffs reassess litigation strategy. Whether individual defendants reached confidential settlements, whether service difficulties arose, or whether the plaintiff identified procedural issues prior to service remains unknown from the public record. The absence of any defendant appearance means the merits of the design patent claim were never tested in this case.
Filing to Voluntary dismissal in 17 days
17 days — resolved before most defendants could be served
Voluntarily dismissed: what the Rule 41(a)(1) filing means for both parties
Rule 41(a)(1): plaintiff’s unilateral right to dismiss
Under Federal Rule of Civil Procedure 41(a)(1), a plaintiff may voluntarily dismiss an action without a court order at any point before the defendant serves an answer or a motion for summary judgment. Because none of the Schedule A defendants appeared or filed any responsive pleading, the plaintiff could file the dismissal as of right. No judicial approval was required, and the case closed automatically upon filing.
No court order neededThe record is silent on with- or without-prejudice status
The verdict text states dismissal of ‘all causes of action’ under Rule 41(a)(1) but does not expressly specify whether the dismissal is with or without prejudice. Under Rule 41(a)(1)(B), a first-time voluntary dismissal is presumed without prejudice unless the notice states otherwise. However, the public record does not confirm this, and practitioners should not assume re-filing rights without reviewing the full dismissal filing. The basis of termination recorded is simply ‘Voluntary dismissal.’
Prejudice status unconfirmedNo appearance, no merits ruling — defendants face residual uncertainty
None of the Schedule A defendants appeared, meaning no invalidity or non-infringement defences were placed on the record. While the dismissal ends this specific action, defendants who sell watch case apparatus products covered by the USD1002391S design remain potentially exposed to a re-filed action by the same plaintiff, particularly if the dismissal is without prejudice. The cost-neutrality order provides no fee recovery for any defendant.
Merits untestedDesign patent Schedule A campaigns: enforcement or leverage?
Actions terminated this quickly — before any defendant appears — are consistent with two patterns: confidential pre-dismissal settlements with individual sellers, or a plaintiff reassessing the strength of its Schedule A list. For e-commerce sellers in the wearables and watch accessories space, this case signals that USD1002391S remains an active enforcement asset. Design patent holders in consumer electronics continue to use the Northern District of Illinois as a preferred venue for Schedule A campaigns.
Watch accessories sector riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dongguan Guardian Technology Co. Ltd. | Company | Consumer electronics design IP holder — owner of watch case apparatus design patent USD1002391SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Unnamed online marketplace sellers identified collectively on Schedule A to the complaintSearch in Eureka ↗ |
| Plaintiff counsel | Depeng Bi | Attorney | Counsel for Dongguan Guardian Technology Co. Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Konrad Val Sherinian | Attorney | Counsel for Dongguan Guardian Technology Co. Ltd.Search in Eureka ↗ |
| Plaintiff law firm | The Law Offices of Konrad Sherinian LLC | Law Firm | Representing Dongguan Guardian Technology Co. Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Sunil R. Harjani | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The plaintiff’s Rule 41(a)(1) filing confirms a clean procedural exit: because no Schedule A defendant answered or filed a dispositive motion, the dismissal required no court order and was effective on filing. The cost-neutrality clause — ‘each party shall bear its own attorneys’ fees and costs’ — is standard in unopposed Schedule A dismissals and does not reflect a merits adjudication. The design patent USD1002391S was neither upheld nor challenged; its validity and scope remain entirely open for future proceedings.
USD1002391S — Watch Case Apparatus Design Patent
USD1002391S is a U.S. design patent — filed as application US29/824538 — protecting the ornamental appearance of a watch case apparatus. Design patents protect the visual, non-functional characteristics of a manufactured article, granting the holder the right to exclude others from making, using, or selling products with a substantially similar appearance. The filing falls within the wearables and watch accessories product category, a segment that has seen significant design patent enforcement activity as consumer demand for smartwatch and fashion watch accessories has grown.
For competitors and e-commerce sellers in the watch accessories space, USD1002391S represents an active enforcement asset held by a Chinese-domiciled technology company. Design patents in this category are frequently used in Schedule A campaigns targeting online marketplace sellers, and the visual claim scope can encompass a range of similar watch case form factors. Companies developing or sourcing watch case products should treat this patent as a material freedom-to-operate consideration, particularly given the plaintiff’s willingness to file in U.S. federal court.
Should your product team run an FTO check against USD1002391S?
Any company designing, importing, or selling watch case apparatus products — whether for smartwatches, fashion watches, or wearable accessories — should assess whether its product design falls within the visual claim scope of USD1002391S. E-commerce sellers listing on platforms such as Amazon, eBay, or Alibaba-connected storefronts are precisely the defendant profile targeted in this Schedule A action. Given the plaintiff’s demonstrated willingness to enforce in U.S. federal court, an FTO review is warranted before new product lines are committed to tooling or inventory.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD1002391S against your specific product designs, identify prior art that could narrow or invalidate the claim, and surface related applications or continuations in the US29/824538 family. Eureka can also flag new Schedule A filings by Dongguan Guardian Technology Co. Ltd. across U.S. district courts, giving product and legal teams early warning of enforcement activity before a complaint reaches their marketplace storefront.
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 the Northern District of Illinois
Comparable Schedule A design patent enforcement actions involving consumer electronics and wearable accessories filed in the Northern District of Illinois.
What this case signals for the watch accessories design patent landscape
A 17-day voluntary dismissal in a Schedule A action rarely signals the end of enforcement — it often signals a pivot.
Design patent Schedule A actions can close before merits are ever tested
This case closed 17 days after filing with no defendant appearance and no judicial ruling on infringement or validity. For sellers of watch case products on e-commerce platforms, that means the design patent USD1002391S was never invalidated or narrowed. The plaintiff retains full enforcement rights and the freedom to refile against the same or different defendants.
Northern District of Illinois remains a high-velocity Schedule A venue
The Northern District of Illinois is one of the most active venues for Schedule A multi-defendant design patent actions. Cases here move fast — both in filing and in dismissal. Sellers and platforms operating in the watch accessories category should monitor new filings in this district as an early-warning signal of enforcement campaigns targeting their product category.
Dongguan v Partnerships — key questions answered
Dongguan Guardian Technology Co. Ltd. filed a design patent infringement action on 9 December 2024 in the Northern District of Illinois asserting USD1002391S against unnamed Schedule A defendants. The plaintiff voluntarily dismissed all claims under Rule 41(a)(1) on 26 December 2024 — 17 days after filing — with each party bearing its own costs. No defendant ever appeared in the case.
USD1002391S is a U.S. design patent filed as application US29/824538 by Dongguan Guardian Technology Co. Ltd. It covers the ornamental design of a watch case apparatus. Design patents protect the visual appearance of a product rather than its functional features, and infringement is assessed by whether an ordinary observer would find the accused product substantially similar in appearance to the patented design.
Rule 41(a)(1) allows a plaintiff to dismiss an action as of right — without a court order — before any defendant serves an answer or motion for summary judgment. In Schedule A cases, this mechanism is commonly used when defendants settle privately before appearing, or when a plaintiff reassesses its defendant list. The patent’s validity and infringement scope are not adjudicated, and the plaintiff typically retains the right to refile.
No. The case was voluntarily dismissed before any defendant appeared, answered, or filed any responsive pleading. There was no judicial ruling on infringement or validity. The design patent USD1002391S was neither upheld nor challenged on the merits in this proceeding, meaning its scope and enforceability remain entirely open.
Under Rule 41(a)(1)(B), a first voluntary dismissal is presumed without prejudice, which would allow refiling against the same or different defendants. The public record in this case does not expressly confirm the dismissal is without prejudice, but the procedural posture is consistent with that presumption. Companies selling watch case apparatus products on online marketplaces should monitor for new Schedule A filings by Dongguan Guardian Technology in U.S. district courts.
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