Dongguan Juyuan v. Schedule A: Design Patent Dismissal After 213 Days
Dongguan Juyuan Precision Technology Co., Ltd. filed a design patent infringement action in the Northern District of Illinois against anonymous Schedule A defendants over foldable phone holders and wireless charging stands. After 213 days — with no motion for reconsideration filed — Judge Pallmeyer dismissed the case without prejudice.
Schedule A design patent action ends without merits ruling
On 10 December 2024, Dongguan Juyuan Precision Technology Co., Ltd., a Chinese precision technology manufacturer, filed a design patent infringement action in the Northern District of Illinois, Case No. 1:24-cv-12703. The suit targeted anonymous ‘Schedule A’ defendants — the common e-commerce enforcement mechanism used to pursue multiple online sellers simultaneously — over alleged infringement of two design patents: USD1038108S and USD1019552S, both covering foldable phone holders and foldable wireless charging stands for phones.
On 11 July 2025, Judge Rebecca R. Pallmeyer dismissed the case without prejudice. The court’s minute entry notes that the plaintiff did not file a motion for reconsideration or otherwise pursue the litigation following an earlier court event. Because the dismissal is without prejudice, Dongguan Juyuan retains the legal right to refile the action, though no renewed complaint appears in the public docket as of the dismissal date.
The 213-day duration and the court’s characterisation — that the plaintiff simply ceased pursuing the case — is consistent with outcomes common in Schedule A litigation: plaintiffs frequently obtain early injunctive relief or reach confidential settlements with some defendants, then allow remaining claims to lapse. The public record does not disclose whether any defaults, settlements, or injunctions were obtained before dismissal, leaving the full commercial outcome of this enforcement campaign unclear.
Filing to Dismissed without Prejudice in 213 days
213 days from filing to dismissal — below average for N.D. Illinois patent cases, suggesting early inactivity
Dismissed without prejudice: what the termination means for both parties
Without prejudice: the case ends but the door stays open
A dismissal without prejudice terminates the current action without adjudicating the merits. Unlike a with-prejudice dismissal, it does not bar the plaintiff from refiling the same claims. Here, Judge Pallmeyer’s minute entry makes clear the dismissal was triggered by plaintiff inactivity — not a substantive ruling — meaning no court has assessed whether the Schedule A defendants actually infringed USD1038108S or USD1019552S.
No merits adjudicatedWith or without prejudice? What the public record does — and doesn’t — say
The basis of termination is explicitly ‘dismissed without prejudice.’ This is legally significant: a with-prejudice dismissal would extinguish the plaintiff’s claims permanently, while without-prejudice preserves the right to refile. The court record does not disclose any settlement terms, consent judgments, or injunctions that may have been secured earlier in the proceeding — outcomes that commonly precede inactivity-driven dismissals in Schedule A cases.
Refiling right preservedSchedule A defendants: no injunction on record, but risk persists
Any defendants who were not individually settled with or enjoined earlier in the case are effectively off the hook for now — the dismissal without prejudice clears the immediate litigation threat. However, because the design patents remain valid and enforceable, these sellers face ongoing exposure should Dongguan Juyuan refile or pursue enforcement through alternative channels such as Amazon’s IP complaint system or U.S. Customs recordation.
Patents remain enforceableDesign patent enforcement in foldable accessories remains active risk
This case is consistent with a broader pattern of Chinese OEM design patent holders using Schedule A litigation in N.D. Illinois as a rapid enforcement tool against online marketplace sellers. The without-prejudice dismissal does not signal weakness in the patents themselves — USD1038108S and USD1019552S remain unchallenged on the merits. Sellers of foldable phone holders and wireless charging stands should treat these patents as live enforcement risks.
Ongoing IP enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | DONGGUAN JUYUAN PRECISION TECHNOLOGY CO., LTD | Company | Chinese precision technology manufacturer — holder of USD1038108S and USD1019552SSearch in Eureka ↗ |
| Defendant | THE PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, | Individual | Anonymous online marketplace sellers identified on Schedule A — foldable phone holder marketSearch in Eureka ↗ |
| Plaintiff counsel | Mingzi Ouyang | Attorney | Counsel for DONGGUAN JUYUAN PRECISION TECHNOLOGY CO., LTDSearch in Eureka ↗ |
| Plaintiff law firm | Alioth Law LLP | Law Firm | Representing DONGGUAN JUYUAN PRECISION TECHNOLOGY CO., LTDSearch in Eureka ↗ |
| Presiding judge | Judge Rebecca R. Pallmeyer | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The minute entry is procedural rather than substantive: Judge Pallmeyer terminated the case solely because the plaintiff failed to continue pursuing it — not because of any ruling on infringement, validity, or damages. The phrasing ‘did not file a motion for reconsideration or otherwise pursue this litigation’ suggests a prior court event went unresponded to. This is characteristic of Schedule A cases where the plaintiff’s enforcement objectives have been met through early-stage relief, making further public litigation unnecessary.
USD1038108S & USD1019552S — Foldable Phone Holder and Wireless Charging Stand Designs
USD1038108S (application no. US29/916871) and USD1019552S (application no. US29/878093) are U.S. design patents — a form of IP protection that covers the ornamental appearance of a functional article rather than its underlying mechanics. Design patents protect the specific visual characteristics of foldable phone holders and wireless charging stands, meaning any product that is substantially similar in overall visual impression to the patented designs could constitute infringement under the ‘ordinary observer’ test established in Egyptian Goddess v. Swisa.
In the crowded mobile accessories market, design patents have become a primary enforcement tool for manufacturers seeking to differentiate commodity-like products. Foldable phone holders and wireless charging stands are sold in high volume across Amazon, Temu, and AliExpress, making design patent-based Schedule A campaigns a commercially rational enforcement strategy. With both patents unchallenged on the merits following this dismissal, their enforceability is intact — creating ongoing risk for any seller whose product matches the patented ornamental design.
Should you run an FTO against USD1038108S and USD1019552S?
Any company designing, importing, or distributing foldable phone holders or wireless charging stands in the U.S. market should consider a freedom-to-operate review against both Dongguan Juyuan design patents. These patents have not been invalidated or narrowed by any court ruling. Even after this dismissal, the patents remain fully enforceable, and the plaintiff retains all rights to initiate new enforcement actions — including platform takedowns and fresh district court filings.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD1038108S and USD1019552S against your product designs, identify prosecution history that may inform claim boundaries, and flag related design patent families in the foldable accessories space. For product teams finalising designs ahead of a U.S. market launch, running an Eureka FTO analysis now is substantially cheaper than responding to a Schedule A TRO after launch.
Run a freedom-to-operate analysis on USD1038108S to assess your product’s exposure
Run FTO in Eureka →Similar Design Patent Schedule A Cases in N.D. Illinois
Cases involving design patent enforcement against Schedule A defendants in the Northern District of Illinois, particularly in the consumer electronics accessories sector.
What this case signals for the foldable accessories IP landscape
Schedule A design patent campaigns rarely end on the public record — this dismissal likely reflects off-record activity, not patent weakness.
Without-prejudice dismissal ≠ patent invalidity — risk remains live
No court has assessed the validity or scope of USD1038108S or USD1019552S. Sellers and competing manufacturers of foldable phone holders should not interpret this dismissal as a safe harbour. The patents are enforceable, and Dongguan Juyuan retains the right to refile or pursue platform-level takedowns without any prior ruling limiting claim scope.
Schedule A tactics obscure true enforcement outcomes from public record
The most commercially significant events in Schedule A litigation — TROs, asset freezes, individual settlements — routinely occur before a case goes quiet. That Dongguan Juyuan stopped pursuing the case publicly is consistent with having achieved enforcement goals against key defendants off-record. IP professionals monitoring this space should not rely on docket activity alone as an enforcement signal.
DONGGUAN v PARTNERSHIPS — key questions answered
Dongguan Juyuan Precision Technology Co., Ltd. filed a design patent infringement suit in N.D. Illinois on 10 December 2024 against anonymous Schedule A online sellers over foldable phone holders and wireless charging stands. After 213 days, Judge Pallmeyer dismissed the case without prejudice on 11 July 2025, citing plaintiff inactivity — with no merits ruling on the asserted patents.
Yes. A dismissal without prejudice has no effect on the validity or enforceability of the underlying patents. Neither USD1038108S nor USD1019552S was challenged, narrowed, or invalidated in this proceeding. Dongguan Juyuan retains full rights to enforce both patents in new actions and through platform-level IP complaint mechanisms.
Defendants named on Schedule A face no current court-ordered obligations arising from this case. However, the dismissal without prejudice means Dongguan Juyuan can refile the same infringement claims. Sellers whose products match the ornamental designs in USD1038108S or USD1019552S remain exposed to future enforcement, particularly via Amazon IP complaints or a new district court filing.
The court record does not disclose the reason. The minute entry states only that the plaintiff did not file a motion for reconsideration or otherwise pursue the litigation. In Schedule A cases, this pattern is consistent with plaintiffs having secured early TROs, asset freezes, or confidential settlements with key defendants before allowing remaining claims to lapse — though none of these outcomes are confirmed in the public record here.
Schedule A litigation is a multi-defendant enforcement strategy where a plaintiff sues a large group of anonymous online sellers — named only on a confidential Schedule A attachment — in a single action. The Northern District of Illinois is the dominant venue due to its established practice of granting ex parte TROs and asset freezes in e-commerce IP cases, making it attractive for plaintiffs seeking rapid enforcement against marketplace infringers.
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