Dongguan Naquan v. Sanbo Wang: Camping Lights Patent Case Transferred to E.D. Virginia
Dongguan Naquan E-Commerce filed a patent infringement action against Sanbo Wang over camping string lights technology in Illinois, only for the case to be transferred to the Eastern District of Virginia under 35 U.S.C. § 293 within 46 days. The unopposed transfer motion signals a jurisdictional pivot that resets the litigation timeline.
A patent venue pivot: why this case landed in Virginia, not Illinois
On June 13, 2025, Dongguan Naquan E-Commerce Co., Ltd. filed a patent infringement action in the Northern District of Illinois against defendant Sanbo Wang, asserting rights under US1058875A covering camping string lights. The complaint alleged infringement of decorative outdoor LED lighting technology. The case was assigned to Judge Manish S. Shah and represented on the plaintiff side by Glacier Law LLP.
Before any merits ruling could be reached, the court granted an unopposed motion to transfer the case to the United States District Court for the Eastern District of Virginia on July 29, 2025 — just 46 days after filing. The transfer was ordered pursuant to 35 U.S.C. § 293, a provision specifically governing actions against foreign defendants who have designated the Eastern District of Virginia as their agent for service of process. A pending motion to dismiss was simultaneously terminated as moot.
The 46-day duration before transfer is consistent with early procedural resolution in cases invoking § 293, where venue in Virginia is effectively prescribed by statute when the foreign defendant has no U.S. domicile but has made the required designation. The unopposed nature of the transfer motion suggests Sanbo Wang’s counsel did not contest venue, which likely accelerated the court’s action. No substantive patent claims, claim construction, or damages have been adjudicated; all such issues now sit with the Eastern District of Virginia.
Filing to Case Transferred in 46 days
46 days from filing to transfer — rapid early-stage resolution before substantive merits review
What the § 293 transfer to E.D. Virginia means for both parties
35 U.S.C. § 293 mandates E.D. Virginia as the venue
Section 293 of the Patent Act provides that when a foreign party has no U.S. domicile but has designated an agent for service, patent infringement actions against them must proceed in the Eastern District of Virginia. The Illinois court’s grant of the unopposed transfer motion under this provision reflects a procedural correction rather than any merits finding — the case was never in the wrong court in bad faith, but § 293 creates a statutory home court for such defendants.
Statutory venue correctionLitigation continues in Virginia — clock resets, costs accrue
For Dongguan Naquan, the transfer is a setback in terms of timing and cost, but not a loss on the merits. The infringement claim survives intact and will be re-docketed in E.D. Virginia. The plaintiff must now engage Virginia-admitted counsel or seek pro hac vice admission and adjust its litigation strategy to the Alexandria Division’s scheduling practices. The dismissal of the motion to dismiss as moot preserves plaintiff’s ability to argue its full case.
Claim survives; new venueTransfer was unopposed — defendant may prefer Virginia forum
The fact that Sanbo Wang’s counsel did not oppose the transfer motion is strategically telling. It suggests the defendant either acknowledges the § 293 designation or sees tactical advantage in litigating in E.D. Virginia rather than Illinois. The motion to dismiss that was pending — and terminated as moot — may be refiled in Virginia, potentially resurrecting the same grounds in a new forum. Defendant retains full procedural options going forward.
Unopposed; motions may reviveIP enforcement against foreign e-commerce defendants: venue matters
This case illustrates the complexity of enforcing U.S. patents against foreign-based e-commerce sellers. The § 293 designation mechanism is frequently encountered when Chinese-domiciled sellers are named as defendants, and IP holders targeting such defendants should anticipate mandatory transfer to E.D. Virginia at the outset. Strategic plaintiffs increasingly file directly in Virginia to avoid the delay and dual-cost burden seen here.
Cross-border e-commerce IP riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dongguan Naquan E-Commerce Co., Ltd. | Company | E-commerce lighting company — holder of US1058875A covering camping string lightsSearch in Eureka ↗ |
| Defendant | Sanbo Wang | Individual | Individual defendant Sanbo Wang — alleged infringer of camping string lights patentSearch in Eureka ↗ |
| Plaintiff counsel | Tao Liu | Attorney | Counsel for Dongguan Naquan E-Commerce Co., Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Wei Wang | Attorney | Counsel for Dongguan Naquan E-Commerce Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Glacier Law LLP | Law Firm | Representing Dongguan Naquan E-Commerce Co., Ltd.Search in Eureka ↗ |
| Defendant counsel | Christopher Paul Keleher | Attorney | Counsel for Sanbo WangSearch in Eureka ↗ |
| Defendant counsel | Lance Y. Liu | Attorney | Counsel for Sanbo WangSearch in Eureka ↗ |
| Defendant law firm | The Keleher Appellate Law Group, LLC | Law Firm | Representing Sanbo WangSearch in Eureka ↗ |
| Presiding judge | Judge Manish S. Shah | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s minute order grants the unopposed motion to transfer under 35 U.S.C. § 293 and simultaneously terminates the pending motion to dismiss as moot. This framing is significant: no merits of the infringement claim were examined, and the dismissal motion received no substantive ruling. The transfer is procedural and venue-corrective in nature. Both the infringement allegations and any defences raised in the dismissed motion remain live and may be reasserted in the Eastern District of Virginia, which now holds exclusive jurisdiction over this dispute.
US1058875A — Camping String Lights Decorative Lighting Technology
US1058875A covers technology relating to camping string lights — a category of outdoor decorative LED or similar lighting commonly used in recreational, camping, and residential patio contexts. The patent sits within the broader consumer lighting sector, where design differentiation, power efficiency, and durability features are common points of novelty. The application history and exact claim scope would require a full prosecution history review, but the asserted product — camping string lights — places this patent squarely in the high-volume, e-commerce-driven consumer goods space.
From a competitive intelligence standpoint, patents covering decorative string lighting are strategically relevant to any company manufacturing or sourcing similar products for the outdoor or recreational market. The involvement of a Chinese-domiciled plaintiff enforcing against another individual defendant in U.S. courts suggests an increasingly common pattern: Chinese e-commerce brands using U.S. patent rights to exclude competing sellers on platforms such as Amazon. Competitors in the camping accessories and outdoor lighting space should monitor this patent’s claim scope carefully.
Should your product team run an FTO against US1058875A?
Any company designing, importing, or selling camping string lights, outdoor decorative lighting, or similar recreational LED products in the U.S. market should treat US1058875A as a potential clearance concern. The e-commerce enforcement context of this case suggests the patent is being actively asserted against commercial sellers, not just manufacturers. Importers and Amazon marketplace sellers are particularly exposed given the cross-border enforcement dynamics on display here.
PatSnap Eureka’s FTO Search Agent can map the claim scope of US1058875A against your current product specifications, flag design-around opportunities, and identify prior art that could form the basis of an invalidity argument. For product teams sourcing camping or outdoor lighting products from overseas manufacturers, an automated FTO screen before launch is a low-cost risk mitigation step that this litigation demonstrates is commercially essential.
Run a freedom-to-operate analysis on US1912703733 to assess your product’s exposure
Run FTO in Eureka →Similar patent infringement cases: outdoor lighting and e-commerce IP disputes
Cases involving patent enforcement against foreign e-commerce defendants in U.S. district courts, particularly in the outdoor lighting and consumer goods sectors.
What this case signals for the outdoor lighting and e-commerce IP landscape
Enforcing patents against foreign-domiciled e-commerce defendants involves structural venue constraints that can reshape litigation timelines and costs from day one.
File directly in E.D. Virginia when § 293 applies to avoid costly transfers
Patent holders targeting foreign defendants who have made a § 293 agent designation should assess venue before filing. Initiating in the wrong district — even in good faith — results in transfer, duplicated procedural costs, and timeline delays. A pre-filing venue analysis is essential when the defendant is domiciled abroad with U.S. e-commerce operations.
An unopposed transfer motion often signals defendant’s strategic preference
When a defendant does not contest a transfer motion, it frequently indicates comfort with or advantage in the receiving forum. IP litigants should treat an unopposed § 293 transfer as a signal to reassess their forum strategy and prepare for a fresh procedural posture in Virginia, including the possible resurrection of previously mooted motions.
Dongguan v Sanbo — key questions answered
The case was transferred under 35 U.S.C. § 293, which requires patent infringement actions against foreign defendants who have designated an agent for U.S. service of process to proceed in the Eastern District of Virginia. Judge Shah granted the unopposed transfer motion on July 29, 2025, 46 days after filing.
The pending motion to dismiss (docket entry 16) was terminated as moot when the court granted the transfer motion. No substantive ruling was issued on the dismissal grounds. The defendant may refile a similar motion in the Eastern District of Virginia, where the case will be re-docketed.
The plaintiff asserts US1058875A, a patent relating to camping string lights technology. The product at issue is described as ‘The Camping String Lights.’ No claim construction or infringement analysis was conducted in Illinois before the transfer.
Section 293 of the Patent Act provides a specific venue rule: when a foreign party has no U.S. domicile but has designated an agent for service, patent infringement suits against them must be brought in the Eastern District of Virginia. It is a statutory venue correction mechanism, not a merits ruling, and does not affect the underlying infringement claims.
The defendant’s decision not to oppose the transfer motion suggests either an acknowledgment of the § 293 designation or a strategic preference for the Eastern District of Virginia forum. It accelerated the court’s ruling and may signal that the defendant intends to renew procedural challenges — including a motion to dismiss — once the case is re-docketed in Virginia.
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