Guangzhou Linyu v. Shengzhou Yuneng: Rolling Cart Design Patent Dispute Dismissed
Guangzhou Linyu Trading Co., Ltd filed suit against Shengzhou Yuneng Trade Department in the Northern District of Illinois, asserting design patent USD1002985S over the YEMUNY Rolling Storage Cart (ASIN B0BGXCPXYQ). The case ended via voluntary dismissal without prejudice after 119 days — leaving the door open for future action.
E-commerce design patent clash ends early — but not finally
On 31 December 2024, Guangzhou Linyu Trading Co., Ltd filed an infringement action in the United States District Court for the Northern District of Illinois against Shengzhou Yuneng Trade Department. The asserted patent, USD1002985S (Application No. US29/879610), protects the ornamental design of the YEMUNY Rolling Storage Cart, sold on Amazon under ASIN B0BGXCPXYQ. Plaintiff was represented by Glacier Law LLP, a firm that frequently handles cross-border e-commerce IP disputes on behalf of Chinese design-goods manufacturers.
The case closed on 29 April 2025 — just 119 days after filing — when the plaintiff filed a notice of voluntary dismissal without prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). This procedural mechanism allows a plaintiff to exit the litigation unilaterally before the defendant serves an answer or a motion for summary judgment. Because the dismissal is without prejudice, Guangzhou Linyu retains the right to refile the same claims against Shengzhou Yuneng in the future.
A resolution inside four months — before defendant counsel even entered an appearance on the docket — is consistent with pre-answer settlement negotiations or a strategic withdrawal pending further evidence gathering. The public record does not disclose whether any agreement was reached between the parties. What remains unknown is whether the defendant altered its product listing, ceased US sales, or engaged in any commercial resolution. The absence of a merits ruling means patent USD1002985S has not been tested in court.
Filing to Voluntary dismissal in 119 days
119 days — resolved faster than the median district court patent case, which typically runs 2–3 years
Voluntarily dismissed: what Rule 41 dismissal means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral exit before answer
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order by filing a notice of dismissal before the opposing party serves an answer or a motion for summary judgment. This is the earliest — and lowest-cost — exit ramp available. No judicial approval is required, no merits are adjudicated, and no precedent is set on the patent’s validity or scope.
No merits rulingDismissed without prejudice: refiling remains an open option
A dismissal without prejudice means the plaintiff is not barred from reasserting the same claims. The public record confirms the ‘without prejudice’ designation explicitly in the verdict text. This differs from a dismissal with prejudice, which would permanently extinguish the claims. Whether the parties reached a private settlement — which could include a covenant not to sue — is not disclosed in the public docket.
Refiling permittedDefendant exits without a judgment — but exposure persists
Shengzhou Yuneng Trade Department faces no adverse judgment and no injunction from this action. However, the without-prejudice nature of the dismissal means potential exposure to a future refiling. If the defendant continues selling the accused product in the US market, the risk of a second lawsuit — possibly with stronger evidence — remains live. No defendant counsel appeared on the docket, suggesting the case resolved before formal engagement.
Latent refiling riskAmazon design patent disputes: fast pressure, fast resolution
This case fits a recognisable pattern in Amazon marketplace IP enforcement: a Chinese design-patent holder files suit in a US district court to pressure a competing seller, then withdraws once the commercial objective — listing removal, sales halt, or private agreement — is achieved. The 119-day lifecycle, pre-answer dismissal, and absence of defendant counsel all suggest swift commercial leverage rather than a protracted merits battle.
Marketplace enforcement tacticFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Guangzhou Linyu Trading Co., Ltd | Company | Chinese consumer goods manufacturer — holder of design patent USD1002985S for rolling storage cartsSearch in Eureka ↗ |
| Defendant | Shengzhou Yuneng Trade Department | Individual | Chinese e-commerce trade department selling rolling storage carts on Amazon US marketplaceSearch in Eureka ↗ |
| Plaintiff counsel | Ruoting Men | Attorney | Counsel for Guangzhou Linyu Trading Co., LtdSearch in Eureka ↗ |
| Plaintiff counsel | Tao Liu | Attorney | Counsel for Guangzhou Linyu Trading Co., LtdSearch in Eureka ↗ |
| Plaintiff law firm | Glacier Law LLP | Law Firm | Representing Guangzhou Linyu Trading Co., LtdSearch in Eureka ↗ |
| Presiding judge | Judge John F. Kness | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The verdict text invokes Rule 41(a)(1)(A)(i), the self-executing dismissal notice available only before an answer is filed — confirming this case ended at its earliest procedural stage. No merits were adjudicated: patent USD1002985S was neither validated nor invalidated. The without-prejudice designation is explicit, preserving the plaintiff’s right to refile. The absence of any defendant agent on record suggests Shengzhou Yuneng may not have been formally served or chose not to engage US counsel before the case was withdrawn.
USD1002985S — Ornamental Design for a Rolling Storage Cart
USD1002985S, filed under Application No. US29/879610, is a US design patent protecting the ornamental appearance of a rolling storage cart — the specific visual and aesthetic elements of its form, rather than any functional feature. Design patents in the US grant the holder the right to prevent others from making, using, or selling articles with substantially the same ornamental appearance. The YEMUNY cart sold on Amazon (ASIN B0BGXCPXYQ) was identified as the accused product in this action.
Design patents on consumer storage and organisation products have become an increasingly common enforcement tool in the Amazon marketplace, where visual similarity between competing ASIN listings can be identified and documented with relative ease. Holders of US design patents in this category — particularly Chinese manufacturers filing through US IP counsel — can use a single registered design to challenge multiple competitors. Any seller offering a visually similar rolling cart on Amazon should assess their exposure to USD1002985S and comparable design registrations in the same product family.
Should you run an FTO analysis against USD1002985S?
If your company sells rolling storage carts, shelving trolleys, or similar wheeled organisational products on Amazon or other US retail channels, USD1002985S warrants attention. The patent’s ornamental scope — how broadly courts would construe its visual claim — has not been tested in this case. Any product with a substantially similar aesthetic profile to the YEMUNY cart could fall within the patent’s reach. This applies equally to private-label sellers, importers, and fulfilment-by-Amazon vendors sourcing from Chinese manufacturers.
PatSnap Eureka’s FTO Search Agent can map USD1002985S against your product’s design, surface prior art that could challenge the patent’s validity, and identify related design registrations filed by Guangzhou Linyu or associated entities. R&D and product teams can use Eureka to flag design-around options before a product launch — reducing the risk of facing a similar enforcement action in the Northern District of Illinois or other high-volume patent courts.
Run a freedom-to-operate analysis on USD1002985S to assess your product’s exposure
Run FTO in Eureka →Similar design patent infringement cases: rolling carts and consumer goods
Explore comparable design patent enforcement actions involving consumer storage products and Amazon marketplace disputes in the Northern District of Illinois and related courts.
What this case signals for the consumer goods design patent landscape
Short-lived Amazon enforcement actions like this one reveal how design patents are increasingly used as commercial pressure tools, not just litigation assets.
Pre-answer dismissals signal commercial resolution, not legal defeat
When a plaintiff voluntarily dismisses before the defendant even appears, the litigation itself was likely the tactic. IP teams monitoring competitor enforcement activity should track these early-exit cases — they often indicate private agreements, ASIN takedowns, or market-withdrawal commitments that never surface in public court records.
Design patents on storage products carry real marketplace leverage
USD1002985S was asserted against a specific Amazon ASIN, illustrating how ornamental design patents — even on commodity products like rolling carts — can disrupt competitor listings. Companies selling in the same product category should audit their own designs against registered US design patents held by Chinese manufacturers.
Guangzhou v Shengzhou — key questions answered
The case was voluntarily dismissed without prejudice on 29 April 2025 under Federal Rule of Civil Procedure 41(a)(1)(A)(i). No merits were adjudicated. The plaintiff, Guangzhou Linyu Trading Co., Ltd, retains the right to refile the same claims against Shengzhou Yuneng Trade Department in the future.
The asserted patent is USD1002985S (Application No. US29/879610), a US design patent covering the ornamental appearance of a rolling storage cart. The accused product was the YEMUNY Rolling Storage Cart, sold on Amazon under ASIN B0BGXCPXYQ.
A dismissal without prejudice means no judgment is entered against the defendant and no injunction or damages are awarded. However, the plaintiff is not barred from refiling the same claims. The defendant faces no immediate legal consequence but remains exposed to a future action on the same patent, particularly if the accused product continues to be sold in the US market.
Many Amazon design patent disputes are filed primarily to achieve commercial objectives — ASIN removal, competitor withdrawal, or a private licensing agreement — rather than to litigate to judgment. Once the desired commercial outcome is achieved, plaintiffs frequently file a Rule 41 voluntary dismissal. The 119-day resolution in this case is consistent with that enforcement pattern.
Plaintiff Guangzhou Linyu Trading Co., Ltd was represented by Glacier Law LLP, with attorneys Ruoting Men and Tao Liu listed as agents. Glacier Law LLP is known for representing Chinese businesses in US IP enforcement actions, particularly cross-border e-commerce and Amazon marketplace disputes filed in federal district courts.
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