Guangzhou Youlan v. ciokea patio: Design Patent Dispute Settled in 35 Days
Guangzhou Youlan Technology Co. Ltd. filed a design patent infringement action in the Northern District of Illinois over USD1075331S, an ornamental design covering an outdoor chaise lounge, against Amazon seller ciokea patio and co-defendants listed in Schedule A. The case resolved in just 35 days when Youlan voluntarily dismissed Defendant No. 1 Xingyi International Trade Co. following a settlement, with each party bearing its own fees and costs.
Design patent enforcement on Amazon: fast settlement over outdoor furniture
On 7 July 2025, Guangzhou Youlan Technology Co. Ltd., a Chinese consumer goods company, filed a design patent infringement action in the U.S. District Court for the Northern District of Illinois before Judge Sharon Johnson Coleman. The complaint asserted U.S. Design Patent USD1075331S, covering the ornamental appearance of an outdoor chaise lounge, against a group of defendants identified collectively in Schedule A — a filing strategy commonly used to pursue multiple anonymous or pseudonymous online marketplace sellers in a single action.
The case closed on 11 August 2025 — just 35 days after filing — when Youlan filed a notice of voluntary dismissal as to Defendant No. 1, Xingyi International Trade Co. Ltd., operating under the Amazon storefront ‘ciokea patio’ (Seller ID: A1VEET6Y983935). The dismissal was predicated on a settlement having been reached between the parties, with each side agreeing to bear its own fees, costs, and expenses. The public record does not specify whether the dismissal was with or without prejudice.
A 35-day resolution is notably fast, even by the standards of Schedule A design patent enforcement actions, which are specifically structured for rapid resolution against e-commerce sellers. The swift settlement likely reflects the commercial calculus typical of marketplace enforcement: the cost and disruption of defending an Amazon-channel dispute often incentivises early resolution. Whether remaining Schedule A defendants are still subject to ongoing proceedings is not determinable from this docket entry alone.
Filing to Voluntary dismissal in 35 days
35 days — well below the typical 2–3 year N.D. Illinois patent case lifecycle, suggesting early settlement
Voluntary dismissal following settlement: what the record reveals
Voluntary dismissal under FRCP 41 — settlement-driven exit
Pursuant to FRCP 4(a)(1)(A)(i) as cited in the filing, Youlan notified the court that the parties had reached settlement and voluntarily dismissed Xingyi International from the action. Voluntary dismissal is a procedural mechanism that terminates claims against a specific defendant without requiring a court merits ruling. The public record does not specify whether the dismissal is with or without prejudice, which carries material consequences for any future re-filing.
FRCP voluntary dismissalWith or without prejudice? The record is silent
A dismissal ‘with prejudice’ bars Youlan from re-filing the same design patent claims against Xingyi International. A dismissal ‘without prejudice’ preserves that right. The filed notice states only that the parties settled and that each party bears its own costs — it does not expressly designate either form. Under FRCP 41(a)(1)(B), a second voluntary dismissal by the same plaintiff against the same defendant operates as a dismissal with prejudice, making the prejudice question potentially significant if Youlan pursues future enforcement.
Prejudice designation unconfirmedYoulan exits with settlement — enforcement signal sent to marketplace
For Youlan, a swift settlement against an Amazon seller is broadly consistent with the commercial goals of Schedule A enforcement: delist or monetise infringing listings with minimal litigation spend. The absence of a fee award against Youlan suggests no exceptional case finding or bad-faith claim was raised. Whether the settlement included licence terms, product removal, or a financial payment is not disclosed in the public record.
Settlement — terms undisclosedciokea patio settles — Amazon storefront the likely pressure point
For Xingyi International / ciokea patio, agreeing to settle within 35 days of filing suggests the commercial cost of contesting the action — including potential Amazon account disruption and legal fees — exceeded the cost of resolution. Design patent Schedule A cases frequently create an asymmetric commercial threat for marketplace sellers: even a contested case risks extended storefront disruption. Each party bearing its own costs is consistent with a relatively even negotiating outcome at this stage.
Settled — each party pays own costsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Guangzhou Youlan Technology Co. Ltd. | Company | Consumer goods design IP holder — asserting USD1075331S over outdoor chaise lounge ornamental designSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations in Schedule A | Individual | Amazon marketplace seller operating as ciokea patio (Xingyi International Trade Co. Ltd.)Search in Eureka ↗ |
| Plaintiff counsel | Robert Michael Dewitty | Attorney | Counsel for Guangzhou Youlan Technology Co. Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Dewitty And Associates, Chtd. | Law Firm | Representing Guangzhou Youlan Technology Co. Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Sharon Johnson Coleman | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The verdict notice is a plaintiff-filed settlement notification rather than a court-issued merits ruling. It confirms the parties reached agreement and that Youlan elected voluntary dismissal as the procedural vehicle. The explicit reference to each party bearing its own costs suggests no prevailing-party fee claim was asserted or conceded. The absence of any merits adjudication means the validity and enforceability of USD1075331S remain untested by this proceeding, leaving the patent’s strength neither confirmed nor diminished by this docket entry.
USD1075331S — Ornamental Design of an Outdoor Chaise Lounge
USD1075331S is a U.S. design patent — filed under application number US29/910922 — protecting the ornamental appearance of an outdoor chaise lounge. U.S. design patents cover the non-functional, visual characteristics of a product and are assessed for infringement under the ‘ordinary observer’ test: whether an ordinary purchaser would mistake the accused product for the patented design. Design patents in the furniture and outdoor leisure category have become an increasingly active enforcement tool for consumer goods manufacturers seeking to protect product aesthetics in e-commerce markets.
For competitors in the outdoor furniture sector, USD1075331S represents the type of design IP that is easily overlooked in utility-focused FTO analyses. Chinese OEM manufacturers who hold U.S. design patents on their proprietary product designs can assert them against sellers sourcing visually similar products from other suppliers. Any party importing, distributing, or listing outdoor chaise lounges that share ornamental similarity with the patented design faces potential infringement exposure — regardless of differences in underlying construction or materials.
Should you run an FTO check against USD1075331S before listing outdoor chaise lounges?
Any retailer, distributor, or Amazon seller carrying outdoor chaise lounges that are visually similar to the design claimed in USD1075331S should conduct a design patent FTO review before listing. The active enforcement of this patent — resulting in a settled lawsuit within 35 days — confirms that the holder is willing and able to pursue marketplace sellers. Given the Schedule A mechanism, new defendants can be added with minimal procedural friction, making early FTO analysis a cost-effective risk management step.
PatSnap Eureka’s FTO Search Agent allows R&D and sourcing teams to run image-based and classification-based searches across USPTO design patent records, identifying design patents with overlapping ornamental scope in furniture categories such as D06 and D21. Eureka can map the design patent landscape around specific product silhouettes, alert teams to new grants by identified holders, and surface related enforcement activity — equipping product and legal teams to make listing decisions with full IP visibility.
Run a freedom-to-operate analysis on USD1075331S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois: outdoor furniture
Explore comparable design patent infringement actions against Amazon marketplace sellers in the N.D. Illinois court involving consumer goods and outdoor furniture.
What this case signals for the outdoor furniture IP enforcement landscape
Schedule A design patent enforcement against Amazon sellers is a structured, repeatable strategy — and this case illustrates both its efficiency and its limits.
Schedule A filings are purpose-built for Amazon enforcement speed
The 35-day resolution in this case is consistent with the architecture of Schedule A design patent actions: a single complaint targeting multiple online sellers, often followed by TRO applications and Amazon account holds. For design patent holders in consumer goods, this mechanism can create rapid commercial leverage without lengthy litigation. Competitors operating on Amazon marketplace should monitor new Schedule A filings in N.D. Illinois as early enforcement signals.
Ornamental design patents on furniture are actively enforced in U.S. courts
USD1075331S covering an outdoor chaise lounge design reflects a broader trend of Chinese consumer goods manufacturers proactively registering and enforcing U.S. design patents on furniture and outdoor products. Any company sourcing, distributing, or selling visually similar outdoor furniture in the U.S. market should assess FTO exposure against active design patent portfolios held by manufacturers like Youlan before listing products on e-commerce platforms.
Guangzhou v Partnerships — key questions answered
Guangzhou Youlan Technology Co. Ltd. filed a design patent infringement action against Xingyi International Trade Co. Ltd. (Amazon storefront: ciokea patio) and co-defendants in Schedule A, asserting U.S. Design Patent USD1075331S covering an outdoor chaise lounge. The case was filed in N.D. Illinois on 7 July 2025 and voluntarily dismissed following a settlement on 11 August 2025 — 35 days after filing.
Youlan filed a notice of voluntary dismissal as to Xingyi International after the parties reached settlement. The public record does not specify whether the dismissal is with or without prejudice. Each party agreed to bear its own fees, costs, and expenses. No court ruling on the merits of the infringement claim was issued, meaning the validity of USD1075331S was not adjudicated in this proceeding.
USD1075331S is a U.S. design patent (application no. US29/910922) protecting the ornamental appearance of an outdoor chaise lounge. Design patents in the U.S. cover the visual, non-functional characteristics of a product and are infringed when an ordinary observer would find the accused product substantially similar to the patented design.
A Schedule A case is a filing strategy used to sue multiple anonymous or pseudonymous online marketplace sellers — often Amazon third-party sellers — in a single complaint. The defendants are listed by pseudonym or seller ID in a schedule attached to the complaint. N.D. Illinois is a frequently chosen venue for such cases due to its procedural familiarity with this format. Plaintiffs often seek TROs to freeze seller accounts as early leverage.
The voluntary dismissal filed on 11 August 2025 names only Defendant No. 1, Xingyi International Trade Co. Ltd. (ciokea patio). The docket entry does not indicate that other Schedule A defendants were dismissed or settled. It is not determinable from the public record alone whether proceedings against remaining defendants are ongoing, were separately resolved, or were never actively pursued.
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