Haoran Niu v. Schedule A Defendants — Motorcycle Design Patent Dismissed in 8 Days
Plaintiff Haoran Niu filed a design patent infringement action in the Northern District of Illinois asserting USD1068562S, a motorcycle design patent, against unnamed Schedule A defendants. The case closed just 8 days after filing via voluntary dismissal under Rule 41(a)(1)(B), with no answer or motion for summary judgment filed by any defendant.
Eight-day lifespan: a Schedule A motorcycle design suit that never got started
On September 2, 2025, plaintiff Haoran Niu, represented by Alioth Law LLP attorney Huicheng Zhou, filed a patent infringement action in the U.S. District Court for the Northern District of Illinois before Judge Franklin U. Valderrama. The suit asserted design patent USD1068562S (Application No. 29/845180), which covers the ornamental design of a motorcycle, against defendants identified only as ‘THE DEFENDANT IDENTIFIED ON SCHEDULE A’ — a naming convention commonly used in multi-defendant e-commerce enforcement campaigns.
Eight days after filing, on September 10, 2025, plaintiff filed a notice of voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(B). The notice expressly states that no defendant had served an answer or motion for summary judgment, satisfying the procedural precondition for dismissal as of right. The verdict text further states the dismissal is ‘without prejudice,’ meaning Niu retains the right to refile the same claims against the same or different defendants in the future.
A resolution window of 8 days is unusually short even for Schedule A cases, which themselves tend to resolve faster than standard patent litigation. The public record does not reveal what precipitated the withdrawal — possibilities include an out-of-court resolution, identification of the wrong defendant, a strategic pivot, or a decision to pursue alternative enforcement channels. No defendant agents or law firms are listed, suggesting no defendant formally appeared before the dismissal was filed.
Filing to Voluntary dismissal in 8 days
Resolved in 8 days — well below the median district court patent case duration of 2+ years
Voluntarily dismissed: what the Rule 41 notice means for both parties
Rule 41(a)(1)(B) dismissal as of right — no court order needed
Under Fed. R. Civ. P. 41(a)(1)(B), 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. Because no defendant had responded here, Niu’s notice was self-executing. The court had no discretion to deny it. This is the most plaintiff-friendly dismissal mechanism available in federal civil procedure.
Dismissal as of rightThe verdict states ‘without prejudice’ — but the distinction matters
The notice expressly invokes Rule 41(a)(1)(B) and states dismissal is without prejudice, meaning plaintiff retains the right to refile the same infringement claims in the future. A dismissal with prejudice would have extinguished those claims permanently. The public record here is unambiguous on this point: the case is dismissed without prejudice, preserving Niu’s enforcement options against the same or different Schedule A defendants.
Without prejudice confirmedDefendant never appeared — no exposure recorded on public docket
No defendant agents or law firms are recorded, and no answer or substantive motion was filed before dismissal. This means the Schedule A defendant(s) faced no formal adverse ruling and incurred no recorded legal liability in this proceeding. However, a without-prejudice dismissal does not insulate them from a future refiled action asserting the same design patent.
No adverse ruling recordedSchedule A enforcement dynamics: early exits are tactically common
Schedule A design patent campaigns — often targeting e-commerce sellers of accused products — frequently see early voluntary dismissals. This may follow a private settlement, takedown compliance, or strategic reassessment. The 8-day window suggests the plaintiff’s objective may have been achieved (or abandoned) before any court process was needed. Sellers of motorcycle products bearing similar ornamental designs should monitor USD1068562S for potential refiling activity.
E-commerce enforcement patternFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Haoran Niu | Individual | Individual design patent holder — asserting USD1068562S covering motorcycle ornamental designSearch in Eureka ↗ |
| Defendant | THE DEFENDANT IDENTIFIED ON SCHEDULE A | Individual | Unnamed Schedule A defendant(s) — identity not disclosed in public court recordSearch in Eureka ↗ |
| Plaintiff counsel | Huicheng Zhou | Attorney | Counsel for Haoran NiuSearch in Eureka ↗ |
| Plaintiff law firm | Alioth Law LLP | Law Firm | Representing Haoran NiuSearch in Eureka ↗ |
| Presiding judge | Judge Franklin U. Valderrama | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(B) and expressly states the action is dismissed without prejudice, confirming that no defendant had served an answer or motion for summary judgment. This language is legally precise: the ‘without prejudice’ designation preserves plaintiff’s right to refile identical claims. The absence of any defendant response on the docket means no merits determination was reached, and the design patent USD1068562S has not been tested for validity or infringement in this proceeding.
USD1068562S — Ornamental Design of a Motorcycle
USD1068562S (filed under Application No. 29/845180) is a U.S. design patent protecting the ornamental appearance of a motorcycle. Design patents grant a 15-year term from grant and cover the non-functional, visual characteristics of a product as depicted in the patent drawings. Unlike utility patents, design patents do not protect how a product works — only how it looks. This makes claim scope highly drawing-dependent, and infringement is assessed under the ‘ordinary observer’ test established in Egyptian Goddess v. Swisa.
Design patents on consumer vehicles and accessories have become increasingly prominent in Schedule A enforcement actions, particularly against e-commerce platforms selling third-party motorcycle parts, accessories, and replica products. USD1068562S represents a direct enforcement risk for any seller whose motorcycle product shares the overall visual impression of the patented design. Given the without-prejudice dismissal here, the patent holder retains full enforcement posture, and competitors or distributors operating in the motorcycle accessories space should treat this patent as an active commercial risk.
Should your product team run an FTO against USD1068562S?
Any company designing, importing, or selling motorcycle products — particularly through e-commerce channels such as Amazon, eBay, or AliExpress — should assess whether their product’s ornamental appearance could be found substantially similar to USD1068562S under the ordinary observer test. This is especially urgent for sellers who may fall within the broad ‘Schedule A’ defendant class typically targeted in Northern District of Illinois campaigns. A proactive FTO review is significantly less costly than responding to a TRO or asset freeze.
PatSnap Eureka’s FTO Search Agent can map USD1068562S against your product’s design characteristics, identify prior art that may limit the patent’s enforceable scope, and flag related design applications from the same inventor or law firm. Eureka’s litigation monitoring tools can also alert your team if Haoran Niu or Alioth Law LLP files a new Schedule A action asserting this or related design patents — giving you early warning before a TRO is sought.
Run a freedom-to-operate analysis on USD1068562S to assess your product’s exposure
Run FTO in Eureka →Similar motorcycle design patent Schedule A cases in Illinois federal courts
Related Schedule A design patent infringement cases involving motorcycle or vehicle accessory designs filed in the Northern District of Illinois.
What this case signals for motorcycle design patent enforcement
Ultra-short Schedule A cases like this one reveal enforcement patterns that IP teams monitoring the motorcycle accessories market should track closely.
Without-prejudice dismissal keeps the threat alive for Schedule A defendants
Because the dismissal is explicitly without prejudice, plaintiff Haoran Niu retains full ability to refile against the same or different defendants. Sellers of motorcycle products with similar ornamental designs cannot treat this dismissal as a clearance event — the underlying design patent USD1068562S remains enforceable.
Eight-day cases signal private resolution or rapid strategic pivot
An 8-day case lifecycle — from filing to voluntary dismissal — typically suggests either a private agreement was reached quickly, the plaintiff identified a targeting error, or a takedown was achieved without litigation. This pattern is consistent with Schedule A enforcement campaigns where the filing itself is the leverage.
Niu v DEFENDANT — key questions answered
The voluntary dismissal notice expressly states the action is dismissed without prejudice under Fed. R. Civ. P. 41(a)(1)(B). This means plaintiff Haoran Niu retains the right to refile the same infringement claims against the same or different defendants in a future action.
USD1068562S (Application No. 29/845180) is a U.S. design patent protecting the ornamental appearance of a motorcycle. Design patents cover the non-functional visual characteristics of a product and have a 15-year term from grant. Infringement is assessed under the ordinary observer test, comparing the accused product’s appearance to the patent drawings.
The public record does not disclose the reason for the rapid voluntary dismissal. Possible explanations include a private settlement or takedown agreement with the unnamed defendant(s), a strategic decision to refile in a different venue, or identification of a targeting error. No defendant formally appeared, and no merits determination was made.
Schedule A cases involve defendants whose identities are withheld from the public docket and listed only on a sealed schedule. This format is commonly used in IP enforcement campaigns targeting multiple e-commerce sellers simultaneously, often to obtain temporary restraining orders and asset freezes before defendants are notified of the suit.
Yes. Because the dismissal is without prejudice, plaintiff Haoran Niu is not barred from refiling an infringement action asserting USD1068562S against the same or different defendants. The patent itself was not adjudicated and remains fully enforceable. Sellers of motorcycle products with similar ornamental designs should treat this dismissal as a pause rather than a resolution.
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