Huangji Yang v. Schedule A Defendants: Table Leg Design Patent Dismissed in 35 Days
Huangji Yang filed suit in the Northern District of Illinois alleging infringement of design patent USD985320S, which covers a table leg design. The case was voluntarily dismissed without prejudice just 35 days after filing, before any defendant filed an answer or motion for summary judgment.
A rapid Schedule A design patent case that ended before it began
On August 14, 2024, Huangji Yang, represented by Ni, Wang & Associates PLLC, filed a patent infringement action in the U.S. District Court for the Northern District of Illinois before Judge Joan B. Gottschall. The suit targeted a broad group of anonymous defendants identified collectively as ‘Partnerships and Unincorporated Associations identified in Schedule A’ — a filing strategy commonly used to pursue multiple e-commerce sellers simultaneously. The patent at issue, USD985320S, covers an ornamental design for a table leg.
On September 18, 2024 — just 35 days after filing — plaintiff’s counsel filed a notice of voluntary dismissal without prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). The notice confirmed that none of the remaining defendants had yet filed an answer or motion for summary judgment at the time of dismissal, satisfying the procedural requirement for a plaintiff to dismiss unilaterally without a court order. Because the dismissal was without prejudice, the patent claims remain live and Yang retains the right to re-file against the same or similar defendants.
The 35-day duration is notably short even by the standards of Schedule A e-commerce enforcement actions, which frequently resolve before defendants engage. The rapid closure may suggest early settlement with some or all defendants, difficulty serving anonymous overseas sellers, or a strategic reassessment of the defendant pool — though the public record does not disclose any of these specifics. The absence of defendant representation throughout the docket is consistent with the typical Schedule A enforcement pattern targeting marketplace sellers.
Filing to Voluntary dismissal in 35 days
35 days from filing to dismissal — well below the district median for design patent cases
Voluntarily dismissed: what the Rule 41 notice means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral right to dismiss
Federal Rule of Civil Procedure 41(a)(1)(A)(i) permits a plaintiff to dismiss an action without a court order by filing a notice of dismissal before the opposing party serves an answer or motion for summary judgment. Here, no defendant had done either, making the dismissal procedurally straightforward. No judicial approval was required, and no merits ruling was issued.
No court order requiredWithout prejudice: the patent claims remain live
A dismissal without prejudice does not extinguish the underlying claims. Huangji Yang retains the right to re-file suit against the same defendants or new Schedule A sellers for infringement of USD985320S. This stands in contrast to a dismissal with prejudice, which would bar re-filing. The public record specifies ‘WITHOUT PREJUDICE’ explicitly, so there is no ambiguity on this point.
Claims survive dismissalDefendants face no judgment — but remain exposed
The Schedule A defendants received no adverse judgment and incurred no recorded liability. However, because the dismissal is without prejudice, they cannot treat this case as a final resolution. If they continue selling products that Yang alleges infringe USD985320S, a fresh action remains possible. The lack of any defendant representation on the docket suggests most were not engaged in the proceedings.
No preclusion for defendantsSchedule A enforcement: a pattern of rapid resolution
Schedule A cases targeting anonymous marketplace sellers frequently close quickly — through early private settlements, TRO-driven asset freezes, or dismissal when defendants cannot be served. A 35-day lifecycle is consistent with either a pre-answer resolution with some defendants or a tactical reassessment. Design patents covering furniture components such as table legs are actively enforced against Asian e-commerce sellers on platforms like Amazon and Alibaba.
E-commerce enforcement patternFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Huangji Yang | Individual | Design patent holder asserting ornamental rights in a table leg design — USD985320SSearch in Eureka ↗ |
| Defendant | Partnerships and Unincorporated Associations identified in Schedule A | Individual | Anonymous e-commerce sellers and partnerships identified collectively in Schedule ASearch in Eureka ↗ |
| Plaintiff counsel | Hao Ni, Esq. | Attorney | Counsel for Huangji YangSearch in Eureka ↗ |
| Plaintiff law firm | Ni Wang & Associates PLLC | Law Firm | Representing Huangji YangSearch in Eureka ↗ |
| Presiding judge | Judge Joan B. Gottschall | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) and expressly specifies ‘WITHOUT PREJUDICE,’ confirming this is a plaintiff-initiated procedural exit rather than a merits adjudication. The notation that defendants had not yet answered is a required procedural recital establishing Yang’s right to dismiss unilaterally. No court findings were made regarding infringement, validity, or damages. The without-prejudice designation means the statute of limitations and claim viability are unaffected by this filing.
USD985320S — Ornamental design for a table leg
USD985320S is a U.S. design patent covering the ornamental appearance of a table leg, filed under application number 29/815038. Design patents under 35 U.S.C. § 171 protect the non-functional, aesthetic characteristics of an article of manufacture. The scope of protection is determined by the claimed drawings rather than written claims, and infringement is assessed under the ‘ordinary observer’ test — whether an ordinary observer would mistake the accused design for the patented one.
Table leg designs are a commercially contested space in the furniture and home goods sector, where manufacturers in China and other Asian markets frequently supply near-identical products to multiple Western e-commerce platforms. A design patent in this category can be a cost-effective enforcement tool against marketplace sellers, particularly when combined with TRO-based asset freeze motions in the Northern District of Illinois — a favored venue for Schedule A enforcement. The continued validity of USD985320S is untested, as no defendant mounted a challenge before dismissal.
Should your product team run an FTO against USD985320S?
Any manufacturer, importer, or marketplace seller offering table legs or furniture leg components in the U.S. market should assess their exposure to USD985320S. Design patent infringement turns on visual similarity under the ordinary observer standard, which is highly fact-specific. Products that share the overall ornamental impression of the claimed design — regardless of material, size, or minor variations — may face enforcement risk, particularly given the without-prejudice dismissal that leaves the door open for re-filing.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD985320S against your product’s design features, identify prior art that could support an invalidity challenge, and flag related design patent families held by the same applicant. For e-commerce sellers and OEMs sourcing furniture components from overseas suppliers, proactive FTO clearance is a lower-cost alternative to defending a Schedule A TRO action in Chicago.
Run a freedom-to-operate analysis on USD0985320S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois
Explore comparable design patent infringement actions against Schedule A e-commerce defendants filed in the Northern District of Illinois covering furniture and home goods.
What this case signals for the furniture design IP enforcement landscape
Schedule A design patent suits against e-commerce sellers are a growing enforcement channel — this case illustrates both their speed and their limits.
Without-prejudice dismissals preserve enforcement optionality
A voluntary dismissal without prejudice is not a concession on the merits. Patent holders using Schedule A tactics routinely dismiss and re-file as they identify new seller cohorts or refine defendant lists. Competitors and marketplace sellers should not interpret this closure as a signal that USD985320S will go unenforced.
Schedule A suits move fast — defense teams need immediate response protocols
With a 35-day case duration, defendants in Schedule A actions have minimal time to retain counsel, respond to TRO motions, or contest asset freezes before a case closes or settles. E-commerce sellers and their platforms should have pre-established IP response procedures to avoid default outcomes.
Yang v Partnerships — key questions answered
The case was voluntarily dismissed without prejudice by plaintiff Huangji Yang on September 18, 2024, just 35 days after filing. The dismissal was made under Fed. R. Civ. P. 41(a)(1)(A)(i) before any defendant filed an answer or motion for summary judgment. No merits ruling was issued.
The patent at issue is USD985320S, a U.S. design patent covering the ornamental design of a table leg, filed under application number 29/815038. Design patents protect non-functional aesthetic features and are enforced under the ordinary observer infringement standard.
A dismissal without prejudice does not bar the plaintiff from re-filing. Huangji Yang retains the right to assert USD985320S against the same or different defendants in a future action. The patent’s validity and enforceability are unaffected by this procedural dismissal.
Schedule A defendants are anonymous groups of individuals or entities — typically e-commerce marketplace sellers — identified collectively rather than by name at the time of filing. This approach allows plaintiffs to pursue multiple sellers simultaneously, often seeking TROs and asset freezes while their identities are uncovered through discovery or platform disclosures.
Schedule A cases often resolve rapidly because defendants are anonymous overseas sellers who may not engage with proceedings, because early private settlements are reached after TRO motions, or because plaintiffs reassess their defendant list. A 35-day duration like this case is consistent with pre-answer resolution or a tactical decision to re-file with a refined defendant pool.
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