Jinlong Holding v. Schedule A Defendants: Tripod Easel Stand Design Patent Dismissed
Jinlong Holding Trading Co., Ltd. filed suit in the Northern District of Illinois asserting design patent USD1074223S covering a tripod easel stand against a broad class of anonymous online sellers. The case closed just 35 days after filing, with Jinlong voluntarily dismissing all claims without prejudice under Fed. R. Civ. P. 41(a)(1)(A)(i).
Design patent dispute over tripod easel stand ends in swift voluntary dismissal
On August 25, 2025, Jinlong Holding Trading Co., Ltd. filed a design patent infringement action in the U.S. District Court for the Northern District of Illinois (Case No. 1:25-cv-10146) before Judge Sharon Johnson Coleman. The asserted patent, USD1074223S (application number US29/962269), protects the ornamental design of a tripod easel stand. Defendants were identified collectively as individuals and entities listed on Schedule A — a common enforcement tactic targeting suspected online marketplace sellers.
The case closed on September 29, 2025, just 35 days after filing. Jinlong dismissed all claims against all Schedule A defendants without prejudice pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), which permits a plaintiff to voluntarily dismiss before the defendant serves an answer or a motion for summary judgment. Because the dismissal was expressly stated to be without prejudice, Jinlong retains the legal right to refile these claims in a future action, subject to applicable statutes of limitations.
A resolution within 35 days suggests the case likely did not progress past the initial motion or preliminary injunction stage, which is common in Schedule A marketplace enforcement actions. The public record does not disclose whether the dismissal followed a private settlement, an inability to identify or serve defendants, or a strategic reassessment by Jinlong. The without-prejudice designation leaves the door open for future enforcement, meaning accused sellers on Schedule A cannot treat this dismissal as a final resolution of their exposure.
Filing to Case Dismissed in 35 days
35 days — resolved well below the median district court patent case duration
Voluntarily dismissed: what the without-prejudice ruling means for both parties
Rule 41(a)(1)(A)(i): plaintiff exits before any defense response
Fed. R. Civ. P. 41(a)(1)(A)(i) allows a plaintiff to dismiss its own action as of right — without a court order — before the defendant has served an answer or a motion for summary judgment. This is the earliest and lowest-cost exit available. No merits determination was made; the court never adjudicated whether USD1074223S was infringed, valid, or enforceable.
No merits rulingWithout prejudice: dismissal does not bar a future lawsuit
The complaint expressly states the dismissal is without prejudice. This means the claims are not extinguished — Jinlong may refile against any or all Schedule A defendants in a future action within the applicable limitation period. The public record is silent on whether any private agreement exists between the parties. Practitioners should not treat this dismissal as evidence that USD1074223S is weak or unenforceable.
Refiling right preservedSchedule A sellers face continued exposure despite dismissal
Because the dismissal is without prejudice, defendants on Schedule A cannot rely on this outcome as a shield against future infringement claims. Jinlong retains enforcement rights over USD1074223S. Sellers operating in the tripod easel stand category should treat this as a temporary pause rather than a cleared path, and should assess whether their product designs are independently defensible.
Exposure not clearedSchedule A enforcement: a pattern with lasting deterrent effect
Schedule A cases against anonymous online sellers are frequently used by design patent holders to obtain TROs, freeze assets, and compel settlements before formal litigation proceeds. A swift voluntary dismissal without prejudice is consistent with a resolved dispute outside the court record, or a tactical reset. Online marketplace sellers in the home goods and art supply segments should monitor USD1074223S for any refiled enforcement actions.
Enforcement risk remainsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Jinlong Holding Trading Co., Ltd. | Company | Consumer goods IP holder — holder of USD1074223S (tripod easel stand design)Search in Eureka ↗ |
| Defendant | The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associates Identified on Schedule A | Company | Anonymous online marketplace sellers identified on Schedule A of the complaintSearch in Eureka ↗ |
| Plaintiff counsel | Alexander Warden | Attorney | Counsel for Jinlong Holding Trading Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | West Atlantic Law Firm, PLLC. | Law Firm | Representing Jinlong Holding Trading Co., Ltd.Search in Eureka ↗ |
| Defendant counsel | Jonathan Kevin Barger | Attorney | Counsel for The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associates Identified on Schedule ASearch in Eureka ↗ |
| Defendant law firm | Butler Weihmuller Katz Craig LLP | Law Firm | Representing The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associates Identified on Schedule ASearch in Eureka ↗ |
| Presiding judge | Judge Sharon Johnson Coleman | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal was filed by plaintiff Jinlong itself under Fed. R. Civ. P. 41(a)(1)(A)(i), making it a unilateral voluntary exit requiring no court approval and producing no judicial ruling on the merits. The explicit without-prejudice designation is legally significant: it preserves Jinlong’s right to refile the same claims against any Schedule A defendant. No finding was made regarding the validity, enforceability, or infringement of USD1074223S, and no costs or fees were adjudicated.
USD1074223S — Tripod Easel Stand Ornamental Design
USD1074223S is a U.S. design patent (application number US29/962269) protecting the ornamental appearance of a tripod easel stand. Design patents under 35 U.S.C. § 171 cover only the novel, non-functional visual characteristics of a product — not its mechanical or structural features. Protection is assessed by the ‘ordinary observer’ test: whether an ordinary purchaser would be deceived into believing the accused design is the same as the patented design. The application number suggests a relatively recent filing, consistent with Jinlong’s active enforcement posture in consumer goods.
Tripod easel stands occupy a crowded consumer marketplace dominated by third-party sellers on platforms such as Amazon, Temu, and AliExpress. A design patent in this category can provide meaningful enforcement leverage because visual similarity is easy to photograph and assert, and accused sellers are often small operators without IP counsel. For competitors and marketplace sellers, the strategic risk is asymmetric: the cost of a TRO asset freeze can far exceed the cost of a proactive design clearance before product launch.
Should your team run an FTO against USD1074223S?
Any seller, importer, or distributor of tripod easel stands — particularly those supplying online marketplaces — should assess their exposure to USD1074223S. Jinlong’s willingness to file suit and its retention of without-prejudice refiling rights suggests active enforcement intent. The ornamental design claim means that visual similarity of the product’s appearance, rather than functional overlap, is the operative legal test. Even minor aesthetic differences may be sufficient to avoid infringement — but that assessment requires a formal point-of-novelty analysis against the claimed design.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD1074223S against your product’s design, surface prior art that may limit the patent’s enforceable scope, and identify related design patent families that could present additional risk. For product teams preparing to launch or scale a tripod easel stand or similar display product, an Eureka FTO report provides the documented clearance evidence that strengthens your freedom-to-operate position and supports a proactive response to any Schedule A-style enforcement action.
Run a freedom-to-operate analysis on USD1074223S to assess your product’s exposure
Run FTO in Eureka →Similar design patent infringement cases — Schedule A online seller enforcement
Explore related design patent enforcement actions in the Northern District of Illinois targeting anonymous Schedule A online marketplace sellers of consumer goods.
What this case signals for the consumer goods design patent IP landscape
Schedule A enforcement over ornamental designs is intensifying. A 35-day lifecycle reveals how quickly these cases are weaponised and resolved outside the public record.
Without-prejudice dismissals in Schedule A cases rarely signal surrender
In Schedule A enforcement, voluntary dismissal without prejudice often follows an off-record resolution — settlement, asset freeze compliance, or seller de-listing. IP teams monitoring competitors or their own exposure should not interpret this dismissal as a sign that USD1074223S has been abandoned or found unenforceable.
Design patents on consumer goods products carry real enforcement leverage
USD1074223S covers the ornamental design of a tripod easel stand — a product category with numerous look-alike competitors on online marketplaces. Design patent holders in this space can move quickly from filing to TRO, creating significant commercial disruption for accused sellers even before any merits ruling.
Jinlong v Individuals — key questions answered
It means Jinlong voluntarily ended the lawsuit without any court ruling on the merits, and retains the right to refile the same claims against any or all Schedule A defendants in a future action. The dismissal was made under Fed. R. Civ. P. 41(a)(1)(A)(i), which allows plaintiff-initiated dismissal before any answer is filed.
USD1074223S protects the ornamental design — the visual appearance — of a tripod easel stand. As a design patent, it does not cover the functional mechanics of the stand; protection is limited to the novel aesthetic elements as depicted in the patent’s drawings, assessed under the ordinary observer test.
Yes. Because the dismissal was expressly without prejudice, Jinlong preserves its right to bring a new action asserting USD1074223S against any defendant from the original Schedule A, subject to applicable statutes of limitations. The dismissal does not extinguish the underlying patent rights.
Schedule A enforcement actions are frequently accompanied by ex parte TROs and account or asset freezes that create immediate commercial pressure on accused sellers. This pressure commonly leads to rapid off-record settlements or voluntary seller compliance, which can produce a plaintiff voluntary dismissal within weeks of filing — consistent with the 35-day duration seen in this case.
The case (1:25-cv-10146) was filed in the U.S. District Court for the Northern District of Illinois and assigned to Judge Sharon Johnson Coleman. The Northern District of Illinois, particularly in Chicago, is a well-known venue for Schedule A design patent enforcement actions and has developed substantial procedural practice in this area.
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