JJ Zhang v. Schedule A Defendants: Design Patent Suit Voluntarily Dismissed
JJ Zhang filed suit in the Northern District of Illinois asserting design patent USD1004815S covering a fan with light against anonymous online sellers. The case closed after just 50 days when the plaintiff voluntarily dismissed the entire action under Fed. R. Civ. P. 41(a)(1), leaving the public record silent on whether a settlement was reached.
Design patent dispute over fan-with-light product ends in voluntary exit
On October 15, 2025, plaintiff JJ Zhang filed an infringement action (Case No. 1:25-cv-12597) in the Northern District of Illinois before Judge Georgia N. Alexakis. The suit named the anonymous ‘Partnerships and Unincorporated Associations identified in Schedule A’ — a common litigation tactic targeting online marketplace sellers — and asserted design patent USD1004815S (application no. US29/857847) covering a fan with light product.
The case closed on December 4, 2025, just 50 days after filing. Plaintiff JJ Zhang invoked Fed. R. Civ. P. 41(a)(1) to dismiss the entire action. The basis of termination is recorded as ‘Voluntary dismissal.’ The public docket does not specify whether the dismissal was with or without prejudice, which carries meaningfully different consequences for both parties — see the outcome analysis cards below.
A 50-day lifespan suggests the dispute was resolved — or abandoned — before any defendant appeared, filed responsive pleadings, or engaged in substantive motion practice. Schedule A cases of this type frequently conclude quickly when targeted sellers comply, settle informally, or cannot be served. What specifically drove the dismissal here is not discernible from the public record.
Filing to Voluntary dismissal in 50 days
50-day lifespan — resolved well before any substantive court ruling
Voluntarily dismissed: what the Rule 41(a)(1) exit means for both parties
Rule 41(a)(1): plaintiff’s unilateral right to exit
Fed. R. Civ. P. 41(a)(1) permits a plaintiff to dismiss an action without a court order by filing a notice before the defendant serves an answer or motion for summary judgment. This is the earliest, cleanest exit available — no judicial approval required. The dismissal here was filed at the whole-action level, ending all claims against all Schedule A defendants simultaneously.
Procedural dismissal — no merits rulingThe public record is silent on prejudice designation
A dismissal ‘with prejudice’ bars the plaintiff from re-filing the same claims — permanently extinguishing the suit. A dismissal ‘without prejudice’ preserves the right to refile. Under Rule 41(a)(1), a first voluntary dismissal is automatically without prejudice unless the notice states otherwise. The verdict text references ‘without prejudice,’ suggesting this is the operative designation — but independent verification from the docket is advisable before drawing firm conclusions.
Refiling rights likely preservedSellers exit without a finding of non-infringement
The Schedule A defendants obtained no merits ruling in their favour. No court adjudicated whether USD1004815S is valid or whether their products infringe. A dismissal without prejudice means defendants cannot rely on this outcome as a bar to future suits. Sellers who remain in the relevant product category should treat this case as an unresolved enforcement signal rather than a cleared path.
No infringement ruling issuedDesign patent enforcement via Schedule A remains a live risk
Schedule A design patent suits targeting online sellers of consumer goods — including fan and lighting accessories — are a well-established enforcement strategy. A voluntary dismissal without prejudice does not signal weakness in the underlying patent; it may reflect a settlement, seller compliance, or a tactical reset. Online marketplace sellers in adjacent product categories should monitor USD1004815S and related filings by JJ Zhang for renewed enforcement activity.
Refiling risk remainsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | JJ Zhang | Individual | Design patent holder asserting ornamental IP rights in fan-with-light productsSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations identified in Schedule A | Individual | Anonymous online marketplace sellers identified collectively in Schedule ASearch in Eureka ↗ |
| Plaintiff counsel | Faye Yifei Deng | Attorney | Counsel for JJ ZhangSearch in Eureka ↗ |
| Plaintiff law firm | YK Law LLP | Law Firm | Representing JJ ZhangSearch in Eureka ↗ |
| Presiding judge | Judge Georgia N. Alexakis | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The plaintiff’s Rule 41(a)(1) notice states dismissal of the ‘entire action without prejudice,’ ending all claims against all Schedule A defendants in one filing. No judge signature was required and no merits determination was made. The phrase ‘without prejudice’ — if operative — means JJ Zhang retains the right to refile against any or all of the named sellers. The absence of any defendant filing on the docket is consistent with an early-stage resolution, whether through informal settlement, seller compliance, or a plaintiff decision not to proceed.
USD1004815S — Ornamental design for a fan with light
USD1004815S is a US design patent (application no. US29/857847) protecting the ornamental appearance of a fan with light. Design patents cover the visual, non-functional characteristics of a product — in this case, the specific aesthetic configuration of a combined fan and light unit. Design patents are typically granted more quickly than utility patents and carry a 15-year term from grant. The filing context suggests this patent targets the consumer electronics and home goods segment, where differentiated product aesthetics are commercially significant.
Fan-with-light combination products are a crowded category on major e-commerce platforms, making design patent enforcement particularly valuable as a tool to distinguish ornamental variants and suppress copycat listings. USD1004815S, if broadly claimed, could cover a wide range of visually similar fan-light products. Competitors and online sellers in this category should assess claim scope carefully — design patent infringement is determined by the ‘ordinary observer’ test, which focuses on overall visual impression rather than feature-by-feature comparison.
Should your team run an FTO against USD1004815S?
Any company designing, importing, or selling fan-with-light products for the US market — particularly through online marketplaces — should consider an FTO assessment against USD1004815S. The voluntary dismissal in this case does not reflect a finding of non-infringement; the patent remains in force. Given the Schedule A enforcement model, sellers may receive no warning before a TRO application and account freeze are filed.
PatSnap Eureka’s FTO Search Agent allows R&D and IP teams to map the visual claim scope of USD1004815S against your product designs, identify prior art that could support invalidity arguments, and monitor for continuation or related design filings by the same applicant. Running this analysis before launching or scaling a fan-with-light product line in the US is a straightforward risk mitigation step.
Run a freedom-to-operate analysis on USD1004815S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in the Northern District of Illinois
Cases involving design patent enforcement against Schedule A online sellers in the Northern District of Illinois, particularly in consumer goods and home appliance product categories.
What this case signals for the consumer goods design patent landscape
Schedule A design patent actions move fast and often resolve before the public record reveals why — here is what practitioners and sellers should take away.
Schedule A suits resolve quickly — speed of response matters
This case closed in 50 days with no recorded defendant appearance. Online sellers targeted in Schedule A design patent actions typically face TRO applications and asset freezes early. Engaging counsel immediately after being named — even before formal service — is critical to preserving defences and negotiating position.
Voluntary dismissal is not a patent validity win for defendants
USD1004815S was never adjudicated invalid or not infringed. Sellers who were dismissed without prejudice remain exposed to re-filing. Companies selling fan-with-light products through online marketplaces should conduct an FTO review against this design patent before continuing or expanding sales.
Zhang v Partnerships — key questions answered
JJ Zhang filed a design patent infringement suit in the Northern District of Illinois on October 15, 2025, asserting USD1004815S against anonymous online sellers. The plaintiff voluntarily dismissed the entire action under Fed. R. Civ. P. 41(a)(1) on December 4, 2025 — 50 days after filing — with no merits ruling issued.
A dismissal without prejudice means the plaintiff retains the right to refile the same claims against the same defendants. No court found the defendants’ products non-infringing, and the patent USD1004815S was never adjudicated invalid. Defendants in the Schedule A list should not treat this outcome as a cleared path to continue selling similar fan-with-light products in the US market.
USD1004815S (application no. US29/857847) is a US design patent protecting the ornamental appearance of a fan with light. Design patents protect the visual, non-functional look of a product for 15 years from grant. Infringement is assessed under the ‘ordinary observer’ test — whether an ordinary consumer would find the accused product’s appearance substantially similar to the patented design.
Schedule A cases target multiple anonymous online sellers simultaneously and often include ex parte TRO and asset-freeze applications at filing. Many cases close quickly because sellers comply, delist products, or settle informally before formal appearance. The 50-day timeline here is consistent with that pattern, though the specific driver is not disclosed in the public record.
Under Fed. R. Civ. P. 41(a)(1), a first voluntary dismissal is automatically without prejudice unless the notice states otherwise. The verdict text references dismissal ‘without prejudice,’ suggesting the plaintiff retains refiling rights. A second voluntary dismissal against the same defendants would operate as an adjudication on the merits under Rule 41(a)(1)(B). Sellers and IP professionals should monitor for renewed enforcement activity.
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