Liangliang Su v. Schedule A Defendants: Design Patent Dispute Over Bluetooth Headphones Stayed
Liangliang Su filed a design patent infringement action in Florida’s Southern District Court targeting anonymous online sellers of Bluetooth headphones, earbuds, and charge cases. After 256 days, the court administratively closed the case — not on the merits — while staying proceedings to allow service on remaining defendants via Amazon subpoena.
Schedule A Design Patent Case Stalled at Service Stage in Florida
On June 1, 2024, plaintiff Liangliang Su filed a complaint in the U.S. District Court for the Southern District of Florida alleging infringement of design patent USD902,588S — covering the ornamental design of Bluetooth headphones, wireless earbuds, and charge cases — against a large group of anonymous online merchants identified only on Schedule A. The Palmer Law Group PA represented Su, a litigation structure typical of design patent enforcement against suspected counterfeit or copycat e-commerce sellers.
The court granted alternative service by email and website publication in June 2024, but service difficulties persisted for months. A November 2024 status conference prompted an Omnibus Order requiring 30-day status reports and responses to Su’s TRO motion. A subpoena served on Amazon in November 2024 — seeking seller identification data — was formally objected to by Amazon’s counsel. By January 2025, Su reported a partial agreement with Amazon but could not confirm when defendant identities would be obtained. On February 12, 2025, Judge Melissa Damian stayed the action and administratively closed it, setting an April 1, 2025 deadline for Su to perfect service or face dismissal of unserved defendants without prejudice.
The 256-day timeline reflects procedural friction common to Schedule A actions against pseudonymous defendants, not a substantive ruling on the patent’s validity or infringement. The court’s administrative closure is a docket management tool — jurisdiction is expressly retained. Whether Su ultimately serves sufficient defendants to pursue meaningful relief, or whether the case lapses into dismissals without prejudice, remains unknown from the public record. The Amazon subpoena dispute highlights a recurring tension in platform-based IP enforcement.
Filing to Case Stayed in 256 days
256 days from filing to administrative closure — shorter than average Schedule A patent cases, which frequently exceed 18 months
Administrative closure explained: what a stay means for both parties
Administrative closure is not a dismissal on the merits
The court’s February 12, 2025 order stays the action and closes it for administrative and statistical purposes only. This is a docket management tool under the court’s inherent authority — not a judgment on the patent’s validity or infringement. The court expressly retains jurisdiction and has set an April 1, 2025 deadline for Su to complete service. Unserved defendants face dismissal without prejudice if that deadline is missed.
Jurisdiction retainedSu retains the right to proceed — if service is completed
The administrative closure does not extinguish Su’s claims. If Amazon provides the subpoenaed seller data and service is perfected by April 1, 2025, the case can resume on its merits. However, failure to serve remaining defendants will result in their dismissal without prejudice — meaning Su could refile but loses momentum and incurs additional cost. The partial agreement with Amazon suggests some defendants may yet be identified.
Refiling possibleUnserved defendants benefit from the delay — for now
Defendants who have not been served face no immediate liability while the stay is in effect. If Su fails to meet the April 2025 deadline, those defendants would be dismissed without prejudice — a temporary reprieve rather than a permanent win. Defendants who have already appeared face potential TRO and preliminary injunction proceedings once the stay lifts, given Su’s pending motion for asset restraint and expedited discovery.
Temporary protection onlyPlatform subpoena resistance raises enforcement cost for design patentees
Amazon’s formal objection to Su’s identification subpoena illustrates a growing friction point in Schedule A litigation: platform cooperation is not guaranteed, and contested subpoenas materially extend timelines and costs. For design patent holders pursuing e-commerce infringers, this case signals that even court-authorised alternative service may not resolve the identification problem quickly. Enforcing design rights against pseudonymous sellers requires sustained resources.
Platform enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Liangliang Su | Individual | Individual patent holder asserting design rights over Bluetooth audio product aesthetics — holder of USD902,588SSearch in Eureka ↗ |
| Defendant | The Individuals, Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous e-commerce sellers of Bluetooth headphones, earbuds, and charge cases identified on Schedule ASearch in Eureka ↗ |
| Plaintiff counsel | Andrew Jonathan Palmer | Attorney | Counsel for Liangliang SuSearch in Eureka ↗ |
| Plaintiff law firm | Palmer Law Group PA | Law Firm | Representing Liangliang SuSearch in Eureka ↗ |
| Presiding judge | Judge Melissa Damian | Judge | Florida Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The February 12, 2025 order is a procedural stay, not a merits ruling. The court’s language — closing the case ‘for administrative and statistical purposes only’ while expressly retaining jurisdiction — signals that this closure is reversible. The order imposes a hard April 1, 2025 service deadline; failure triggers dismissal without prejudice for unserved defendants. No findings on infringement, validity, or damages have been made. The pending TRO motion for asset restraint and expedited discovery remains live, suggesting the case could accelerate quickly once the service obstacle is resolved.
USD902,588S — Ornamental Design for Bluetooth Headphones and Earbuds
USD902,588S (application number US29/739,641) is a U.S. design patent protecting the ornamental appearance — not functional characteristics — of Bluetooth headphones, wireless earbuds, and their charge cases. Design patents under 35 U.S.C. § 171 cover the visual, non-functional aspects of a product. Infringement is assessed using the ‘ordinary observer’ test: whether an ordinary purchaser would be deceived into thinking the accused product is the same as the patented design.
In the hyper-competitive Bluetooth audio accessories market, visual differentiation is commercially significant — and copycat products from anonymous e-commerce sellers are a persistent enforcement challenge. Design patents like USD902,588S are increasingly used as enforcement tools against Schedule A defendants on Amazon and similar platforms, where product photos directly reflect the protected ornamental design. The patent’s continued assertion, despite service difficulties, suggests Su views its scope as sufficiently broad to cover multiple accused product variants.
Should you run an FTO check against USD902,588S?
Any company manufacturing, importing, or selling Bluetooth headphones, wireless earbuds, or compatible charge cases in the U.S. market should assess exposure to USD902,588S. The ordinary observer standard for design patents is broader than it may appear — visual similarity across a product category can trigger infringement even without intent to copy. Sellers on Amazon and similar platforms are the direct targets of this litigation, but downstream distributors and OEM buyers may also carry risk.
PatSnap Eureka’s FTO Search Agent enables R&D and product teams to map the ornamental design claims of USD902,588S against proposed product aesthetics before launch. Eureka identifies design patent families, prior art, and similar granted designs in the Bluetooth audio accessories space — helping counsel assess whether a clearance opinion is warranted and where design-around opportunities exist.
Run a freedom-to-operate analysis on USD0902588S to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A Design Patent Cases in Florida Courts
Explore comparable Schedule A design patent enforcement actions targeting Bluetooth audio and consumer electronics sellers filed in Florida Southern District Court.
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SettledRelated infringement action — same court
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DecidedLiangliang Su’s broader IP enforcement history
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Portfolio viewWhat this case signals for the consumer electronics design IP landscape
Schedule A design patent actions against e-commerce sellers face structural friction at the service stage — this case illustrates the pattern clearly.
Amazon subpoena resistance is now a material enforcement variable
When platforms formally object to identification subpoenas, Schedule A cases stall at the service stage — often for months. Design patent holders must budget for contested subpoena negotiations and build in timeline contingency. Su’s case took over seven months to reach a partial Amazon agreement, with no final resolution yet.
Administrative closure is not case death — monitor the April 2025 deadline
The court’s stay preserves jurisdiction and sets a hard service deadline. Competitors and downstream sellers in the Bluetooth headphones space should monitor whether Su perfects service and the TRO motion proceeds. An asset-restraining TRO against appearing defendants could freeze seller accounts rapidly once the stay lifts.
Design patent USD902,588S poses live risk to Bluetooth audio product sellers
The case has not been dismissed on the merits. USD902,588S remains an asserted, active design patent covering the ornamental appearance of Bluetooth headphones and earbuds. Any seller with a product visually similar to the protected design remains a potential target if Su resumes enforcement post-stay.
Schedule A TRO strategy could freeze e-commerce assets rapidly post-service
Su’s pending motion seeks not only injunctive relief but asset restraint and expedited discovery — a combined package that, if granted by Judge Damian, could freeze PayPal and Amazon Seller balances before defendants can liquidate. This enforcement playbook is increasingly common in the Southern District of Florida.
Su v Individuals — key questions answered
The case was administratively closed on February 12, 2025, via a court-ordered stay. This is not a dismissal on the merits. The court retained jurisdiction and set an April 1, 2025 deadline for plaintiff Liangliang Su to complete service on remaining defendants. Failure to do so would result in dismissal without prejudice for unserved parties.
The asserted patent is USD902,588S (U.S. application no. 29/739,641), a design patent protecting the ornamental appearance of Bluetooth headphones, wireless earbuds, and associated charge cases. Design patents cover visual, non-functional aspects and infringement is assessed under the ordinary observer test.
Judge Melissa Damian stayed the action under the court’s inherent docket management authority because Su had not yet perfected service on all Schedule A defendants. The administrative closure is a statistical tool — jurisdiction is expressly retained. The stay allows Su until April 1, 2025 to obtain defendant identification data from Amazon and complete service.
Schedule A cases involve large groups of anonymous e-commerce defendants whose identities are withheld at filing to prevent asset concealment. Plaintiffs typically seek TROs to freeze seller accounts and subpoena platforms like Amazon for seller data. The Southern District of Florida is one of the most active venues for this litigation format, particularly in consumer goods and design patent cases.
Per the court’s February 12, 2025 order, unserved defendants will be dismissed without prejudice and without further notice. Dismissal without prejudice means Su could theoretically refile against those defendants, but would face statute of limitations, cost, and strategic challenges. Defendants who have already appeared remain in the case and subject to Su’s pending TRO motion.
Monitor Bluetooth audio design patent enforcement before your next product launch
USD902,588S remains an active enforcement risk in the U.S. market. Use PatSnap Eureka to run FTO analysis, track Schedule A litigation activity, and identify design-around opportunities in the Bluetooth headphones and earbuds category.
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