Book a demo

Cut patent&paper research from weeks to hours with PatSnap Eureka AI!

Try now
Liangliang Su v. Schedule A Defendants – Bluetooth Headphones Patent | PatSnap
Explore in Eureka
Case ID0:24-cv-60936
FiledJun 2024
ClosedFeb 2025
Patent Litigation

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.

Resolution time
256days
256 days from filing to administrative closure — shorter than average Schedule A patent cases, which frequently exceed 18 months
Patents asserted
1
USD0902588S — Bluetooth headphones, earbuds, and charge case industrial design
Outcome
Case Stayed
Administratively closed pending completion of service on remaining Schedule A defendants; court retains jurisdiction
Cost ruling
Not Determined
No costs or fees ruling issued; case stayed before merits adjudication
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

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.

Case at a glance
Case no.0:24-cv-60936
PlaintiffLiangliang Su
CourtFlorida Southern
JudgeMelissa Damian
FiledJune 1, 2024
ClosedFebruary 12, 2025
Duration256 days
OutcomeCase Stayed
Verdict causeInfringement Action
BasisCase Stayed
Prior Art Intelligence
See what prior art exists on this patent.
Eureka scans millions of patents and papers to surface prior art that may have invalidated these claims before costly litigation begins.
Check Prior Art
Case data sourced from PACER / Florida Southern District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

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

Case timeline: Complaint filed JUN 1 2024, OCT–NOV — 256 days total Horizontal timeline showing the three key events in Liangliang Su v The Individuals, Partnerships and Unincorporated Associations Identified on Schedule A from filing to resolution. Source: PACER, Florida Southern District Court. JUN 1 2024 Complaint filed Pre-trial proceedings FEB 12 2025 Case Stayed 256 DAYS TOTAL
Dismissal terms

Administrative closure explained: what a stay means for both parties

Legal mechanism

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 retained
Plaintiff outlook

Su 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 possible
Defendant outlook

Unserved 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 only
Commercial implications

Platform 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 risk
Legal analysis based on PACER docket records for case 0:24-cv-60936 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffLiangliang SuIndividualIndividual patent holder asserting design rights over Bluetooth audio product aesthetics — holder of USD902,588SSearch in Eureka ↗
DefendantThe Individuals, Partnerships and Unincorporated Associations Identified on Schedule AIndividualAnonymous e-commerce sellers of Bluetooth headphones, earbuds, and charge cases identified on Schedule ASearch in Eureka ↗
Plaintiff counselAndrew Jonathan PalmerAttorneyCounsel for Liangliang SuSearch in Eureka ↗
Plaintiff law firmPalmer Law Group PALaw FirmRepresenting Liangliang SuSearch in Eureka ↗
Presiding judgeJudge Melissa DamianJudgeFlorida Southern District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“THIS CAUSE is before the Court upon Plaintiff, Liangliang Su’s (“Plaintiff”), Status Report [ECF No. 27], filed January 13, 2025, and a sua sponte review of the record. THE COURT has considered the Status Report and the pertinent portions of the record and is otherwise fully advised. By way of background, Plaintiff initiated this action on June 1, 2024, by filing a Complaint alleging patent infringement under the Leahy-Smith America Invents Act, 35 U.S.C. § 100, et seq., against entities listed on Schedule “A” (collectively, “Defendants”). See generally Compl. [ECF No. 1]; see also Schedule “A” [ECF No. 9]. On June 5, 2024, Plaintiff filed an Ex Parte Motion to Serve by Alternate Means [ECF No. 7], and on June 13, 2024, the Court granted the Motion [ECF No. 12], allowing Plaintiff to serve Defendants via e-mail Case 0:24-cv-60936-MD Document 30 Entered on FLSD Docket 02/12/2025 Page 1 of 4 2 and website publication. In the ensuing weeks, certain Defendants entered a notice of appearance and motion to appear pro hac vice. See ECF Nos. 13, 14. The Court held a Status Conference on November 13, 2024, to address pending matters and the status of the service upon any remaining Defendants. See ECF No. 19. Following the Status Conference, the Court entered an Omnibus Order directing Plaintiff to effectuate service of process upon the Defendants who have yet to be served, unsealing the case, requiring the Defendants who have appeared to file responses to Plaintiff’s Motion for Entry of Temporary Restraining Order, Preliminary Injunction, Order Restraining Transfer of Assets and Expedited Discovery [ECF No. 6] by December 16, 2024, and ordering Plaintiff to file status reports every thirty (30) days beginning from the date of the Order as to the status of service. See generally ECF No. 20. As the Court noted above, Plaintiff filed its latest Status Report on January 13, 2025. [ECF No. 27]. In it, Plaintiff explains that, on November 8, 2024, it served a subpoena upon Amazon requesting information necessary to serve the remaining Defendants and that, on December 4, 2024, Amazon’s counsel formally objected to the subpoena. Id. at 1. Despite the objection, Plaintiff notes that it has “largely reached an agreement” with Amazon following extensive negotiations and, as a result, will proceed to serve the remaining Defendants once Amazon provides the information. Id. Plaintiff does not state when it expects to receive that information or when it plans to serve Defendants. “A district court has inherent authority to manage its own docket ‘so as to achieve the orderly and expeditious disposition of cases.’” Equity Lifestyle Properties, Inc. v. Fla. Mowing And Landscape Serv., Inc., 556 F.3d 1232, 1240 (11th Cir. 2009) (quoting Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991)); see also Johnson v. Bd. of Regents of Univ. of Ga., 263 F.3d 1234, 1269 Case 0:24-cv-60936-MD Document 30 Entered on FLSD Docket 02/12/2025 Page 2 of 4 3 (11th Cir. 2001) (“[W]e accord district courts broad discretion over the management of pretrial activities, including discovery and scheduling.” (citations omitted)). Additionally, “[a]bsent a showing of good cause, the district court has the discretion [pursuant to Federal Rule of Civil Procedure 4(m)] to extend the time for service of process.” Lepone-Dempsey v. Carroll Cnty. Comm’rs, 476 F.3d 1277, 1282 (11th Cir. 2007) (citing Horenkamp v. Van Winkle & Co., 402 F.3d 1129, 1133 (11th Cir. 2005)). Accordingly, in light of the Court’s inherent authority and the fact that this matter has been pending for a considerable amount of time without Plaintiff having effectuated valid service on the remaining Defendants, it is ORDERED as follows: 1. Plaintiff shall, on or before April 1, 2025, perfect service on the remaining Defendants and file proofs of service with the Court. Failure to do so will result in the dismissal of those Defendants without prejudice and without further notice. 2. Plaintiff shall continue to comply with the Court’s Omnibus Order dated November 14, 2024 [ECF No. 20], insofar as the Order directs Plaintiff to file Status Reports every thirty (30) days informing the Court of the status of service of process upon the remaining Defendants and whether any Defendants have contacted Plaintiff or Plaintiff’s counsel. 3. The above-styled action is temporarily STAYED until all Defendants have been served or April 1, 2025, whichever is earlier. Case 0:24-cv-60936-MD Document 30 Entered on FLSD Docket 02/12/2025 Page 3 of 4 4 4. The Clerk is directed to CLOSE this case for administrative and statistical purposes only. The Court nonetheless retains jurisdiction to address any future motions, including those relevant to service of process or default. DONE AND ORDERED in Chambers at the Southern District of Florida, this 12th day of February, 2025”
Source: PACER Docket, Case 0:24-cv-60936, Florida Southern District Court

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.

PACER case 0:24-cv-60936 · Public docket record Explore in Eureka ↗
Patent at issue

USD902,588S — Ornamental Design for Bluetooth Headphones and Earbuds

Publication No.USD0902588S
Application No.US29/739641
Patent details
ProductOrnamental design of Bluetooth headphones, wireless earbuds, and associated charge cases
Cited in actionJune 1, 2024

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.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

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.

PatSnap Eureka FTO Search

Run a freedom-to-operate analysis on USD0902588S to assess your product’s exposure

Run FTO in Eureka →
Related litigation

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.

🔍
Access 40+ similar cases in PatSnap Eureka
Liangliang Su patent enforcement history, Florida Southern case history, Liangliang Su’s full IP portfolio, and comparable case analysis
Schedule A Bluetooth cases FLDesign patent TRO outcomesAmazon subpoena case historyUSD design patent enforcements
Unlock similar cases in Eureka →
Strategic implications

What 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.

🔒
Full strategic analysis in PatSnap Eureka
Unlock gated insights on Schedule A enforcement strategy, design patent FTO risk, and district court TRO precedents in Florida Southern.
USD902,588S claim scopeSchedule A TRO precedentsAmazon subpoena outcomes
Unlock full analysis →
Analysis powered by PatSnap Eureka Litigation Intelligence Explore in Eureka ↗
Frequently asked questions

Su v Individuals — key questions answered

Still have questions? PatSnap Eureka can answer them instantly from patent and litigation data. Ask Eureka ↗
PatSnap Eureka

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.

Ask anything about this case.
PatSnap Eureka searches patents and litigation data to answer instantly.
Powered by PatSnap Eureka
Link copied to clipboard

Related Litigation Cases

Help us improve this page

Found incorrect or outdated information? Let us know and we'll get it fixed.