Liu Feng v. Schedule A Defendants: Voluntary Dismissal Strategy in E-Commerce Patent Enforcement

A patent infringement action filed in the Northern District of Illinois concluded after 140 days not through courtroom battle, but through a calculated procedural exit. In Liu Feng v. The Partnerships and Unincorporated Associations Identified in Schedule A (Case No. 1:25-cv-04598), plaintiff Liu Feng voluntarily dismissed the action without prejudice before the remaining defendant had filed any responsive pleading.

While the case produced no merits ruling, its trajectory tells a story familiar to practitioners navigating Schedule A patent litigation — a high-volume enforcement mechanism increasingly deployed against anonymous or pseudonymous online marketplace sellers. For patent attorneys, IP professionals, and R&D stakeholders, this case illustrates how patent infringement actions in the Northern District of Illinois can serve strategic purposes extending well beyond a final judgment, and why dismissals without prejudice deserve the same analytical attention as full trial verdicts.

Case Overview

The Parties

The Patent(s) and Product(s) at Issue

The specific patent numbers and accused products were not disclosed in the available case record. This is not unusual in Schedule A proceedings, where complaints are often filed under seal and full patent claim details may remain restricted during early enforcement phases. Practitioners seeking complete claim details should consult the official PACER docket for Case No. 1:25-cv-04598 in the U.S. District Court for the Northern District of Illinois.

Legal Representation

Plaintiff’s Counsel: Hao Ni and Tong Jin of Ni, Wang & Massand, PLLC, a Dallas-based intellectual property boutique.

Defendant’s Counsel: None on record — the remaining defendant had not entered an appearance prior to dismissal.

Litigation Timeline & Procedural History

The case was filed on April 28, 2025, in the U.S. District Court for the Northern District of Illinois, a preferred venue for Schedule A IP enforcement due to its established procedural familiarity with multi-defendant e-commerce cases, its efficient TRO and preliminary injunction processes, and its receptiveness to ex parte asset restraint applications.

The case proceeded under Chief Judge Joan B. Gottschall, a highly experienced jurist with decades of federal bench experience in the Northern District.

Over the 140-day lifespan of the case, the docket moved through what appears to be the standard early-phase enforcement arc: complaint filing, potential ex parte relief proceedings, defendant identification and service efforts, and ultimately reduction to a single remaining defendant. No answer, motion to dismiss, or summary judgment motion was filed by that defendant before Liu Feng elected to dismiss.

The total duration of 140 days is consistent with Schedule A cases that resolve through early-stage settlements, defendant default, or strategic dismissal rather than contested litigation.

The Verdict & Legal Analysis

Outcome

On September 15, 2025, plaintiff Liu Feng filed a Notice of Voluntary Dismissal Without Prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). The action was terminated without any merits adjudication, damages award, or injunctive relief entering against the remaining defendant.

Critically, the dismissal was executed without prejudice — meaning Liu Feng retains the legal right to refile the same claims against this defendant in the future, subject to applicable statutes of limitations and any procedural constraints.

Procedural Mechanism: Rule 41(a)(1)(A)(i)

Rule 41(a)(1)(A)(i) permits a plaintiff to dismiss an action as of right — without court approval — provided the opposing party has not yet served an answer or a motion for summary judgment. The filing of the notice itself effectuates dismissal automatically. This is a one-time, self-executing right and one of the few procedural tools that gives a plaintiff complete unilateral control over case termination.

The practical significance here: because the remaining defendant never filed a responsive pleading, Liu Feng faced no procedural barrier to invoking this right. No motion practice was required. No judicial approval was needed. The case closed on plaintiff’s terms, at plaintiff’s timing.

Strategic Analysis: Why Voluntary Dismissal Without Prejudice?

Voluntary dismissals in Schedule A patent cases frequently signal one or more of the following strategic outcomes:

• Pre-Dismissal Settlement. It is common practice for Schedule A plaintiffs to resolve disputes confidentially with individual defendants and then dismiss those defendants from the action. A dismissal without prejudice, particularly where no adverse ruling has been entered, strongly suggests that the parties reached a resolution — whether a licensing agreement, a cease-and-desist compliance, or a monetary settlement — on terms acceptable to the plaintiff. The absence of defendant counsel on record does not preclude an informal resolution.
• Defendant Non-Response / Default Considerations. Where a defendant fails to appear, plaintiffs may assess whether the cost and effort of pursuing a default judgment is commercially justified, particularly if the defendant’s assets are minimal or unlocatable.
• Preserving Litigation Optionality. A without-prejudice dismissal keeps enforcement options alive. If the infringing conduct resumes, Liu Feng may refile. This preserves leverage without committing to the costs of contested litigation.

Legal Significance

No claim construction ruling, invalidity finding, or infringement determination was entered. Accordingly, this case carries no direct precedential value on substantive patent law. However, it contributes to the broader procedural record of Schedule A enforcement in the Northern District of Illinois — a record that IP practitioners rely upon when advising clients on enforcement strategy, venue selection, and early-phase litigation economics.

Industry & Competitive Implications

The Liu Feng v. Schedule A Defendants case is one data point in a substantially larger pattern. The Northern District of Illinois has become the dominant U.S. venue for Schedule A IP enforcement, processing hundreds of such cases annually. These cases disproportionately target sellers on Amazon, Wish, and AliExpress — often small or mid-sized merchants sourcing products from overseas manufacturers.

For IP professionals in the e-commerce and consumer products sectors, this enforcement model has meaningful implications. Patent holders with product-covering utility or design patents are increasingly monetizing those rights not through single-defendant litigation but through coordinated multi-defendant campaigns designed to generate early settlements at scale.

The 140-day case lifecycle here reflects efficient enforcement economics. For in-house counsel at marketplace platforms and for brands operating in adjacent product spaces, monitoring Schedule A dockets in the Northern District of Illinois provides early warning of emerging enforcement campaigns in specific product categories.

Licensing trends in this space favor early resolution: defendants who engage promptly, even without formal counsel, frequently resolve matters on more favorable terms than those who ignore service.

FAQ

What was the outcome of Liu Feng v. Schedule A Defendants (1:25-cv-04598)?

The case was voluntarily dismissed without prejudice by plaintiff Liu Feng on September 15, 2025, pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), after 140 days of litigation. No merits ruling was entered.

What does “dismissed without prejudice” mean in patent litigation?

It means the plaintiff retains the right to refile the same claims in the future. No judgment was entered against either party, and the plaintiff’s substantive patent rights remain intact.

Why is the Northern District of Illinois a common venue for Schedule A patent cases?

The court has developed significant procedural experience with multi-defendant e-commerce IP enforcement, including efficient handling of TRO applications, sealed filings, and asset restraint orders targeting online marketplace sellers.