Lucky Wang v. Schedule A Defendants: Door Knocker Design Patent Dismissed Without Prejudice
Lucky Wang brought a design patent infringement action in the Northern District of Illinois asserting USD1039961S — a design patent covering door knockers — against a group of unnamed online marketplace defendants. After 211 days, the plaintiff voluntarily dismissed the entire action without prejudice under Fed. R. Civ. P. 41(a)(1), leaving the door open to refile.
Design patent enforcement against online marketplace sellers ends voluntarily
On November 21, 2024, plaintiff Lucky Wang filed suit in the U.S. District Court for the Northern District of Illinois, Case No. 1:24-cv-11983, asserting infringement of design patent USD1039961S (application no. US29/938624), which covers the ornamental design of door knockers. The defendants were identified collectively as ‘The Partnerships and Unincorporated Associations Identified on Schedule A’ — a common pleading convention used in multi-defendant e-commerce enforcement actions to target anonymous online sellers across platforms such as Amazon or AliExpress.
The case closed on June 20, 2025, when Lucky Wang, represented by Faye Yifei Deng of YK Law LLP, filed a voluntary dismissal of the entire action without prejudice pursuant to Fed. R. Civ. P. 41(a)(1)(A). A dismissal without prejudice means no judgment was entered on the merits and the plaintiff retains the right to refile the same claims at a future date, subject to applicable statutes of limitations. The defendants, none of whom appear to have filed formal appearances or retained counsel of record, faced no adverse ruling.
A 211-day lifespan without any recorded verdict, injunction, or damages award is consistent with the typical arc of Schedule A design patent enforcement campaigns, where plaintiffs often obtain temporary restraining orders and asset freezes early in the case, then resolve individual defendants through private settlements before dismissing the remainder. The public record does not disclose whether settlements were reached with any Schedule A defendants, and the without-prejudice dismissal leaves the legal status of the patent’s enforceability against these specific parties unresolved.
Filing to Dismissed without Prejudice in 211 days
211-day lifespan — resolved before trial, consistent with early settlement or enforcement leverage
Dismissed without prejudice: what Rule 41(a)(1) means for both parties
Rule 41(a)(1): a plaintiff-controlled exit with no merits ruling
Fed. R. Civ. P. 41(a)(1)(A) allows a plaintiff to dismiss an action without a court order before the opposing party serves an answer or a motion for summary judgment. Because no defendants appear to have filed formal appearances, Lucky Wang could exit the litigation unilaterally. Critically, no judgment was entered — the court made no finding on infringement, validity, or damages.
No merits adjudicationWithout prejudice: the right to refile survives
A dismissal without prejudice means the plaintiff is not barred from bringing the same claims again. The public record is silent on whether individual Schedule A defendants reached private settlements. Some may have paid to be removed; others may remain exposed to future suit. This distinguishes a without-prejudice dismissal from a with-prejudice one, which would extinguish the claims permanently.
Refiling right preservedDefendants face no judgment — but remain at risk
The Schedule A defendants received no adverse ruling and face no court-ordered injunction or damages from this action. However, the without-prejudice dismissal means Lucky Wang could refile against any defendant who did not settle. Defendants who continued selling the accused door knocker design after dismissal may remain exposed to a new enforcement action.
No judgment; exposure remainsDesign patent enforcement campaigns: what this outcome signals
Schedule A enforcement campaigns targeting e-commerce sellers are a common monetisation strategy for design patent holders. A voluntary without-prejudice dismissal typically suggests the campaign achieved its enforcement objectives — through TROs, asset freezes, or private settlements — without needing a full trial. USD1039961S remains an enforceable patent and can anchor future enforcement rounds.
Patent remains enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Lucky Wang | Individual | IP enforcement plaintiff — holder of door knocker design patent USD1039961SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Unnamed online marketplace sellers identified collectively on a confidential Schedule ASearch in Eureka ↗ |
| Plaintiff counsel | Faye Yifei Deng | Attorney | Counsel for Lucky WangSearch in Eureka ↗ |
| Plaintiff law firm | YK Law LLP | Law Firm | Representing Lucky WangSearch in Eureka ↗ |
| Presiding judge | Judge Martha M. Pacold | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal was filed by the plaintiff under Fed. R. Civ. P. 41(a)(1), which permits unilateral dismissal without a court order when no defendant has answered or moved for summary judgment. The ‘without prejudice’ qualifier is legally significant: it forecloses no future claim, creates no estoppel, and establishes no precedent on the validity or infringement of USD1039961S. The court made no merits finding. Both the enforceability of the patent and the liability of individual Schedule A defendants remain legally unresolved.
USD1039961S — Ornamental design for a door knocker
USD1039961S (application no. US29/938624) is a U.S. design patent protecting the ornamental appearance of a door knocker. Design patents under 35 U.S.C. § 171 protect the visual, non-functional characteristics of a manufactured article — meaning the scope of protection is limited to the specific aesthetic depicted in the patent drawings. The application number prefix ’29/’ confirms this is a design patent application, distinct from utility patents, and the ‘D’ prefix on the grant number designates it as such under USPTO classification.
For consumer hardware products sold on e-commerce platforms, design patents are strategically potent. Unlike utility patents — which require proving functional claims — a design patent infringement analysis applies the ‘ordinary observer’ test: would an ordinary purchaser mistake the accused product for the patented design? This lower evidentiary threshold, combined with the visual nature of online listings, makes design patents on items like door knockers particularly effective in Schedule A campaigns targeting marketplace sellers. Competitors offering similar ornamental hardware in the U.S. market should map their product aesthetics against USD1039961S.
Should you run an FTO analysis against USD1039961S?
Any manufacturer, importer, or online seller of door knockers — particularly those supplying U.S. e-commerce platforms — should conduct a freedom-to-operate review against USD1039961S. The active enforcement of this design patent in federal court confirms the holder is monitoring the market. Because design patent infringement turns on visual similarity under the ordinary observer test, even products not deliberately copied may be at risk if their ornamental appearance is substantially similar to the patented design as depicted in the patent drawings.
PatSnap Eureka’s FTO Search Agent can map USD1039961S against your product’s design profile, surface related design patent families, and flag prior art that may bear on validity. For teams managing multiple SKUs across global markets, Eureka’s portfolio monitoring tools can flag new design patent filings in the consumer hardware category before they become enforcement risks — giving procurement and product design teams advance warning to adjust specifications.
Run a freedom-to-operate analysis on USD1039961S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in the Northern District of Illinois
Browse comparable design patent enforcement actions targeting e-commerce sellers in the Northern District of Illinois, including multi-defendant Schedule A cases involving consumer product designs.
What this case signals for the consumer product design IP landscape
Schedule A enforcement campaigns are a growing fixture of U.S. design patent practice. This case illustrates the standard playbook and its strategic ceiling.
Schedule A campaigns rarely reach verdict — and are designed not to
The without-prejudice dismissal after 211 days is consistent with the standard Schedule A enforcement lifecycle. Plaintiffs typically use early TROs and payment-processor freezes to compel settlements, then dismiss remaining defendants. This case confirms that USD1039961S is being actively enforced and that the strategy generated at least some off-record resolution.
Design patents on everyday products carry real enforcement leverage
Door knocker designs may seem low-stakes, but design patents on manufactured consumer goods are powerful against online marketplace sellers whose primary liability exposure is platform removal and asset freezes — not damages trials. Companies selling ornamental hardware products should audit their SKUs against active design patent portfolios like USD1039961S.
Wang v Partnerships — key questions answered
The case was voluntarily dismissed without prejudice by plaintiff Lucky Wang on June 20, 2025, under Fed. R. Civ. P. 41(a)(1). No merits ruling was issued. The dismissal without prejudice means Lucky Wang retains the right to refile claims based on design patent USD1039961S against any or all of the Schedule A defendants.
A dismissal without prejudice creates no res judicata bar and no adverse judgment against the defendants. Any Schedule A defendant who did not reach a private settlement with Lucky Wang remains legally exposed to a new action asserting the same patent. Defendants should not treat this dismissal as a permanent resolution of their liability risk.
The case asserts design patent USD1039961S (application no. US29/938624), a U.S. design patent covering the ornamental design of a door knocker. Design patents protect the visual appearance of a manufactured article and are enforced using the ordinary observer test for infringement.
The Northern District of Illinois, particularly in Chicago, has become a favoured venue for Schedule A e-commerce enforcement actions due to its procedures for granting ex parte temporary restraining orders and asset freezes against anonymous online sellers. These early-stage remedies are central to the enforcement leverage that makes Schedule A campaigns commercially viable for design patent holders.
Yes. A voluntary dismissal without prejudice under Rule 41(a)(1) does not bar the plaintiff from refiling the same claims. Lucky Wang could initiate a new action asserting USD1039961S against any unsettled Schedule A defendants, subject to applicable statutes of limitations. The six-year limitation period for patent infringement under 35 U.S.C. § 286 would govern recovery of damages in any subsequent action.
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