Lvliang Lishi v. Junpeng Wu: Dismissed for Lack of Personal Jurisdiction in 39 Days
Lvliang Lishi Linglong Electronic Trade Co. Ltd. filed suit against Junpeng Wu in the Illinois Northern District Court asserting US11925592B1 in connection with the TheGAME, Martino, and Maiden product lines. The court dismissed the case without prejudice after just 39 days, finding it lacked personal jurisdiction over the defendant — leaving the door open for refiling in a competent forum.
Jurisdiction gap ends Illinois patent action in under six weeks
On March 31, 2025, Lvliang Lishi Linglong Electronic Trade Co. Ltd. filed a declaratory judgement action against individual defendant Junpeng Wu in the U.S. District Court for the Northern District of Illinois, asserting US11925592B1 in relation to the TheGAME, Martino, and Maiden product lines. The plaintiff simultaneously sought a temporary restraining order, signalling urgency around the alleged IP dispute. Attorneys from Aronberg Goldgehn represented the plaintiff; defendant Wu was represented by J. Zhang & Associates PC.
On May 9, 2025 — just 39 days after filing — the court granted Wu’s motion to dismiss, terminating the case without prejudice on the ground that the Northern District of Illinois lacked personal jurisdiction over the defendant. The court also denied the plaintiff’s TRO motion without prejudice, explicitly noting it may be refiled in a court possessing jurisdiction over Wu. A dismissal without prejudice means no merits determination was reached, and the plaintiff is free to bring the same claims in an appropriate forum.
The speed of resolution — under six weeks — suggests the jurisdictional defect was identified early and was not contested on substantive patent grounds. What remains unknown from the public record is where Wu is domiciled or what contacts, if any, were alleged to establish Illinois jurisdiction. The outcome leaves plaintiff’s patent rights entirely intact but requires strategic re-evaluation of venue before any future enforcement action proceeds against Wu.
Filing to Dismissed without Prejudice in 39 days
39 days — well below the median district court patent case duration of 2+ years
Dismissed without prejudice: what the jurisdictional ruling means for both parties
Personal jurisdiction dismissal — no merits ruling on the patent
A dismissal for lack of personal jurisdiction is purely procedural: the court ruled it has no authority over the defendant, not that the patent claims lack merit. Under Rule 12(b)(2), plaintiffs must establish that the defendant has sufficient contacts with the forum state. Here, the court found those contacts absent. The case was dismissed without prejudice, meaning the underlying patent dispute remains entirely unresolved.
Procedural — no merits adjudicationPlaintiff retains full right to refile in the correct jurisdiction
A ‘without prejudice’ dismissal does not extinguish the plaintiff’s claims. Lvliang Lishi Linglong may refile the same patent infringement or declaratory judgement action in any court that can properly assert personal jurisdiction over Junpeng Wu. The court explicitly noted the TRO may also be refiled there. Crucially, this outcome carries no preclusive effect — the patent’s validity and infringement questions remain open for future litigation.
Plaintiff may refile — no claim preclusionWu escapes Illinois forum — but faces potential suit elsewhere
Junpeng Wu’s successful motion to dismiss removes him from the Illinois forum, which may have been strategically or practically unfavourable. However, this is not a final victory on the merits: the defendant remains exposed to the same patent claims in any jurisdiction where personal jurisdiction can properly be established. The result is a venue victory, not a substantive one, and the underlying IP dispute likely continues.
Venue win — merits exposure remainsEnforcement strategy must now account for defendant’s jurisdictional footprint
For companies in the electronic trade and consumer goods sector, this case is a reminder that patent enforcement actions against individual defendants — particularly those with unclear or limited U.S. contacts — require careful jurisdictional analysis before filing. A failed forum selection wastes time and litigation cost, and may alert the defendant. Plaintiff’s counsel must now identify Wu’s minimum contacts with another U.S. district before proceeding.
Venue strategy critical for enforcementFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Lvliang Lishi Linglong Electronic Trade Co.Ltd. | Company | Electronic trade company — holder of US11925592B1 covering TheGAME/Martino/Maiden goodsSearch in Eureka ↗ |
| Defendant | Junpeng Wu | Individual | Individual defendant Junpeng Wu — successfully challenged Illinois personal jurisdictionSearch in Eureka ↗ |
| Plaintiff counsel | Karolina Jozwiak | Attorney | Counsel for Lvliang Lishi Linglong Electronic Trade Co.Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Matthew L. De Preter | Attorney | Counsel for Lvliang Lishi Linglong Electronic Trade Co.Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Aronberg Goldgehn | Law Firm | Representing Lvliang Lishi Linglong Electronic Trade Co.Ltd.Search in Eureka ↗ |
| Defendant counsel | Jiyuan Zhang | Attorney | Counsel for Junpeng WuSearch in Eureka ↗ |
| Defendant law firm | J. Zhang & Associates PC | Law Firm | Representing Junpeng WuSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order granting dismissal under Rule 12(b)(2) confirms that the threshold question of personal jurisdiction was dispositive before any substantive patent analysis could occur. The explicit denial of the TRO ‘without prejudice to refiling in a court that has jurisdiction over Wu’ signals the court found no procedural bar to the plaintiff’s claims on the merits — only a forum defect. This framing is favourable to the plaintiff in any future refiling, as it suggests the court did not find the underlying claims frivolous or the relief sought inherently inappropriate.
US11925592B1 — TheGAME, Martino & Maiden electronic trade products
US11925592B1 (application number US18/202966) is the sole patent asserted in this case, covering technology embodied in the TheGAME, Martino, and Maiden product lines sold or distributed by Lvliang Lishi Linglong Electronic Trade Co. Ltd. The patent was granted as a U.S. utility patent, and its assertion in a declaratory judgement context suggests the plaintiff sought affirmative confirmation of rights — or was responding to an existing dispute over those products. The electronic trade designation places this patent within the competitive consumer goods marketplace sector.
For competitors and marketplace sellers operating in the same electronic trade product categories, US11925592B1 represents an active enforcement asset. The plaintiff’s willingness to pursue litigation — including a TRO application — signals a commercial commitment to excluding unauthorised products. Although this case was dismissed on procedural grounds, the patent itself remains in force and the plaintiff retains all enforcement rights. Any company selling products that may overlap with the TheGAME, Martino, or Maiden categories should assess their exposure under this patent’s claims.
Should you run an FTO analysis against US11925592B1?
Product teams and sourcing managers working in electronic consumer goods — particularly those operating on marketplace platforms where TheGAME, Martino, or Maiden branded or functionally similar products compete — should treat US11925592B1 as an active risk. The patent holder has already demonstrated willingness to litigate and seek emergency injunctive relief. A freedom-to-operate analysis is advisable for any new product launch or expansion into this product category.
PatSnap Eureka’s FTO Search Agent can map the claim scope of US11925592B1 against your product specifications, identify prior art that may support design-around strategies, and surface related patent families held by Lvliang Lishi Linglong Electronic Trade Co. Ltd. This enables R&D and legal teams to assess exposure before committing to a product line — rather than after receiving a cease and desist.
Run a freedom-to-operate analysis on US11925592B1 to assess your product’s exposure
Run FTO in Eureka →Similar patent cases in electronic trade and consumer goods enforcement
Explore related patent litigation in the electronic trade and consumer goods sector filed in Illinois Northern District Court and comparable U.S. venues.
What this case signals for the consumer electronics IP enforcement landscape
A swift jurisdictional dismissal against an individual defendant exposes key enforcement risks in cross-border electronic trade patent cases.
Jurisdictional due diligence is prerequisite to any patent enforcement action
Filing in a court without proper personal jurisdiction over the defendant wastes resources and forfeits the element of surprise — particularly relevant when pursuing individual actors in the electronic trade sector. Investigate the defendant’s contacts, residence, and business activity in the target forum before filing.
Without prejudice dismissal preserves the patent — but not enforcement momentum
US11925592B1 survives this action entirely unscathed on the merits. However, plaintiff must now refile in a competent forum, re-serve the defendant, and potentially rebuild the factual record. Each delay increases the risk of ongoing infringement going unchecked and of the defendant reorganising assets or activities.
Lvliang v Junpeng — key questions answered
The Illinois Northern District Court dismissed the case without prejudice because it lacked personal jurisdiction over defendant Junpeng Wu. The court granted Wu’s Rule 12(b)(2) motion to dismiss on May 9, 2025, without reaching any merits of the patent dispute involving US11925592B1.
A dismissal without prejudice means no merits determination was made and the plaintiff retains the right to refile the same patent claims in a court that can properly assert personal jurisdiction over Junpeng Wu. US11925592B1 remains valid and enforceable. There is no claim preclusion arising from this dismissal.
The court denied the plaintiff’s motion for a temporary restraining order without prejudice, explicitly noting it may be refiled in a court that has jurisdiction over Wu. The denial was procedural — the court made no finding on the merits of the TRO application or on whether immediate harm was established.
The patent at issue is US11925592B1, filed under application number US18/202966. It is asserted in connection with the TheGAME, Martino, and Maiden product lines sold or distributed by the plaintiff. The patent was the sole IP right asserted in this declaratory judgement action.
Yes. Because the dismissal was without prejudice and solely on jurisdictional grounds, Lvliang Lishi Linglong Electronic Trade Co. Ltd. may refile in any U.S. district court that can establish personal jurisdiction over Junpeng Wu. The court’s order explicitly preserved this right, including the ability to refile for a TRO in the appropriate forum.
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