Mingsen Zhang v. Gekufa: Sink Bracket Patent Action Voluntarily Dismissed
Plaintiff Mingsen Zhang asserted US11060269B2 — a patent covering a bracket for installing sinks — against Amazon marketplace sellers in the Northern District of Illinois. The case closed after 397 days when Zhang voluntarily dismissed defendant Gekufa without prejudice under Fed. R. Civ. P. 41(a)(1)(A)(i).
A Schedule A sink-bracket enforcement action ends before adjudication
On April 13, 2024, plaintiff Mingsen Zhang filed a patent infringement action in the U.S. District Court for the Northern District of Illinois — one of the most active venues for Schedule A e-commerce enforcement matters — asserting US11060269B2, which covers a bracket for installing sinks. The sole named defendant class was ‘The Partnerships and Unincorporated Associations Identified on Schedule A,’ a procedural vehicle widely used to consolidate claims against multiple online marketplace sellers in a single filing. Gekufa, identified as defendant #3 on Schedule A, operates an Amazon storefront (Store ID: ALMG4ZS3JXRL) and sold product ASIN B0BRCWGYJD, allegedly infringing the asserted patent.
On May 7, 2025, plaintiff Zhang filed a notice of voluntary dismissal as to Gekufa specifically, invoking Fed. R. Civ. P. 41(a)(1)(A)(i), which permits a plaintiff to dismiss a defendant without a court order before that defendant serves an answer or a motion for summary judgment. The case was formally closed on May 15, 2025. The dismissal notice expressly states ‘without prejudice,’ meaning Zhang retains the legal right to reassert these infringement claims against Gekufa in a future action, subject to applicable statutes of limitations.
The 397-day duration from filing to dismissal is consistent with Schedule A enforcement patterns in which plaintiffs pursue temporary restraining orders, asset freezes, and potential settlements before formally closing cases against individual defendants. The public record does not disclose whether a settlement or licensing agreement was reached between Zhang and Gekufa prior to dismissal, and no defendant counsel of record appears, suggesting Gekufa may not have formally appeared in the action. What drove the decision to dismiss at this stage — whether settlement, inability to serve, or strategic withdrawal — cannot be confirmed from the available docket.
Filing to Voluntary dismissal in 397 days
397 days from filing to voluntary dismissal — consistent with Schedule A enforcement campaigns that resolve pre-answer
Voluntarily dismissed: what the Rule 41 notice means for both parties
Rule 41(a)(1)(A)(i) dismissal: plaintiff acts unilaterally
Fed. R. Civ. P. 41(a)(1)(A)(i) allows a plaintiff to dismiss a defendant without a court order, provided the defendant has not yet served an answer or summary judgment motion. This is a purely procedural exit — the court makes no findings on the merits of the infringement claims. The dismissal notice expressly states ‘without prejudice,’ preserving Zhang’s right to refile.
No merits rulingWithout prejudice confirmed — but the underlying reason is unknown
A voluntary dismissal without prejudice means the plaintiff is not barred from refiling the same claims against the same defendant. A dismissal with prejudice would permanently extinguish the claims. The plaintiff’s Rule 41 notice in this case explicitly states ‘without prejudice.’ However, the public docket is silent on whether a confidential settlement, licensing arrangement, or other consideration accompanied the dismissal.
Refiling rights preservedGekufa exits without a liability finding — but exposure persists
Gekufa faces no injunction, damages award, or infringement finding as a result of this dismissal. However, because the dismissal is without prejudice, the patent holder could reassert US11060269B2 against Gekufa in a new action. If Gekufa continues to sell the accused ASIN or similar products, renewed enforcement risk remains. No defendant counsel appeared, which is consistent with a default-risk posture common in Schedule A matters.
No liability — risk persistsSchedule A patent campaigns: strategic withdrawal is common, not conclusive
Schedule A enforcement actions against Amazon sellers often resolve through platform-level asset freezes and quiet settlements rather than full adjudication. A voluntary dismissal without prejudice, particularly against a single defendant from a larger Schedule A list, typically signals either a reached accommodation or an inability to proceed against that specific seller. US11060269B2 remains in force and can be asserted against other marketplace sellers of competing sink bracket products.
Patent remains enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Mingsen Zhang | Individual | Patent holder asserting sink bracket mounting hardware IP — holder of US11060269B2Search in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Gekufa: Amazon marketplace seller of sink installation brackets (ASIN B0BRCWGYJD)Search in Eureka ↗ |
| Plaintiff counsel | Lance Y. Liu | Attorney | Counsel for Mingsen ZhangSearch in Eureka ↗ |
| Plaintiff law firm | Lance Liu | Law Firm | Representing Mingsen ZhangSearch in Eureka ↗ |
| Presiding judge | Judge Andrea R. Wood | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) and names Gekufa specifically by Amazon Store ID and ASIN, indicating targeted rather than blanket resolution. The express ‘without prejudice’ language is legally significant: it forecloses any res judicata or claim preclusion defense by Gekufa in a future proceeding. The court made no merits determination. The specificity of the notice — naming the store owner’s email — is consistent with plaintiff having identified and potentially contacted the responsible party prior to filing the dismissal.
US11060269B2 — Bracket for Installing Sink
US11060269B2 is a utility patent covering a bracket designed for installing sinks, filed under application number US16/525597. Patents in this category typically protect the mechanical configuration, fastening mechanisms, or installation method that enables secure sink mounting — functional innovations in home improvement hardware. The patent is asserted by individual inventor Mingsen Zhang, suggesting an individual inventor or small entity origin, which is common in the consumer hardware space where product-specific utility patents are used to protect differentiated installation solutions sold through e-commerce channels.
From a competitive intelligence perspective, a granted utility patent on sink installation brackets represents a meaningful enforcement asset in the Amazon marketplace, where numerous sellers offer functionally similar mounting hardware. The patent holder’s choice to pursue Schedule A litigation — targeting multiple sellers simultaneously — suggests active commercial exploitation of the IP and awareness of widespread alleged copying. For hardware importers, distributors, and private-label Amazon sellers in the sink mounting category, this patent warrants FTO review, particularly given the without-prejudice dismissal leaving the door open for renewed enforcement.
Should your product team run an FTO against US11060269B2?
Any company designing, importing, or selling sink installation brackets — particularly through Amazon or other online marketplaces — should assess freedom to operate against US11060269B2. The patent holder has demonstrated willingness to litigate in the Northern District of Illinois, a court known for efficient Schedule A proceedings and ex parte asset freeze orders. Products with similar bracket configurations, attachment mechanisms, or installation methods to those claimed in this patent carry non-trivial infringement risk, even if sold under different brand names or ASINs.
PatSnap Eureka’s FTO Search Agent can map the claims of US11060269B2 against your product specifications, flag overlap with the asserted claims, and surface relevant prior art that may support design-around or invalidity arguments. Eureka also enables monitoring of new filings by Mingsen Zhang or related entities, so your team receives early warning if enforcement activity expands to additional defendants or related patents in the sink hardware category.
Run a freedom-to-operate analysis on US11060269B2 to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A patent cases: sink & home hardware on Amazon
Explore comparable utility patent infringement actions filed in the Northern District of Illinois against Amazon marketplace sellers of home installation and mounting hardware.
What this case signals for the home hardware e-commerce IP landscape
Schedule A enforcement of hardware utility patents on Amazon is increasing. This case illustrates both the leverage and the limits of that strategy.
Rule 41 exits are common in Schedule A actions — read the docket pattern
Voluntary dismissals without prejudice against individual Schedule A defendants are a routine feature of multi-seller enforcement campaigns. They rarely signal patent weakness. More commonly, they reflect confidential resolution or a shift in enforcement priority. IP teams monitoring competitors should track the full Schedule A list, not just cases that reach judgment.
US11060269B2 remains active and enforceable against new sellers
The dismissal of Gekufa does not affect the validity or enforceability of the underlying sink bracket patent. Any Amazon or e-commerce seller offering competing sink mounting bracket products should treat this patent as a live enforcement risk. The patent holder’s willingness to file and maintain a multi-defendant action signals active monitoring of the marketplace.
Zhang v Partnerships — key questions answered
Voluntary dismissal without prejudice under Rule 41(a)(1)(A)(i) means the plaintiff chose to end the case against Gekufa without a court ruling on the merits. Gekufa faces no infringement finding or damages award. Critically, Zhang retains the right to refile the same claims against Gekufa in a future action — the dismissal does not permanently bar reassertion of US11060269B2 against this defendant.
The asserted patent is US11060269B2, filed under application number US16/525597. It covers a bracket for installing sinks — a utility patent in the home hardware and mounting category. The accused product was sold by Gekufa on Amazon under ASIN B0BRCWGYJD. The patent remains in force and has not been invalidated by this litigation.
The Northern District of Illinois is a preferred venue for Schedule A patent enforcement actions targeting e-commerce sellers. It has an established procedural framework for granting ex parte TROs and asset freezes against anonymous or overseas Amazon sellers, making it strategically attractive for plaintiffs pursuing online marketplace infringement at scale.
The Rule 41(a)(1)(A)(i) dismissal notice is specific to Gekufa (defendant #3 on Schedule A). It has no direct legal effect on any other defendants named in the Schedule A list. Other defendants remain subject to the original complaint unless separately dismissed or resolved. The public record does not indicate the status of other Schedule A defendants in this case.
Yes. Because the dismissal was expressly without prejudice, Zhang is not barred from refiling patent infringement claims based on US11060269B2 against Gekufa. However, a second voluntary dismissal of the same claim against the same defendant would operate as a dismissal with prejudice under the ‘two-dismissal rule’ of Rule 41(a)(1)(B). Applicable statutes of limitations would also constrain the timing of any refiling.
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