Quan Ren v. Schedule A Defendants: Watch Case Design Patent Dismissed in 55 Days
Plaintiff Quan Ren asserted design patent USD1043405S — covering a protective case for a watch — against a set of anonymous online sellers before Judge LaShonda A. Hunt in the Northern District of Illinois. The sole remaining defendant, seller alias AilunUS 1, was voluntarily dismissed without prejudice after just 55 days, with each party bearing its own costs.
A Swift Schedule A Exit: Design Patent Dropped Before Answer Filed
On August 5, 2025, Quan Ren filed a design patent infringement action in the U.S. District Court for the Northern District of Illinois (Case No. 1:25-cv-09278), asserting USD1043405S — a design patent covering the ornamental appearance of a protective case for a watch — against a group of anonymous defendants identified on Schedule A, a structure commonly used in e-commerce enforcement actions targeting marketplace sellers.
The case closed on September 29, 2025, following a voluntary dismissal filed under Federal Rule of Civil Procedure 41(a)(1)(A)(i). The dismissal targeted the sole remaining defendant, identified by the seller alias DOE No. AilunUS 1. Because the defendant had not filed an answer or a motion for summary judgment, Rule 41(a)(1)(A)(i) permitted unilateral dismissal by the plaintiff without court order. The dismissal was entered without prejudice, meaning the claims could theoretically be refiled.
A 55-day lifecycle is notably short, suggesting the matter may have resolved through an out-of-court agreement, a decision not to pursue the specific defendant, or strategic case management. The public record does not disclose whether any settlement or licensing arrangement was reached. The without-prejudice designation preserves the plaintiff’s ability to reassert claims, though the absence of any cost award leaves both parties in a neutral financial position.
Filing to Voluntary dismissal in 55 days
55 days — resolved well below the median Schedule A enforcement timeline
Voluntarily dismissed: what the Rule 41 exit means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral exit right
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order at any time before the defendant serves an answer or a motion for summary judgment. Because AilunUS 1 had not filed either, Quan Ren was entitled to dismiss as of right. No judicial approval was required, making this one of the most procedurally straightforward exits available in U.S. federal litigation.
No court order requiredWithout prejudice: the public record is silent on finality
The dismissal was entered without prejudice, meaning no final adjudication was made on the merits of the design patent infringement claims. This preserves the plaintiff’s theoretical right to refile. However, the public docket does not disclose whether a private settlement or licensing agreement underpins the dismissal. Practitioners should not assume a clean resolution — the underlying dispute may or may not be fully resolved.
Refiling remains possibleAilunUS 1 exits with no judgment and no admitted liability
The named defendant exits the case without a finding of infringement, no injunction, and no damages award. Because no answer was ever filed, the defendant incurred minimal visible litigation costs. The without-prejudice dismissal, however, means the design patent remains valid and enforceable — the defendant cannot treat this outcome as a cleared path to continued sale of the accused product.
No liability findingDesign patent remains live; enforcement posture unchanged
USD1043405S is not invalidated or narrowed by this outcome. For other marketplace sellers offering protective watch cases with a similar ornamental design, the patent’s enforceability is unaffected. Schedule A enforcement campaigns frequently involve staged dismissals — this exit of a single alias seller is consistent with ongoing or future enforcement activity against other defendants in the same or related actions.
Patent fully enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Quan Ren | Individual | Design patent holder asserting ornamental rights in a protective watch caseSearch in Eureka ↗ |
| Defendant | The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A | Individual | Anonymous e-commerce seller operating under the alias AilunUS 1 on an online marketplaceSearch in Eureka ↗ |
| Plaintiff counsel | Abby Marie Neu | Attorney | Counsel for Quan RenSearch in Eureka ↗ |
| Plaintiff counsel | Keaton David Smith | Attorney | Counsel for Quan RenSearch in Eureka ↗ |
| Plaintiff counsel | Michael Mitchell | Attorney | Counsel for Quan RenSearch in Eureka ↗ |
| Plaintiff counsel | Ryan Evan Carreon | Attorney | Counsel for Quan RenSearch in Eureka ↗ |
| Plaintiff counsel | Shengmao Mu | Attorney | Counsel for Quan RenSearch in Eureka ↗ |
| Plaintiff law firm | Whitewood Law, PLLC | Law Firm | Representing Quan RenSearch in Eureka ↗ |
| Presiding judge | Judge LaShonda A. Hunt | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) precisely because the defendant never appeared — a procedural posture that makes unilateral exit both available and unreviewable. The without-prejudice designation is standard in this circumstance; it preserves optionality for the plaintiff without conferring any benefit on the defendant. The explicit statement that ‘no defendants remain in the case’ closes the docket entirely, but does not extinguish the asserted patent rights or preclude future enforcement actions.
USD1043405S — Ornamental Design for a Protective Watch Case
USD1043405S is a U.S. design patent — application number US29/855105 — protecting the ornamental appearance of a protective case for a watch. Design patents cover only the visual, non-functional characteristics of a product as depicted in the patent’s drawings; the scope of protection is defined by those figures alone. Design patents in consumer accessories are frequently asserted in Schedule A e-commerce enforcement actions because visual similarity to product listing images can be documented quickly and at scale.
In the competitive marketplace for watch accessories — particularly aftermarket protective cases sold through platforms such as Amazon — design patents serve as a primary enforcement tool. A single design patent can anchor claims against dozens of sellers offering visually similar products. For brands and manufacturers in the watch accessories category, USD1043405S represents an active enforcement risk that is unaffected by this case’s dismissal. Competitors should assess their product aesthetics against the patent figures before entering or expanding in this product segment.
Should you run an FTO against USD1043405S before selling a watch protective case?
Any company manufacturing, importing, or listing for sale a protective case for a watch on e-commerce platforms should treat USD1043405S as a live clearance risk. Design patent infringement is assessed by the ‘ordinary observer’ test — a relatively low threshold that does not require identical copying. A product that creates the same overall visual impression as the patented design may infringe, even without intent. The Northern District of Illinois’s receptivity to Schedule A complaints makes this a credible enforcement venue.
PatSnap Eureka’s FTO Search Agent allows product and IP teams to map a candidate product’s visual design against USD1043405S and related design patent families in minutes. By surfacing the patent’s figures, application history, and related filings — including any continuations off US29/855105 — Eureka helps teams identify design-around opportunities and flag clearance gaps before a product goes to market or a new marketplace listing goes live.
Run a freedom-to-operate analysis on USD1043405S to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A Design Patent Cases in the Northern District of Illinois
Explore comparable Schedule A design patent enforcement actions involving consumer accessory products filed in the Northern District of Illinois before Judge Hunt or related judges.
What this case signals for the consumer accessories IP enforcement landscape
A 55-day Schedule A lifecycle and a without-prejudice exit carry specific signals for marketplace sellers and design patent holders in the watch accessories space.
Schedule A tactics remain active in N.D. Illinois consumer goods enforcement
The Northern District of Illinois continues to be a preferred venue for Schedule A design patent actions targeting e-commerce sellers. A rapid voluntary dismissal — before any answer is filed — is consistent with a demand-and-settle playbook. Sellers operating in consumer accessory categories should treat receipt of a Schedule A complaint as requiring immediate legal response, even absent a court order.
Without-prejudice exit does not clear the product for continued sale
Defendants and their counsel should note that a Rule 41(a)(1)(A)(i) without-prejudice dismissal leaves the underlying design patent fully intact and enforceable. A dismissed defendant who resumes selling an accused product does so at risk of a refiled action, potentially in a less favourable procedural posture if circumstances change.
Ren v Individuals — key questions answered
The dismissal without prejudice means no final judgment was entered on the merits of the design patent infringement claims. Quan Ren retains the right to refile claims against AilunUS 1 or other defendants in the future. It does not mean the defendant was cleared of infringement or that the patent was found invalid.
The patent asserted was USD1043405S (application number US29/855105), a U.S. design patent covering the ornamental appearance of a protective case for a watch. Design patents protect visual characteristics only and are defined entirely by the figures in the patent document.
Rule 41(a)(1)(A)(i) allows a plaintiff to dismiss an action as of right — without a court order — before the defendant has served an answer or a motion for summary judgment. In this case, the defendant AilunUS 1 had not filed either, so Quan Ren could dismiss unilaterally. The court was not required to approve the dismissal.
Yes. A voluntary dismissal without prejudice does not invalidate or narrow the asserted design patent. USD1043405S remains fully enforceable against any party selling a product that infringes its ornamental scope. Sellers in the watch protective case category cannot rely on this dismissal as evidence that the patent is unenforceable.
Schedule A cases are a common enforcement structure in N.D. Illinois where a plaintiff files against a group of anonymous defendants — typically e-commerce marketplace sellers — identified only by seller aliases or store names on a schedule attached to the complaint. The structure allows plaintiffs to seek emergency relief against multiple sellers simultaneously before defendants can transfer assets or delete listings.
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