Quan Ren v. Schedule A Defendants: Watch Case Design Patent Action Ends in 32 Days
Plaintiff Quan Ren filed suit in the Northern District of Illinois asserting design patent USD1043405S covering a protective case for a watch against a broad set of anonymous online marketplace defendants. The action was voluntarily dismissed without prejudice just 32 days after filing, before any defendant filed an answer or motion for summary judgment.
Design patent assertion over watch accessory resolves before any defense filed
On August 15, 2025, plaintiff Quan Ren, represented by Whitewood Law PLLC, filed a patent infringement action in the U.S. District Court for the Northern District of Illinois (Case No. 1:25-cv-09772) before Judge Jeffrey I. Cummings. The asserted patent is USD1043405S (application no. US29/855105), a U.S. design patent covering the ornamental appearance of a protective case for a watch. The defendant class followed the common ‘Schedule A’ pleading structure used in e-commerce enforcement actions, targeting multiple anonymous online sellers in a single complaint.
The case closed on September 16, 2025 — just 32 days after filing — when Quan Ren filed a voluntary notice of dismissal pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure. The filing confirmed that no defendant had filed an answer or a motion for summary judgment, making unilateral plaintiff dismissal procedurally available without court approval. Each party was ordered to bear its own attorney’s fees and costs. No merits ruling of any kind was issued.
A 32-day lifespan is notably brief even by the standards of Schedule A design patent campaigns, which often resolve through early TROs, asset freezes, or rapid settlements. The public record is silent on whether any settlement, licensing payment, or platform-level resolution occurred prior to dismissal. The without-prejudice dismissal preserves Quan Ren’s right to refile, and the absence of any defendant appearance suggests defendants may have been unresponsive, settled informally, or the plaintiff chose to redirect enforcement strategy.
Filing to Voluntary dismissal in 32 days
32 days — well below the median district court patent case duration, suggesting early resolution without merits adjudication
Voluntarily dismissed: what the Rule 41 exit means for both sides
Rule 41(a)(1)(A)(i) allows plaintiff to exit before any defense is filed
Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure permits a plaintiff to dismiss an action without court order, provided the defendant has not yet served an answer or a motion for summary judgment. Because no Schedule A defendant took either step here, Quan Ren retained the unilateral right to exit. The dismissal takes effect immediately upon filing the notice — no judicial approval is required.
Procedural exit — no merits rulingPublic record is silent on whether dismissal was with or without prejudice
Rule 41(a)(1)(A)(i) dismissals are without prejudice by default unless the notice expressly states otherwise, or the plaintiff has previously dismissed the same claim. The verdict text references a without-prejudice dismissal, meaning Quan Ren retains the right to refile the same infringement claims against the same or different defendants based on USD1043405S. However, the specific commercial terms — if any — driving the dismissal are not disclosed in the public docket.
Refiling right preservedDefendants exit without liability finding — but face potential refiling risk
Because the dismissal is without prejudice, defendants obtain no preclusive benefit. There is no ruling on validity, infringement, or damages. No defendant appeared in the case, which is consistent with the Schedule A model where sellers are often unaware of proceedings or unable to mount a defence. The absence of a with-prejudice dismissal or consent judgment means the threat of future enforcement under USD1043405S remains live.
No preclusion for defendantsWatch accessory IP enforcement via Schedule A remains viable — and repeatable
Schedule A design patent cases against e-commerce defendants are a common enforcement vehicle in the Northern District of Illinois. A without-prejudice voluntary dismissal does not signal weakness in the patent itself — the ornamental validity of USD1043405S remains untested. Online sellers of watch protective cases operating across marketplace platforms should note that the underlying patent is unresolved and the plaintiff retains full enforcement rights.
USD1043405S remains enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Quan Ren | Individual | Individual patent holder — asserting ornamental design patent USD1043405S for a watch protective caseSearch in Eureka ↗ |
| Defendant | The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online marketplace sellers identified on Schedule A — unnamed at filingSearch 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 ↗ |
| Plaintiff law firm | Whitewood Law Pllc | Law Firm | Representing Quan RenSearch in Eureka ↗ |
| Presiding judge | Judge Jeffrey I Cummings | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice expressly invokes Rule 41(a)(1)(A)(i), confirming the procedural predicate — no defendant answer or summary judgment motion on file — was satisfied. The ‘without prejudice’ characterisation preserves plaintiff’s full refiling rights. The fee-neutrality clause (each party bears its own costs) is standard for Rule 41(a)(1)(A)(i) exits and does not imply any concession by either side. No merits findings on infringement, validity, or damages attach to this termination.
USD1043405S — Ornamental design for a protective case for a watch
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 the visual, non-functional characteristics of a product — meaning any seller whose watch case product is substantially similar in overall ornamental impression to the patented design may face infringement exposure, regardless of functional differences. The application number prefix ’29/’ confirms this is a design patent filed under 35 U.S.C. § 171.
Watch protective cases are a high-volume, low-margin category dominated by third-party sellers on global e-commerce platforms, making them a recurring target for design patent enforcement campaigns. A single design patent in this category can be deployed against hundreds of SKUs simultaneously via the Schedule A structure. Because USD1043405S has not been adjudicated on validity or infringement, its enforceability is untested — but undiminished. Competitors and marketplace sellers should assess ornamental similarity to this design before listing new watch case products in the U.S. market.
Should your watch case product be cleared against USD1043405S?
Any manufacturer, importer, or online seller of protective cases for watches targeting the U.S. market should consider a freedom-to-operate review against USD1043405S. Because this is a design patent, the infringement test is the ‘ordinary observer’ standard — whether an ordinary purchaser would mistake the accused product for the patented design. This is a visual comparison, not a functional one, and can catch products that differ in materials or mechanisms but share a similar ornamental profile.
PatSnap Eureka’s FTO Search Agent can identify USD1043405S and related design filings in the US29/855105 family, flag visually similar granted designs, and surface prior art that could support an invalidity argument if enforcement resumes. R&D and product teams planning new watch accessory SKUs can run a design clearance workflow directly in Eureka, generating a structured FTO summary without manual patent-by-patent review.
Run a freedom-to-operate analysis on USD1043405S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois
Cases involving ornamental design patents asserted against Schedule A e-commerce defendants in the Northern District of Illinois follow consistent procedural patterns.
What this case signals for the watch accessories IP enforcement landscape
Schedule A design patent filings in N.D. Illinois are a high-volume, fast-cycle enforcement tool. This case illustrates both the speed and opacity of that model.
Early voluntary dismissal does not neutralise the underlying patent
USD1043405S remains valid and unlitigated on the merits. Sellers of watch protective cases on Amazon, Alibaba, or Temu-adjacent platforms should treat this dismissal as a pause, not a clearance. The plaintiff retains the right to refile against the same or new defendants at any time within the applicable limitations period.
Schedule A campaign economics favour rapid settlement or exit
The 32-day duration is consistent with cases where defendants are unresponsive, a TRO was declined, or early off-docket resolution occurred. No asset freeze or injunctive relief appears in the public record. IP teams monitoring competitor enforcement patterns should watch for refiling activity tied to USD1043405S in the months following dismissal.
Ren v Individuals — key questions answered
USD1043405S (application no. US29/855105) is a U.S. design patent covering the ornamental appearance of a protective case for a watch. In Case No. 1:25-cv-09772, Quan Ren asserted this patent against anonymous e-commerce sellers in the Northern District of Illinois. The case was voluntarily dismissed without prejudice after 32 days before any defendant appeared.
A Rule 41(a)(1)(A)(i) dismissal without prejudice means the plaintiff voluntarily ended the case before any defendant filed an answer or summary judgment motion. Defendants receive no preclusive benefit — there is no ruling on infringement or validity. The plaintiff retains the right to refile the same claims in the future. Defendants are not absolved of potential future liability under the same patent.
No. The dismissal notice expressly states that no defendant filed an answer or a motion for summary judgment. This is the procedural prerequisite for a unilateral Rule 41(a)(1)(A)(i) dismissal. The absence of any defendant appearance is consistent with the Schedule A enforcement model, where defendants are often unnamed marketplace sellers who may be unaware of the proceedings.
Quan Ren was represented by Whitewood Law PLLC. The counsel team included Abby Marie Neu, Keaton David Smith, Michael Mitchell, Ryan Evan Carreon, and Shengmao Mu. Whitewood Law PLLC is an active filer in Schedule A e-commerce patent enforcement actions, particularly in the Northern District of Illinois.
Yes. Because the dismissal was entered without prejudice under Rule 41(a)(1)(A)(i), Quan Ren retains the right to refile infringement claims based on USD1043405S against the same or different defendants, subject to applicable statutes of limitations. No settlement, consent judgment, or with-prejudice order was entered that would restrict refiling. The patent itself remains valid and unlitigated on the merits.
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