Shenzhen Century Rainbow v. Schedule A Defendants: Foot File Design Patent Dispute
Shenzhen Century Rainbow Ind. Co., Ltd. filed suit in the Northern District of Illinois asserting design patent USD988602S covering a foot file product against a group of anonymous online marketplace sellers. The case resolved in 242 days through voluntary dismissal consistent with a settlement, with each party bearing its own fees and costs.
Design patent enforcement against anonymous e-commerce sellers
On December 13, 2024, Shenzhen Century Rainbow Ind. Co., Ltd., a Chinese consumer-goods manufacturer, filed an infringement action in the U.S. District Court for the Northern District of Illinois before Judge Manish S. Shah. The plaintiff asserted design patent USD988602S (application no. US29/842652), which covers the ornamental design of a foot file, against an undisclosed group of online marketplace sellers collectively identified as ‘The Partnerships and Unincorporated Associations in Schedule A.’
The case closed on August 12, 2025, via voluntary dismissal. The dismissal notice explicitly states that the plaintiff and the named defendant reached a settlement and that each party is to bear its own fees, costs, and expenses. Because the notice does not specify whether the dismissal is with or without prejudice, the public record is silent on that point — a distinction that carries material consequences for potential future enforcement against the same sellers.
The 242-day duration is consistent with Schedule A enforcement campaigns, where early TRO-based asset freezes on marketplace accounts often accelerate settlement negotiations. What drove the specific settlement terms — including any licensing arrangement, damages payment, or delisting agreement — is not disclosed in the public docket. The silent-prejudice dismissal leaves open the theoretical possibility of re-filing, though that inference should be treated cautiously absent further docket activity.
Filing to Voluntary dismissal in 242 days
242-day lifespan — typical for Schedule A e-commerce enforcement actions that settle early
Voluntarily dismissed: what the settlement exit means for both sides
Voluntary dismissal signals a negotiated exit, not a merits ruling
A voluntary dismissal under FRCP 41 ends the case without any court adjudication of infringement, validity, or damages. Here, the dismissal notice expressly ties the exit to a settlement agreement, meaning the parties resolved the dispute privately. Because the notice does not specify ‘with prejudice’ or ‘without prejudice,’ the default rule under FRCP 41(a)(1)(B) may apply, but practitioners should verify whether a stipulation or court order governs.
No merits adjudicationPublic record is silent on whether dismissal is with or without prejudice
A dismissal with prejudice permanently bars the plaintiff from re-filing the same claims against the same defendants. A dismissal without prejudice preserves that right. The docket notice here omits any prejudice designation, which creates ambiguity. This distinction matters for defendants assessing ongoing risk and for plaintiff’s future enforcement strategy. Practitioners monitoring this patent should check for any subsequent court order that may clarify the terms.
Prejudice status unclearEach party bears its own costs — no fee-shifting order issued
The settlement terms expressly provide that each party bears its own fees, costs, and expenses. This means the court did not award attorneys’ fees under 35 U.S.C. § 285 (exceptional case) or costs under 28 U.S.C. § 1920. For Schedule A defendants who commonly operate at low margins, avoiding a fee-shifting award is commercially significant. For the plaintiff, it suggests neither party sought to litigate the dispute to an exceptional-case finding.
No fee-shiftingSchedule A TRO tactics typically accelerate settlement in e-commerce design cases
Schedule A design patent cases in the Northern District of Illinois commonly pair an ex parte TRO with marketplace account freezes — a procedural posture that creates immediate commercial pressure on defendants selling through platforms such as Amazon or Alibaba. This structural leverage frequently produces early settlements without full merits litigation. The 242-day resolution of this case is consistent with that enforcement pattern, though the specific leverage points here are not confirmed by the public record.
TRO-driven settlement patternFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Shenzhen Century Rainbow Ind. Co., Ltd. | Company | Consumer goods manufacturer — holder of design patent USD988602S for a foot fileSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations in Schedule A | Individual | Anonymous online marketplace sellers identified collectively in Schedule A to the complaintSearch in Eureka ↗ |
| Plaintiff counsel | Robert Michael Dewitty | Attorney | Counsel for Shenzhen Century Rainbow Ind. Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Dewitty And Associates, Chtd. | Law Firm | Representing Shenzhen Century Rainbow Ind. Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Manish S. Shah | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes FRCP 4(a)(1)(A)(i) and states that plaintiff and defendant ‘have reached Settlement,’ with plaintiff voluntarily dismissing and each party bearing its own fees and costs. The language confirms a negotiated exit but does not adjudicate infringement or patent validity. Critically, no prejudice designation appears in the notice, leaving the scope of claim preclusion legally ambiguous on the face of the public record.
USD988602S — Ornamental design for a foot file
USD988602S (application no. US29/842652) is a U.S. design patent protecting the ornamental appearance of a foot file — a personal care tool used for removing calluses and dry skin. Design patents cover only the visual characteristics of a product, not its functional features, and confer a 15-year term from grant. The asserted patent suggests Shenzhen Century Rainbow has invested in protecting the specific aesthetic presentation of its foot file product in the U.S. market, consistent with a brand-differentiation strategy targeting the competitive online consumer goods space.
The foot file market is heavily commoditised on e-commerce platforms, with numerous sellers offering visually similar products at low price points. In that environment, a registered design patent gives the holder a meaningful competitive tool: it enables Schedule A enforcement campaigns that can target large numbers of sellers simultaneously, creating settlement leverage without requiring individual identification of infringers prior to filing. Because USD988602S has not been tested on validity or infringement in contested proceedings, its scope and enforceability relative to prior art designs remains formally unresolved — a factor material to any FTO assessment.
Should you run an FTO check against USD988602S?
Any company designing, sourcing, or listing a foot file — or a visually similar personal care grooming tool — for sale in the U.S. market, particularly through online marketplaces, should treat USD988602S as a live enforcement risk. Shenzhen Century Rainbow has demonstrated willingness to pursue Schedule A litigation in the Northern District of Illinois, a venue experienced in granting ex parte TROs that freeze seller accounts. A proactive FTO review is far less costly than defending a TRO application.
PatSnap Eureka’s FTO Search Agent lets R&D and product teams run structured freedom-to-operate searches across active U.S. design patent portfolios in the personal care tools category. You can identify visually proximate design registrations, assess claim scope relative to your product’s ornamental features, and flag enforcement-active patent holders — all before a product hits a marketplace listing. Start with USD988602S and map the surrounding design patent landscape in foot care.
Run a freedom-to-operate analysis on USD0988602S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in the Northern District of Illinois
Explore comparable design patent infringement actions against anonymous marketplace sellers filed in the Northern District of Illinois involving consumer goods and personal care products.
What this case signals for design patent enforcement in e-commerce
Schedule A design patent campaigns in Illinois continue to resolve swiftly. Here is what this case means for IP teams and product companies.
Design patents remain potent tools against marketplace infringers
USD988602S enabled Shenzhen Century Rainbow to pursue anonymous online sellers collectively via a single docket, leveraging the Northern District of Illinois’s well-established Schedule A procedural framework. Companies holding registered design patents in consumer goods categories should consider whether this enforcement channel aligns with their IP strategy.
Anonymous seller defendants face real commercial risk from asset-freeze TROs
Schedule A cases routinely seek ex parte temporary restraining orders that freeze marketplace accounts and PayPal balances before defendants are even served. Sellers operating across platforms such as Amazon, Etsy, or eBay should monitor design patent registrations in their product categories and conduct FTO checks before listing — particularly for high-volume consumer products like personal care tools.
Shenzhen v Partnerships — key questions answered
The case was voluntarily dismissed on August 12, 2025, following a reported settlement between plaintiff Shenzhen Century Rainbow Ind. Co., Ltd. and the named Schedule A defendants. Each party agreed to bear its own fees, costs, and expenses. No prejudice designation was specified in the dismissal notice, leaving that question open on the public record.
The plaintiff asserted U.S. design patent USD988602S (application no. US29/842652), which protects the ornamental design of a foot file. Design patents cover only the visual appearance of a product, not its functionality, and carry a 15-year term from the date of grant under current U.S. patent law.
The dismissal notice does not specify whether the dismissal is with or without prejudice. A with-prejudice dismissal would permanently bar re-filing the same claims against the same defendants; a without-prejudice dismissal would preserve that right. Under FRCP 41, the default in certain scenarios may apply, but parties and practitioners should review the full docket for any clarifying court order or stipulation.
Schedule A cases allow a plaintiff to sue a large number of anonymous online marketplace sellers as a group using a single complaint with defendants listed in a sealed schedule. This procedural device is common in the Northern District of Illinois for design and trademark enforcement. Plaintiffs typically seek ex parte temporary restraining orders to freeze defendants’ marketplace accounts and financial assets before service of process.
No. The voluntary dismissal reflects a negotiated settlement and carries no merits determination on infringement or patent validity. USD988602S remains a fully enforceable, unchallenged U.S. design patent. Companies selling foot files or visually similar personal care products in the U.S. should treat this patent as a live enforcement risk and conduct freedom-to-operate analysis accordingly.
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