Shenzhen Kaianhao v. Waters Industries: Lighted Headgear Patent Dismissed With Prejudice
Shenzhen Kaianhao Technology Co., Ltd. filed suit against Waters Industries, Inc. in the Northern District of Illinois asserting infringement of US11478035B2, a patent covering lighted headgear and accessories. The parties jointly dismissed the case with prejudice after 311 days, each bearing its own costs — a resolution that permanently closes the courthouse door on these claims.
A joint exit after 311 days: lighted headgear IP dispute ends permanently
Shenzhen Kaianhao Technology Co., Ltd., a Chinese technology manufacturer, filed this patent infringement action against Waters Industries, Inc. in the Northern District of Illinois on 22 October 2024. The case centred on US11478035B2, which covers lighted headgear and accessories therefor — a product category that encompasses illuminated hats, caps, and related wearable lighting goods. The case was assigned to Judge Jorge L. Alonso. Kaianhao was represented by Glacier Law LLP, while Waters Industries retained Funkhouser Vegosen Liebman & Dunn, Ltd.
The case closed on 29 August 2025, 311 days after filing, by way of a joint stipulation of dismissal with prejudice filed pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii). Both parties signed and filed the stipulation, and each agreed to bear its own costs and fees. Dismissal with prejudice under Rule 41 is a final adjudication on the merits — Kaianhao is permanently barred from reasserting the same claims against Waters Industries based on the same patent and accused conduct.
A resolution at 311 days, before any reported trial proceedings, is consistent with a negotiated settlement or commercial resolution reached after discovery or claim-construction activity — though the public record discloses no financial terms. The mutual cost-bearing provision suggests neither side extracted a dominant position, or that any commercial arrangement was handled privately. What drove the parties to a permanent exit rather than a without-prejudice dismissal remains undisclosed, though with-prejudice terms typically reflect a concluded business negotiation or a cross-licensing arrangement.
Filing to Case Dismissed in 311 days
311 days — above the median for N.D. Illinois patent cases resolved before trial
Dismissed with prejudice: what the joint stipulation means for both parties
Rule 41(a)(1)(A)(ii): a final, court-endorsed exit
A joint stipulation under Fed. R. Civ. P. 41(a)(1)(A)(ii) allows both parties to dismiss a case without a court order, provided both sides sign. The ‘with prejudice’ designation converts the dismissal into a final judgment on the merits — functionally equivalent to a ruling against the plaintiff. Kaianhao cannot refile this infringement claim against Waters Industries on the same patent and accused products in any U.S. federal court.
Permanent bar on refilingKaianhao exits permanently — typically signals a deal was reached
Agreeing to a with-prejudice dismissal is a significant concession by a plaintiff: it surrenders all future litigation leverage over the same claims. Patent holders rarely accept this outcome without receiving something in return — most commonly a license, royalty arrangement, or commercial agreement. The public record is silent on any financial terms. The mutual cost-bearing clause, however, suggests Kaianhao did not extract an attorneys’ fee award, which would typically follow an exceptional-case finding.
No public financial termsWaters Industries secures permanent closure of this IP threat
Waters Industries obtains what defendants most value: certainty. The with-prejudice dismissal means Kaianhao cannot resurrect this specific infringement action. However, the patent US11478035B2 itself remains in force — Waters would face exposure again if it were to expand into new product configurations arguably covered by the patent’s claims, or if Kaianhao were to assert the patent against different conduct. The cost-neutral terms suggest Waters also avoided a fee-shifting motion.
Patent remains live and enforceableUS11478035B2 stays active: risk persists for the lighted headgear market
The dismissal resolves only this bilateral dispute. US11478035B2 is still an active, enforceable patent — Kaianhao retains full rights to assert it against other parties in the lighted headgear and illuminated accessories space. Competitors or distributors operating in this product category should treat this case as a signal that Kaianhao is willing to litigate. The 311-day dispute lifecycle also suggests the parties engaged substantively before reaching resolution, which may indicate the patent withstood early validity scrutiny.
Active patent; third-party risk remainsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Shenzhen Kaianhao Technology Co., Ltd | Company | Chinese consumer electronics and wearables manufacturer — holder of US11478035B2Search in Eureka ↗ |
| Defendant | Waters Industries, Inc | Company | Waters Industries, Inc. — U.S. distributor or manufacturer of lighted headgear productsSearch in Eureka ↗ |
| Plaintiff counsel | Tao Liu | Attorney | Counsel for Shenzhen Kaianhao Technology Co., LtdSearch in Eureka ↗ |
| Plaintiff counsel | Wei Wang | Attorney | Counsel for Shenzhen Kaianhao Technology Co., LtdSearch in Eureka ↗ |
| Plaintiff law firm | Glacier Law LLP | Law Firm | Representing Shenzhen Kaianhao Technology Co., LtdSearch in Eureka ↗ |
| Defendant counsel | Glenn Rice | Attorney | Counsel for Waters Industries, IncSearch in Eureka ↗ |
| Defendant counsel | Vance L. Liebman | Attorney | Counsel for Waters Industries, IncSearch in Eureka ↗ |
| Defendant law firm | Funkhouser Vegosen Liebman & Dunn, Ltd. | Law Firm | Representing Waters Industries, IncSearch in Eureka ↗ |
| Presiding judge | Judge Jorge L. Alonso | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The joint stipulation is precise and unambiguous: both parties invoked Rule 41(a)(1)(A)(ii), designated the dismissal as with prejudice, and agreed to mutual cost-bearing. The ‘with prejudice’ language is the critical operative term — it extinguishes Kaianhao’s right to refile these specific claims against Waters Industries, functioning as a final disposition on the merits. The absence of any fee-shifting or carve-out suggests the parties reached a clean bilateral exit, though any underlying commercial terms remain outside the public record.
US11478035B2 — lighted headgear and accessories therefor
US11478035B2, filed under application number US16/934746, covers lighted headgear and accessories therefor — a product category encompassing caps, hats, and related wearable items incorporating integrated illumination technology. The patent is held by Shenzhen Kaianhao Technology Co., Ltd., a China-based manufacturer active in the consumer electronics and wearable accessories space. The corrected application number suggests this patent followed a standard USPTO prosecution path, and its B2 designation confirms it issued after the publication of a substantive examination.
From a competitive intelligence standpoint, US11478035B2 represents a meaningful IP asset in the illuminated wearable accessories segment — a market that intersects consumer electronics, outdoor recreation, and safety equipment. The fact that Kaianhao pursued litigation in U.S. federal court, and reached a with-prejudice resolution, suggests the patent has sufficient claim breadth to sustain a credible infringement assertion. Any company sourcing, distributing, or developing lighted headgear products for the U.S. market should treat this patent as a live enforcement risk and map their product designs against its independent claims.
Should your lighted headgear products be cleared against US11478035B2?
Product teams developing or importing illuminated caps, lighted beanies, LED-integrated headwear, or related wearable accessories for the U.S. market face direct exposure to US11478035B2. This case demonstrates that Kaianhao is prepared to enforce the patent through U.S. federal litigation against domestic distributors — not just competing manufacturers. If your supply chain sources lighted headgear products from China or your product catalogue includes any illuminated headwear, a claim-by-claim FTO analysis is a commercially necessary step before launch or continued distribution.
PatSnap Eureka’s FTO Search Agent can map your product specifications against the independent and dependent claims of US11478035B2, identify design-around opportunities, and surface prior art that may bear on validity. Eureka also tracks related litigation and continuations, so you receive a comprehensive picture of the enforcement landscape — not just a snapshot of the issued patent. For IP counsel advising importers or distributors operating in the lighted headgear space, Eureka provides the structured claim analysis needed to support an opinion letter or product clearance memo.
Run a freedom-to-operate analysis on US11478035B2 to assess your product’s exposure
Run FTO in Eureka →Similar lighted headgear and wearable accessory patent cases in N.D. Illinois
Explore comparable patent infringement actions involving illuminated wearable accessories and consumer product patents filed in the Northern District of Illinois.
What this case signals for the lighted headgear and wearable IP landscape
A with-prejudice exit after 311 days is rarely accidental — it typically reflects commercial resolution and signals an active enforcement posture.
US11478035B2 is still live: lighted headgear players face ongoing exposure
The dismissal does not retire the patent. Any company manufacturing, importing, or distributing illuminated headgear in the U.S. market should assess whether its products fall within the claims of US11478035B2. Kaianhao’s willingness to file and pursue litigation for over 300 days signals a credible enforcement posture — not a one-off complaint.
With-prejudice dismissals often mask undisclosed licensing terms
When both parties walk away bearing their own costs, the economic logic of litigation has typically been resolved elsewhere — through a license, royalty, or product redesign agreement. IP teams monitoring Kaianhao’s enforcement activity should track whether similar actions emerge against other distributors, which would confirm a broader licensing campaign rather than an isolated dispute.
Shenzhen v Waters — key questions answered
The case was dismissed with prejudice by joint stipulation under Fed. R. Civ. P. 41(a)(1)(A)(ii) on 29 August 2025, 311 days after filing. Each party agreed to bear its own costs and fees. Dismissal with prejudice permanently bars Kaianhao from refiling the same infringement claims against Waters Industries based on US11478035B2.
Shenzhen Kaianhao asserted US11478035B2, filed under application US16/934746, which covers lighted headgear and accessories therefor. The patent protects integrated illumination technology in wearable headgear products such as illuminated caps and related accessories sold or distributed in the U.S. market.
No. A dismissal with prejudice under Rule 41 resolves only the bilateral dispute between Kaianhao and Waters Industries. It does not affect the validity or enforceability of US11478035B2. The patent remains in force and Kaianhao retains full rights to assert it against other parties in future actions.
This provision means neither party sought or obtained an award of attorneys’ fees or litigation costs from the other. In patent cases, fee-shifting can occur under 35 U.S.C. § 285 in ‘exceptional cases.’ The mutual cost-bearing clause here signals that no such motion was pursued, which is consistent with a commercially negotiated resolution rather than a finding of litigation misconduct.
The case was filed in the Northern District of Illinois (Eastern Division) and assigned to Judge Jorge L. Alonso under case number 1:24-cv-10866. Plaintiff Kaianhao was represented by Glacier Law LLP (attorneys Tao Liu and Wei Wang). Defendant Waters Industries was represented by Funkhouser Vegosen Liebman & Dunn, Ltd. (attorneys Glenn Rice and Vance L. Liebman).
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