GrillArt v. GA Exclusive: Grill Skewer Patent Suit Dismissed Without Prejudice
Shenzhen Lantianjinrun Trading Co. (GrillArt) filed a patent infringement action against GA Exclusive Inc. in the Northern District of Illinois, asserting US11864694B2 covering the GRILLART Skewers product line. The case closed just 66 days after filing, when GrillArt voluntarily dismissed without prejudice before any answer or summary judgment motion was served.
GrillArt’s pre-answer dismissal leaves patent claims unresolved
On 7 December 2024, Shenzhen Lantianjinrun Trading Co., Ltd., operating under the brand GrillArt, filed a patent infringement action in the U.S. District Court for the Northern District of Illinois against GA Exclusive Inc. and individual defendant Andrei Ababi. The suit centred on U.S. Patent No. 11,864,694 B2, which covers the GRILLART Skewers product, asserting that the defendants’ competing product infringed the patent.
The case closed on 11 February 2025, just 66 days after filing, when GrillArt filed a Notice of Voluntary Dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). Plaintiff confirmed that no defendant had served an answer or a motion for summary judgment prior to the dismissal. The notice expressly stated that dismissal was without prejudice, meaning GrillArt retains the right to refile the same claims in the future.
The rapid resolution — before any responsive pleading — suggests the parties may have reached a private commercial arrangement, or that GrillArt elected to pause enforcement strategy. The public record is silent on any settlement terms or licensing agreement. Because the dismissal was without prejudice, the patent remains enforceable and the underlying infringement allegations have not been adjudicated, leaving strategic optionality with the patent holder.
Filing to Voluntary dismissal in 66 days
66 days — resolved before defendant filed any responsive pleading
Voluntarily dismissed: what the Rule 41 notice means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral right to dismiss
Federal Rule of Civil Procedure 41(a)(1)(A)(i) permits a plaintiff to dismiss an action without a court order by filing a notice of dismissal before the opposing party serves an answer or a motion for summary judgment. GrillArt confirmed neither condition had been triggered, making the dismissal effective upon filing — no judicial approval was required.
Pre-answer dismissalDismissed without prejudice — but the public record is silent on why
A dismissal without prejudice leaves the plaintiff free to refile the same claims. A dismissal with prejudice would bar them permanently. GrillArt’s notice expressly stated ‘without prejudice,’ preserving all patent claims against GA Exclusive and Andrei Ababi. The public record does not disclose whether a settlement, licensing deal, or tactical reconsideration drove this choice — that distinction matters significantly for competitive intelligence.
Claims may be refiledGA Exclusive escapes judgment — but faces ongoing patent exposure
GA Exclusive Inc. and Andrei Ababi obtained no merits ruling and no finding of non-infringement. The absence of a judgment in their favour means they cannot invoke claim or issue preclusion if GrillArt refiles. If they continue selling the accused product, they remain exposed to a renewed infringement action under US11864694B2. No defendant counsel is recorded, which may suggest the early resolution was commercially negotiated.
No preclusion establishedPatent stays enforceable; sector should monitor for refiling
US11864694B2 exits this litigation intact and fully enforceable. Other sellers of competing grill skewer products in the e-commerce channel should note that GrillArt has demonstrated willingness to litigate and retains the option to refile against GA Exclusive or pursue new defendants. The pre-answer posture and lack of cost ruling are consistent with a negotiated exit, but no public terms confirm that reading.
Enforcement risk persistsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Shenzhen Lantianjinrun Trading Co., Ltd. | Company | Consumer barbecue products brand — holder of US11864694B2 (GRILLART Skewers)Search in Eureka ↗ |
| Defendant | GA Exclusive Inc. | Company | GA Exclusive Inc., e-commerce seller of competing grill accessory productsSearch in Eureka ↗ |
| Plaintiff counsel | Matthew L. De Preter | Attorney | Counsel for Shenzhen Lantianjinrun Trading Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Aronberg Goldgehn | Law Firm | Representing Shenzhen Lantianjinrun Trading Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Manish S. Shah | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The notice of dismissal invokes Rule 41(a)(1)(A)(i), the self-executing dismissal mechanism available only before an answer or summary judgment motion is served. GrillArt’s confirmation that neither condition had been met makes this a clean, unilateral exit. The express ‘without prejudice’ designation is legally significant: no claim is extinguished, no issue is decided, and the plaintiff retains full rights to refile against either defendant. The absence of any merits finding means US11864694B2 has not been tested in this proceeding.
US11864694B2 — GRILLART Skewers barbecue device patent
U.S. Patent No. 11,864,694 B2, filed under application number 16/949,391, protects innovations relating to the GRILLART Skewers product — a barbecue grill skewer device in the consumer outdoor cooking accessories market. The patent’s grant of a utility patent (B2 designation) indicates it covers structural or functional innovations in skewer design. The patent is held by Shenzhen Lantianjinrun Trading Co. and forms the commercial basis for the GrillArt brand’s product differentiation strategy in the competitive e-commerce channel.
In the crowded grill accessories market, a granted utility patent provides meaningful exclusivity against competing product listings, particularly on platforms such as Amazon where price-competitive alternatives proliferate. GrillArt’s decision to enforce US11864694B2 against GA Exclusive signals that the patent holder views this IP as commercially material. For other manufacturers and resellers of grill skewer products, the patent’s claim scope is the critical variable — any product working around the protected features would need careful FTO review.
Should your product team run an FTO against US11864694B2?
Any company designing, importing, or selling grill skewer products in the United States — particularly through e-commerce channels — should consider a freedom-to-operate assessment against US11864694B2. GrillArt has demonstrated enforcement intent by initiating litigation in federal court, and the without-prejudice dismissal means the patent remains fully available for future enforcement actions against new or existing defendants.
PatSnap Eureka’s FTO Search Agent can map the claim scope of US11864694B2 against your specific product configuration, flag design-around opportunities, and identify any prior art that could inform an invalidity position. Given the pre-answer resolution here, the patent has never been stress-tested in contested proceedings — making independent claim analysis more important, not less, for competitors currently in the market.
Run a freedom-to-operate analysis on US11864694B2 to assess your product’s exposure
Run FTO in Eureka →Similar grill accessories patent suits in Northern District of Illinois
Explore comparable product patent infringement cases involving consumer grill accessories and e-commerce sellers litigated in the Northern District of Illinois.
What this case signals for the grill accessories IP landscape
A voluntary pre-answer dismissal in a product patent case rarely ends the story — here is what it means for competitors and IP teams.
Without-prejudice dismissals preserve enforcement leverage
GrillArt’s explicit ‘without prejudice’ language is a deliberate strategic choice. It keeps US11864694B2 live as an enforcement tool. Competitors in the grill accessories space — particularly e-commerce sellers — should treat this dismissal as a pause, not a resolution, and assess their own product exposure accordingly.
Pre-answer timing suggests a swift commercial resolution
Cases dismissed before any answer or summary judgment motion are frequently settled or subject to licensing arrangements that never reach the public record. The 66-day window and absence of any defendant counsel filing are consistent with a negotiated outcome. IP teams monitoring this dispute should flag the patent for ongoing watch.
Shenzhen v GA — key questions answered
A voluntary dismissal without prejudice under Rule 41(a)(1)(A)(i) means GrillArt chose to end this specific proceeding without any court judgment. No claims were decided on the merits. Critically, ‘without prejudice’ means GrillArt retains the right to refile the same infringement claims against GA Exclusive or Andrei Ababi in the future. US11864694B2 remains fully enforceable.
The asserted patent is US11864694B2, filed under application number 16/949,391. It covers the GRILLART Skewers product — a barbecue grill skewer device. The patent is held by Shenzhen Lantianjinrun Trading Co., Ltd., which operates the GrillArt consumer brand. The case was filed in the Northern District of Illinois, Case No. 1:24-cv-12598.
The public record does not explain the specific basis for naming Andrei Ababi individually. In e-commerce patent cases, individual officers or principals are sometimes named alongside the corporate entity to increase settlement leverage or to establish personal liability for willful infringement. No defendant counsel filed any appearance in this matter prior to the dismissal.
Yes. Because the dismissal was expressly without prejudice, GrillArt is not barred from refiling infringement claims based on US11864694B2 against GA Exclusive Inc. or Andrei Ababi. Had the dismissal been with prejudice, or had it been a second Rule 41 dismissal involving the same claims against the same parties, refiling would be barred under the ‘two dismissal rule.’ Neither condition applies here.
The case was filed in the U.S. District Court for the Northern District of Illinois, Case No. 1:24-cv-12598, and was assigned to Judge Manish S. Shah. It was filed on 7 December 2024 and closed on 11 February 2025. Plaintiff was represented by attorney Matthew L. De Preter of Aronberg Goldgehn. No defense counsel appearance was recorded in the public docket.
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