Shenzhen Quanxindi v. Schedule A Defendants: Broom Design Patent Dismissed With Prejudice
Shenzhen Quanxindi Technology Co. Ltd. filed suit in the Northern District of Illinois asserting design patent USD991607S covering a broom apparatus against anonymous online marketplace defendants. The case closed in just 86 days via a stipulated voluntary dismissal with prejudice, with each party bearing its own costs.
Design Patent Enforcement Against Anonymous Sellers Ends in 86-Day Stipulated Dismissal
On November 13, 2024, Shenzhen Quanxindi Technology Co. Ltd., a Chinese consumer goods company and holder of design patent USD991607S, filed an infringement action in the U.S. District Court for the Northern District of Illinois before Judge Jorge L. Alonso. The suit targeted an anonymous group of online sellers identified collectively as ‘The Partnerships and Unincorporated Associations Identified on Schedule A’ — a common enforcement structure in e-commerce brand-protection litigation. The asserted patent covers the ornamental design of a broom apparatus.
The case closed on February 7, 2025, via a stipulated voluntary dismissal with prejudice filed under Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Both plaintiff and defendants signed the stipulation through counsel, and the court entered it without a merits ruling. The dismissal with prejudice is a final disposition: Shenzhen Quanxindi cannot refile the same claims against these named defendants. Pending motions — including Plaintiff’s Motion for Preliminary Injunction (Dkt. 31) and Defendants’ response (Dkt. 50) — were rendered moot.
The 86-day resolution is notably swift, suggesting the parties likely reached a private settlement or licensing arrangement that was not disclosed in the public record. The filing of a preliminary injunction motion signals Quanxindi pursued interim relief aggressively before the agreed resolution. The public record is silent on the specific financial terms, any licensing arrangement, or whether injunctive relief was informally agreed — these details, if any, remain confidential.
Filing to Voluntary dismissal in 86 days
86 days — resolved well below the typical 2–3 year N.D. Illinois patent litigation average
Dismissed with prejudice: what the stipulated exit means for both sides
Rule 41(a)(1)(A)(ii) dismissal with prejudice — a final, consensual exit
Under Rule 41(a)(1)(A)(ii), parties may jointly stipulate to dismiss an action after the opposing party has answered. Here, dismissal was entered with prejudice, meaning the claims are extinguished permanently. Unlike a dismissal without prejudice — which preserves the right to refile — this stipulation constitutes a final adjudication on the merits for res judicata purposes against these specific defendants.
With prejudice — no refilingQuanxindi forfeits right to re-sue these defendants — but may retain leverage
By agreeing to dismissal with prejudice, Shenzhen Quanxindi permanently relinquished its right to pursue the same design patent claims against these named defendants. The public record does not disclose any settlement terms, licensing fees, or undertakings from the defendants. The rapid resolution — within 86 days and shortly after a preliminary injunction motion — is consistent with a private resolution providing Quanxindi with some commercial benefit, but this cannot be confirmed from the docket alone.
Claims extinguished; terms undisclosedDefendants exit with finality — but at unknown cost
The Schedule A defendants secured a dismissal with prejudice, eliminating any threat of further litigation by this plaintiff on the same claims. Each party bears its own costs, so no fee award was entered against the defendants. However, the existence of any private agreement — such as a takedown undertaking, licence, or payment — is not reflected in the public docket. Defendants’ willingness to engage counsel and stipulate suggests at least some negotiation occurred.
No fee award; private terms unknownSchedule A enforcement tactics remain viable for design patent holders
This case follows an established e-commerce enforcement playbook: file against anonymous Schedule A sellers, seek a preliminary injunction to freeze assets or listings, then resolve privately. The swift 86-day closure and with-prejudice terms suggest this tactic can produce rapid commercial results for design patent holders targeting online marketplaces. Competitors and sellers operating in the consumer broom and household goods space should note that USD991607S remains in force and could be asserted against other parties not named in this action.
Design patent still enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Shenzhen Quanxindi Technology Co. Ltd. | Company | Chinese consumer goods manufacturer — holder of design patent USD991607S (broom apparatus)Search in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online marketplace sellers identified collectively on Schedule A to the ComplaintSearch in Eureka ↗ |
| Plaintiff counsel | Depeng Bi | Attorney | Counsel for Shenzhen Quanxindi Technology Co. Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Konrad Val Sherinian | Attorney | Counsel for Shenzhen Quanxindi Technology Co. Ltd.Search in Eureka ↗ |
| Plaintiff law firm | The Law Offices of Konrad Sherinian LLC | Law Firm | Representing Shenzhen Quanxindi Technology Co. Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Jorge L. Alonso | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The stipulation invokes Rule 41(a)(1)(A)(ii), confirming that defendants had appeared through counsel — making unilateral dismissal unavailable and requiring joint agreement. The with-prejudice designation is legally significant: it bars Quanxindi from reasserting identical claims against these defendants, conferring finality equivalent to a merits judgment. The concurrent mooting of the preliminary injunction motion (Dkt. 31) confirms that no interim relief order was entered. The absence of a fee award despite pending PI litigation suggests a negotiated, commercially driven exit rather than a concession of weakness by either side.
USD991607S — Ornamental Design for a Broom Apparatus
USD991607S is a U.S. design patent, filed under application number US29/844711, that protects the ornamental appearance of a broom apparatus. Design patents under 35 U.S.C. § 171 cover the visual, non-functional characteristics of a product — meaning the scope of protection is defined by the drawings in the patent, not by functional claims. The patent is assigned to Shenzhen Quanxindi Technology Co. Ltd. and is directed at the consumer household cleaning tools sector.
Design patents for consumer goods sold on e-commerce platforms have become a key tool for Chinese manufacturers seeking to protect product aesthetics against copycat sellers on Amazon, Walmart Marketplace, and similar platforms. USD991607S, covering the distinctive look of a broom apparatus, represents a commercially significant IP asset in a highly competitive category. Any seller offering a broom with a visually similar ornamental design could face infringement exposure, even if the functional characteristics differ. The patent remains in force following the with-prejudice dismissal in this action.
Should you run an FTO analysis against USD991607S?
Any company designing, importing, or selling broom apparatuses — particularly for U.S. e-commerce channels — should assess freedom-to-operate against USD991607S. Design patent infringement is assessed under the ‘ordinary observer’ test: if an ordinary purchaser would consider your product substantially similar in overall appearance to the patented design, infringement may exist regardless of functional differences. Given Quanxindi’s demonstrated willingness to file in N.D. Illinois and pursue preliminary injunctions, the enforcement risk is real and operationally disruptive.
PatSnap Eureka’s FTO Search Agent enables R&D and product teams to map visual design patent landscapes, identify potentially blocking design registrations, and generate clearance reports. For consumer goods entering the U.S. market, Eureka can surface related design patents held by Quanxindi and comparable rights holders, allowing your team to make informed go/no-go decisions before committing to tooling or inventory at scale.
Run a freedom-to-operate analysis on USD991607S to assess your product’s exposure
Run FTO in Eureka →Similar Design Patent Schedule A Enforcement Cases in N.D. Illinois
Explore comparable design patent infringement actions against Schedule A e-commerce defendants filed in the Northern District of Illinois covering consumer goods and household products.
What this case signals for the consumer goods design patent IP landscape
A sub-90-day closure with prejudice in N.D. Illinois reflects the leverage that design patent holders wield in Schedule A e-commerce enforcement actions.
Schedule A filings with PI motions generate rapid resolution pressure
Filing a preliminary injunction motion early — as Quanxindi did at Dkt. 31 — creates immediate operational risk for e-commerce defendants through potential asset freezes and listing takedowns. This case closed in 86 days, consistent with the pattern of defendants seeking swift resolution to avoid injunctive disruption to their marketplace revenue.
Dismissal with prejudice signals private resolution — not a defence win
A mutual stipulation to dismiss with prejudice, with each party bearing own costs, typically signals that a confidential commercial arrangement was reached. Defendants did not achieve a no-cause dismissal or invalidate the patent. USD991607S survives intact and can be enforced against any sellers not party to this stipulation.
Shenzhen v Partnerships — key questions answered
Dismissal with prejudice under Rule 41(a)(1)(A)(ii) means Quanxindi permanently relinquished its right to sue the named defendants on the same design patent claims. It is a final disposition equivalent to a merits judgment for res judicata purposes. The patent USD991607S itself is unaffected and remains enforceable against third parties.
USD991607S is a U.S. design patent (application number US29/844711) assigned to Shenzhen Quanxindi Technology Co. Ltd. It protects the ornamental design — the visual appearance — of a broom apparatus. Design patents protect aesthetic, non-functional characteristics and are assessed under the ordinary observer standard for infringement.
The 86-day resolution is notably rapid for patent litigation, which typically spans years. The filing of a preliminary injunction motion (Dkt. 31) likely created significant operational pressure on defendants — risking marketplace listing freezes or asset restraints. This pressure is consistent with Schedule A enforcement strategy and suggests the parties reached a private commercial resolution, though terms are not disclosed in the public record.
No. Because the dismissal was entered with prejudice, Quanxindi is barred from refiling identical claims against the same named defendants under the doctrine of res judicata. However, Quanxindi retains full rights to enforce USD991607S against any other parties not named in this case.
The Schedule A structure allows plaintiffs to file a single complaint against numerous anonymous online sellers — often identified only by their marketplace store names — without knowing their legal identities upfront. It is widely used in N.D. Illinois for IP enforcement against e-commerce infringers and enables plaintiffs to obtain ex parte TROs or preliminary injunctions to freeze listings and accounts before defendants can conceal assets.
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