Shenzhen Sanhu v. Hats On LLC: Hat Holder Patent Dispute Voluntarily Dismissed
Shenzhen City Sanhu Technology Co., Ltd. filed suit against Lindsay Albanese and Hats On, LLC (d.b.a. TopTote) in California’s Central District, asserting infringement of US10413047B2, a patent covering a hat holder product. The plaintiff voluntarily dismissed the action without prejudice after 218 days, leaving the door open for future proceedings.
A patent dispute over hat holder tech ends before the first ruling
On November 1, 2023, Shenzhen City Sanhu Technology Co., Ltd., a Chinese consumer products company, filed an infringement action in the U.S. District Court for the Central District of California against Lindsay Albanese and Hats On, LLC, operating under the trade name TopTote. The suit centred on US10413047B2, a patent covering hat holder technology, with Sanhu alleging that the defendants’ TopTote product infringed its protected design or utility claims.
On June 6, 2024 — 218 days after filing — the plaintiff filed a notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), terminating the action as to all defendants. The verdict document states the dismissal is ‘without prejudice,’ meaning Sanhu retains the theoretical right to refile claims against the same defendants on the same patent, subject to applicable statutes of limitations and any intervening defences.
The case resolved well before any scheduling order deadlines or merits briefing would typically be reached, suggesting the parties may have reached a commercial accommodation or that the plaintiff reassessed its litigation posture. Because Rule 41(a)(1)(A)(i) dismissals require no court order and generate no substantive ruling, the public record offers no insight into the underlying merits, claim strength, or any terms exchanged between the parties.
Filing to Voluntary dismissal in 218 days
218 days from filing to voluntary dismissal — resolved before any substantive court ruling
Voluntarily dismissed: what the Rule 41 exit means for both parties
Rule 41(a)(1)(A)(i): plaintiff exits before defendant responds
A dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i) allows a plaintiff to withdraw unilaterally, without a court order, before the defendant has served an answer or a motion for summary judgment. This is the earliest and cleanest procedural exit available. No merits ruling is made, no liability is determined, and the court exercises no discretion over whether to grant the dismissal.
No court order requiredThe record states ‘without prejudice’ — refiling remains possible
The plaintiff’s notice expressly states the dismissal is ‘without prejudice,’ meaning Shenzhen Sanhu is not permanently barred from reasserting the same claims against Lindsay Albanese or Hats On, LLC on US10413047B2. A dismissal with prejudice would have extinguished those rights entirely. The distinction matters commercially: TopTote cannot treat this closure as a final adjudication of non-infringement.
Refiling rights preservedTopTote avoids a merits ruling — but faces residual uncertainty
Lindsay Albanese and Hats On, LLC obtained no declaratory judgment of non-infringement and no invalidity ruling. While the immediate litigation threat is removed, the without-prejudice dismissal means the plaintiff could refile if commercial circumstances change or if the defendants’ product line expands. Defendants may wish to conduct their own freedom-to-operate analysis on US10413047B2 to reduce ongoing exposure.
No invalidity ruling obtainedEarly exit signals possible settlement or tactical recalibration
Voluntary dismissals at the pre-answer stage frequently reflect one of two scenarios: a confidential commercial resolution (licence or settlement), or a plaintiff’s reassessment of claim strength or litigation cost. Neither can be confirmed from the public docket. For competitors in the hat holder and portable accessory storage space, US10413047B2 remains an active, unadjudicated patent that has been enforced at least once in U.S. federal court.
Patent remains active and unadjudicatedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Shenzhen City Sanhu Technology Co., Ltd. | Company | Consumer products technology company — holder of US10413047B2 (hat holder device)Search in Eureka ↗ |
| Defendant | Lindsay Albanese | Individual | Lindsay Albanese and Hats On, LLC (d.b.a. TopTote) — hat holder product sellerSearch in Eureka ↗ |
| Co-Defendant | Hats On, LLC | Company | Search in Eureka ↗ |
| Plaintiff counsel | Jiyuan Zhang | Attorney | Counsel for Shenzhen City Sanhu Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Steven L Sugars | Attorney | Counsel for Shenzhen City Sanhu Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | J. Zhang & Associates PC | Law Firm | Representing Shenzhen City Sanhu Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Law Offices of Steven L. Sugars | Law Firm | Representing Shenzhen City Sanhu Technology Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | California Central District CourtSearch in Eureka ↗ |
Official order — verbatim text
The plaintiff’s Rule 41(a)(1)(A)(i) notice is a unilateral procedural act, not a judicial decision. The court made no findings on infringement, validity, or claim construction. The express ‘without prejudice’ designation is legally significant: it preserves Sanhu’s right to refile and prevents the defendants from invoking res judicata or claim preclusion in any future action on the same patent. For defendants, the absence of a declaratory judgment of non-infringement means ongoing commercial exposure under US10413047B2.
US10413047B2 — portable hat holder device
US10413047B2, filed under application number US15/939549, covers a hat holder — a product designed to carry, store, or display hats in a portable or attachable format. The patent is held by Shenzhen City Sanhu Technology Co., Ltd., a Chinese consumer goods technology company. The patent has been granted by the USPTO and remains in force, having been asserted without any invalidity ruling to date. Its claims likely address the structural or functional configuration of the holding mechanism.
For the accessories and lifestyle products sector, this patent represents an enforcement risk that extends beyond the immediate TopTote dispute. Shenzhen-based patent holders with U.S.-registered patents covering everyday consumer accessories have demonstrated a willingness to litigate in U.S. federal courts. Any manufacturer, importer, or online retailer dealing in hat holders, cap carriers, or functionally similar portable accessories should assess the claims of US10413047B2 against their own product specifications.
Should you run an FTO analysis against US10413047B2?
If your company designs, imports, distributes, or retails hat holders or functionally similar portable accessory-carrying products in the United States, US10413047B2 should be on your FTO radar. This patent has been asserted in litigation and remains active with no invalidity finding. The Central District of California is a reachable venue for enforcement actions involving goods distributed through West Coast import channels or major e-commerce platforms.
PatSnap Eureka’s FTO Search Agent can map the claims of US10413047B2 against your product specifications, identify the patent family for continuation risks, and surface any related applications that may broaden the protection scope. Eureka also flags assignee enforcement history, helping you assess whether Shenzhen Sanhu has filed related actions against other hat or accessory product companies — giving your legal team the intelligence needed before you scale.
Run a freedom-to-operate analysis on US10413047B2 to assess your product’s exposure
Run FTO in Eureka →Similar hat holder and consumer accessory patent cases in U.S. district courts
Cases involving consumer accessory patent enforcement in the Central District of California, including hat holder and portable carrying device disputes filed by Chinese IP holders.
What this case signals for the hat holder and accessories IP landscape
A Chinese patent holder enforcing a consumer accessory patent in California’s Central District is a pattern worth tracking for accessory and lifestyle product companies.
US10413047B2 has been actively asserted — FTO review is warranted
Shenzhen Sanhu’s willingness to file in a U.S. federal court signals active enforcement intent. Any company selling hat holders, bag accessories, or comparable portable carrying products in the U.S. market should treat this patent as a live risk and conduct a formal freedom-to-operate review before scaling distribution.
Without-prejudice dismissals do not clear the IP landscape
Competitors and distributors should not interpret this case closure as validation that the TopTote product — or similar designs — are clear of US10413047B2. No court ruled on validity or infringement. The patent survives intact, and the plaintiff’s enforcement posture remains unknown. Monitor the patent family for continuation filings or reexamination activity.
Shenzhen v Lindsay — key questions answered
The dismissal was filed without prejudice under Rule 41(a)(1)(A)(i), meaning no merits ruling was issued. Lindsay Albanese and Hats On, LLC obtained no declaratory judgment of non-infringement. The plaintiff retains the right to refile claims on US10413047B2, so defendants face residual legal exposure despite the case being formally closed.
US10413047B2 covers a hat holder device — a portable product for carrying or storing hats. It has been actively asserted in U.S. federal court by its Chinese assignee, Shenzhen City Sanhu Technology Co., Ltd. Competitors selling hat holders or functionally similar accessories in the U.S. should conduct a freedom-to-operate review to assess infringement risk under this still-active patent.
Rule 41(a)(1)(A)(i) allows a plaintiff to dismiss an action without a court order, as a matter of right, before the defendant has served an answer or motion for summary judgment. It is the earliest available exit. In this case, Shenzhen Sanhu used it to terminate the action against all defendants on June 6, 2024, generating no judicial ruling on the merits of the patent infringement claims.
Yes. The dismissal is expressly stated to be without prejudice, which means Shenzhen Sanhu is not barred from refiling the same patent infringement claims against Lindsay Albanese or Hats On, LLC under US10413047B2, subject to applicable statutes of limitations. A second voluntary dismissal of the same claims by the same plaintiff against the same defendants would, however, operate as a dismissal with prejudice under the ‘two dismissal rule.’
The public docket does not disclose any settlement agreement or licence terms. The case was closed via a unilateral plaintiff notice with no reference to settlement. The early pre-answer dismissal is consistent with either a confidential commercial resolution or a plaintiff decision to discontinue litigation, but neither can be confirmed from the available record.
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