Venue Dismissed: Shenzhen Huajing v. The Grease Box LLC Patent Case

Introduction

A patent infringement complaint filed by a Chinese trading company against a small American LLC was dismissed without prejudice in under eight months — not on the merits of the infringement claim, but because the plaintiff chose the wrong courtroom. In Shenzhen Huajing International Trade Co., Ltd. v. The Grease Box LLC (Case No. 2:25-cv-01300), the U.S. District Court for the Western District of Washington granted the defendant’s motion to dismiss after finding the plaintiff failed to establish that a substantial part of the events giving rise to the claim occurred in Washington.

The case centered on U.S. Patent No. US11812895B2, covering what appears to be a grease containment product, with four specific Amazon-listed grease bucket SKUs named as accused products. Chief Judge Jamal N. Whitehead declined to transfer the case, instead dismissing the complaint outright.

For patent attorneys, IP professionals, and R&D teams, this outcome is a sharp reminder: even a meritorious infringement claim can collapse before it begins if venue is poorly planned. This case is a textbook study in the strategic and procedural stakes of venue selection in patent infringement litigation.

Case Overview

The Parties

The Patent at Issue

The patent at issue is **U.S. Patent No. US11812895B2** (application number US16/984646). While the input data does not disclose the full claim language, the patent falls within the grease containment or cooking accessory product category based on the accused products. The asserted claims were not adjudicated on their merits due to the procedural dismissal.

The complaint accused four Amazon-listed grease bucket products sold by The Grease Box LLC. The commercial relevance is significant: Amazon ASIN-linked products represent active retail inventory, meaning the plaintiff was targeting commercially live products in a competitive e-commerce market.

Legal Representation

Plaintiff was represented by attorneys Hongchang Deng and Jianwei Wang of Alight Law P.C. and LawMay PC.

Defendant was represented by Armon Shahdadi, Christopher R. Kinkade, and Frank Stuart Harrison of Pierson Ferdinand LLP, with offices engaged across Seattle, Georgia, and New Jersey — reflecting a coordinated, multi-jurisdictional defense posture.

Litigation Timeline & Procedural History

The complaint was filed on July 10, 2025 in the U.S. District Court for the Western District of Washington, a court known for handling technology and IP matters in the Pacific Northwest corridor. The case was assigned to Chief Judge Jamal N. Whitehead.

The matter resolved in 228 days — roughly 7.5 months — without reaching claim construction, discovery, or any substantive infringement analysis. The defendant’s motion to dismiss for improper venue was dispositive. No evidence suggests the plaintiff pursued an interlocutory appeal or sought emergency transfer relief.

The speed of dismissal signals an early, aggressive defense motion that the plaintiff was unable to rebut with sufficient jurisdictional facts connecting the alleged infringement events to Washington state. The court’s refusal to transfer — opting instead for outright dismissal — added procedural finality to an already short-lived case.

The Verdict & Legal Analysis

Outcome

Chief Judge Whitehead granted the defendant’s motion to dismiss and dismissed the complaint without prejudice, meaning Shenzhen Huajing retains the right to refile in a proper venue. No damages were awarded. No injunctive relief was issued. The case closed February 23, 2026.

Venue Deficiency: The Core Legal Issue

The court’s ruling turned entirely on 28 U.S.C. § 1391, the general federal venue statute, and potentially 28 U.S.C. § 1400(b), the patent-specific venue provision established and clarified by the Supreme Court in TC Heartland LLC v. Kraft Foods Group Brands LLC (2017).

The court found that the plaintiff failed to demonstrate that a substantial part of the events or omissions giving rise to the claim occurred in Washington. In patent infringement cases, this requires showing that infringing acts — such as sales, offers for sale, manufacture, or use — took place within the district. Where accused products are sold exclusively through Amazon’s national marketplace, pinning venue to a specific district becomes legally complex.

The court notably declined to transfer the case in lieu of dismissal, finding it was not “in the interests of justice” to do so. This is a meaningful distinction: courts have discretion under 28 U.S.C. § 1406(a) to either dismiss or transfer when venue is improper. The court’s choice of dismissal, rather than transfer, suggests the plaintiff’s venue theory was insufficiently developed or that a proper alternative venue was not clearly established on the record.

Strategic Turning Points

Two strategic failures stand out. First, the plaintiff filed in Washington without establishing a clear nexus between The Grease Box LLC’s alleged infringing conduct and that district. For Amazon-based sellers, sales may occur nationwide, but courts increasingly demand proof of defendant’s specific contacts with the chosen forum. Second, the plaintiff’s legal team did not present a compelling transfer argument as a fallback, leaving the court without a clear alternative venue to which it could redirect the case.

Legal Significance

This case reinforces the post-TC Heartland landscape where venue selection in patent cases is a threshold strategic decision, not an afterthought. Plaintiffs — particularly foreign companies asserting U.S. patents — must conduct rigorous pre-filing venue analysis, including identifying where the defendant resides, is incorporated, or has committed acts of infringement with a regular place of business.