Xueyuan Chen v. Schedule A Defendants: Design Patent Dispute Ends With Prejudice
Xueyuan Chen asserted design patent USD1051537S — covering a stainless steel rag — against a group of unnamed online marketplace sellers in the Northern District of Illinois. The case resolved via stipulated dismissal with prejudice after approximately 362 days, foreclosing any refiling of the same claims.
Schedule A design patent enforcement ends in stipulated exit
On December 20, 2024, Xueyuan Chen filed an infringement action in the U.S. District Court for the Northern District of Illinois, asserting design patent USD1051537S — which protects the ornamental appearance of a stainless steel rag — against a group of defendants identified only as ‘The Partnerships and Unincorporated Associations Identified in Schedule A.’ This anonymised pleading format is a well-established tactic in e-commerce IP enforcement, allowing plaintiffs to target large cohorts of online sellers simultaneously.
The case concluded on December 17, 2025, when the parties filed a stipulation of dismissal with prejudice as to the remaining defendant identified as Docket Entry 108/161. The court entered the dismissal and denied as moot two pending defence motions — a motion to sever (Dkt. 130) and a motion to dismiss for failure to state a claim (Dkt. 134). A dismissal with prejudice bars the plaintiff from reasserting the same claims against this defendant in any subsequent proceeding.
At 362 days, the case ran nearly a full year before resolving, which is consistent with Schedule A litigation that progresses through contested motion practice before reaching settlement or stipulated exit. The denial of the defence motions as moot means no merits ruling was issued on claim adequacy or joinder — leaving those legal questions unanswered. The private terms of any underlying agreement, including whether a licence or payment was exchanged, are not disclosed in the public record.
Filing to Case Dismissed in 362 days
362-day duration — typical for a stipulated resolution in a Schedule A e-commerce enforcement action
Dismissed with prejudice: what the stipulated exit means for both sides
Stipulated dismissal with prejudice — a negotiated, final exit
A dismissal with prejudice entered pursuant to a joint stipulation means the parties agreed to end the litigation on final terms. Unlike a court-ordered dismissal, a stipulated exit typically reflects a negotiated resolution. The ‘with prejudice’ designation is legally significant: it extinguishes the plaintiff’s right to refile the same claims against the same defendant, functioning as a final adjudication on the merits for res judicata purposes.
Negotiated final resolutionPlaintiff secures a final, unrefiable resolution
For Xueyuan Chen, a with-prejudice dismissal suggests the enforcement objective against this particular defendant was satisfied — whether through a licence, a payment, or a cessation of infringing activity. The plaintiff retains the design patent USD1051537S and may continue enforcing it against other parties. The public record does not disclose whether financial consideration was exchanged, but the with-prejudice designation is consistent with a completed commercial resolution.
Patent rights intact; defendant resolvedDefence motions denied as moot — no merits ruling obtained
The remaining defendant had filed a motion to sever and a motion to dismiss for failure to state a claim — substantive challenges that, if granted, could have shaped the litigation materially. Both were denied as moot following the stipulation, meaning the defendant did not secure a precedential ruling on claim adequacy or joinder. The with-prejudice nature of the dismissal also means the defendant cannot be sued again on these specific claims, which may have been a negotiated concession.
No merits ruling; claims extinguishedE-commerce design patent enforcement: settlement pressure remains high
This case is consistent with the broader pattern of Schedule A litigation in which individual design patent holders assert rights against large cohorts of online sellers, relying on the in terrorem effect of TRO motions and asset freezes to drive early resolutions. The absence of a merits ruling on the motion to dismiss for failure to state a claim means online sellers in the stainless steel housewares and cleaning product categories should treat USD1051537S as an active enforcement risk when sourcing or listing comparable products.
Active design patent enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Xueyuan Chen | Individual | Individual design patent holder — asserting USD1051537S covering a stainless steel rag ornamental designSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified in Schedule A | Individual | Anonymous online marketplace sellers identified collectively via Schedule A filingSearch in Eureka ↗ |
| Plaintiff counsel | Robert Michael Dewitty | Attorney | Counsel for Xueyuan ChenSearch in Eureka ↗ |
| Plaintiff law firm | Dewitty And Associates, Chtd. | Law Firm | Representing Xueyuan ChenSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The minute entry records a stipulated dismissal with prejudice as to the sole remaining defendant (Dkt. 108/161), with two pending defence motions — severance and failure to state a claim — denied as moot. The with-prejudice designation carries full res judicata effect, barring any refiling of these specific claims. Critically, neither motion was decided on the merits, so no judicial guidance on claim adequacy or joinder propriety emerged from this proceeding.
USD1051537S — Ornamental design for a stainless steel rag
USD1051537S is a U.S. design patent protecting the ornamental appearance of a stainless steel rag — a cleaning and odour-neutralising product that has grown in popularity across e-commerce platforms. Design patents protect the visual, non-functional characteristics of an article of manufacture. The application number US29/956493 indicates a Section 29 design application, which typically proceeds to grant faster than utility patents. The scope of protection is defined by the drawings in the patent, making design-around analysis highly visual and fact-specific.
Stainless steel rag products occupy a competitive niche in the housewares and kitchen cleaning segment, with numerous third-party sellers on Amazon, Alibaba, and other marketplaces offering near-identical items. A design patent in this space gives the holder a commercially potent enforcement tool: because design infringement is assessed under the ‘ordinary observer’ test, even minor visual similarity can sustain a claim. Holders of design patents on commodity housewares products have increasingly weaponised Schedule A filings to extract resolutions from sellers who cannot afford contested litigation.
Should your product team run an FTO against USD1051537S?
Any company sourcing, importing, or listing stainless steel rag products — particularly those with an ornamental form similar to the design depicted in USD1051537S — should treat this patent as a live clearance risk. The with-prejudice resolution confirms the patent holder is actively enforcing, and the patent remains in force. Retailers, private-label brands, and marketplace sellers in the housewares and kitchen cleaning category should prioritise FTO clearance before launching or continuing to sell visually comparable products.
PatSnap Eureka’s FTO Search Agent can map the claims of USD1051537S against your product’s visual design, identify prior art that could support an invalidity argument, and surface related design patents in the stainless steel housewares space. For Schedule A defendants or potential targets, Eureka can also identify other active enforcement campaigns by the same plaintiff, giving your legal team an early warning of litigation risk before a TRO is filed.
Run a freedom-to-operate analysis on USD1051537S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A enforcement cases in Illinois
Explore comparable design patent infringement actions filed in the Northern District of Illinois targeting e-commerce sellers via Schedule A anonymous defendant procedures.
What this case signals for design patent enforcement in e-commerce
Schedule A litigation continues to resolve through private stipulation, leaving no precedent but real commercial consequences for online sellers.
With-prejudice exits in Schedule A cases signal completed commercial deals
When Schedule A litigation ends via stipulated dismissal with prejudice — rather than default judgment or voluntary dismissal — it typically signals that the plaintiff secured the outcome sought: a licence, damages payment, or cessation agreement. For marketplace sellers facing similar actions, this pattern underscores the leverage that asset-freeze TROs create early in the proceeding.
Unresolved motion to dismiss leaves claim adequacy unanswered
The pending motion to dismiss for failure to state a claim was never adjudicated on the merits. Defendants in comparable Schedule A design patent cases should note that such motions, while strategically useful for leverage, frequently become moot before a ruling is issued — meaning the precedent value of pursuing them is limited absent a contested merits hearing.
Chen v Partnerships — key questions answered
The case was dismissed with prejudice. On December 17, 2025, the court entered a stipulated dismissal with prejudice as to the remaining defendant (Dkt. 108/161), meaning the plaintiff is barred from refiling the same infringement claims against that defendant.
USD1051537S is a U.S. design patent filed under application number US29/956493, protecting the ornamental appearance of a stainless steel rag. Design patents cover visual, non-functional characteristics of a product and are enforced using the ‘ordinary observer’ infringement standard.
The defendant filed a motion to dismiss for failure to state a claim (Dkt. 134) and a motion to sever (Dkt. 130). Both were denied as moot following the stipulated dismissal. No merits ruling was issued on either motion, leaving the legal questions unresolved.
Schedule A litigation is a mass-joinder enforcement technique used predominantly in the Northern District of Illinois, where a plaintiff files against a large group of anonymous e-commerce sellers identified in an attached schedule. It is commonly paired with ex parte TRO motions to freeze marketplace accounts, creating significant settlement pressure before defendants can organise a defence.
No. The with-prejudice dismissal resolves claims only against the specific remaining defendant (Dkt. 108/161). Design patent USD1051537S remains in force and can be asserted against other parties. The plaintiff retains full enforcement rights under the patent for its remaining term.
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