Yu Luo v. Schedule A Defendants: Shelf Bracket Design Patent Dispute Ends in Voluntary Dismissal
Patent holder Yu Luo filed suit in the Northern District of Illinois against a cohort of e-commerce sellers — including AAG Inc., LALAGOGO, and Guangzhou Kobe Information Technology — alleging infringement of design patent USD1012683S covering a shelf bracket. The case ran 626 days before closing via voluntary dismissal, with no merits adjudication on the public record.
E-commerce design patent sweep ends without a merits ruling
On 8 March 2024, plaintiff Yu Luo filed suit in the Northern District of Illinois, Case No. 1:24-cv-01977, before Judge Mary M. Rowland. The complaint named a Schedule A roster of online marketplace sellers — including AAG Inc., Guangzhou Kobe Information Technology Co. Ltd, LALAGOGO, MHMY Global Sell, Shieldsen, YMD Parts, HITOMEN, Panda Design, AOCAN, and others — alleging infringement of design patent USD1012683S, which protects the ornamental appearance of a shelf bracket. Plaintiff was represented by Dewitty and Associates, Chtd.
The case closed on 24 November 2025 following a voluntary dismissal. Notably, the dismissal notice on record specifically references MHMY Global Sell as the counter-claimant and third-party plaintiff voluntarily dismissing its counter-defendant and third-party defendants under Fed. R. Civ. Pro. 41(c)(2). The public record does not specify whether the dismissal was entered with or without prejudice, which carries significant consequences: a with-prejudice dismissal bars re-filing, while a without-prejudice dismissal preserves the right to refile.
The 626-day duration — from filing to close — suggests the litigation followed a protracted procedural path before resolution, which is not uncommon in multi-defendant Schedule A cases where defendants may be difficult to serve or may default. What drove the ultimate voluntary dismissal, and whether any private settlement agreement accompanied it, remains unknown from the public record. The involvement of a counter-claim by MHMY Global Sell adds an unusual procedural dimension to what is typically a one-sided Schedule A enforcement action.
Filing to Voluntary dismissal in 626 days
626 days — above the median for Schedule A design patent cases in N.D. Illinois
Voluntarily dismissed: what the record does — and does not — tell us
Fed. R. Civ. Pro. 41(c)(2): voluntary dismissal of a counter-claim
The dismissal invokes Rule 41(c)(2), which governs voluntary dismissal of counter-claims and third-party claims — distinct from Rule 41(a) dismissal of original complaints. Here, counter-claimant MHMY Global Sell voluntarily dismissed its own counter and third-party claims. The basis of termination recorded is ‘voluntary dismissal,’ but the record does not specify prejudice status, leaving the legal finality of this dismissal uncertain from public documents alone.
Rule 41(c)(2) procedural exitWith or without prejudice? The public record is silent
A voluntary dismissal ‘with prejudice’ is a final adjudication on the merits and bars any future action on the same claims. A dismissal ‘without prejudice’ preserves the right to refile. The docket basis states only ‘voluntary dismissal’ — no prejudice qualifier is specified in the available public record. Practitioners should obtain the full docket entry or stipulation to determine finality before relying on this outcome for clearance or enforcement strategy.
Prejudice status: unconfirmedMHMY Global Sell: from defendant to counter-claimant
Most Schedule A defendants default or settle quietly. MHMY Global Sell took the unusual step of filing a counter-claim and third-party complaint, suggesting it contested the action on substantive grounds. Its subsequent voluntary dismissal of those claims may reflect a negotiated exit, a strategic withdrawal, or resource constraints — the public record does not clarify which. Other named defendants appear to have had no recorded legal representation.
Active counter-claimant withdrewDesign patent USD1012683S remains active post-dismissal
Because no merits ruling was issued, the validity and enforceability of USD1012683S have not been adjudicated. The patent survives this litigation intact and could be asserted again. Sellers of shelf brackets — particularly those operating on Amazon, eBay, or similar marketplaces — should treat this case as a signal that the patent holder is willing to litigate Schedule A actions and monitor for re-filing activity against the same or similar defendants.
Patent validity unresolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Yu Luo | Individual | Design patent holder asserting USD1012683S — ornamental shelf bracket designSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Organizations in Schedule A | Individual | Multiple e-commerce sellers across online marketplaces, including China-based entitiesSearch in Eureka ↗ |
| Co-Defendant | AAG Inc. | Company | Search in Eureka ↗ |
| Co-Defendant | Guangzhou Kobe Information Technology Co., Ltd | Company | Search in Eureka ↗ |
| Co-Defendant | LALAGOGO | Individual | Search in Eureka ↗ |
| Co-Defendant | MHMY Global Sell | Individual | Search in Eureka ↗ |
| Co-Defendant | Shieldsen | Individual | Search in Eureka ↗ |
| Co-Defendant | YMD Parts | Individual | Search in Eureka ↗ |
| Co-Defendant | HITOMEN | Individual | Search in Eureka ↗ |
| Co-Defendant | Panda Design | Individual | Search in Eureka ↗ |
| Co-Defendant | AOCAN | Individual | Search in Eureka ↗ |
| Co-Defendant | Others too numerous to list: VANCASTLE, Wildnut, ELSKER&HOME Store | Individual | Search in Eureka ↗ |
| Plaintiff counsel | Robert Michael Dewitty | Attorney | Counsel for Yu LuoSearch in Eureka ↗ |
| Plaintiff law firm | Dewitty And Associates, Chtd. | Law Firm | Representing Yu LuoSearch in Eureka ↗ |
| Presiding judge | Judge Mary M. Rowland | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice is procedurally atypical for a Schedule A case: it is counter-claimant MHMY Global Sell — not plaintiff Yu Luo — that filed the Rule 41(c)(2) voluntary dismissal of its own counter and third-party claims. This suggests the underlying dispute between Yu Luo and the defendants may have resolved separately, with MHMY’s counter-claim representing the last live claim to be formally closed. No merits finding was made on infringement or validity of USD1012683S.
USD1012683S — ornamental design for a shelf bracket
USD1012683S is a US design patent protecting the ornamental appearance of a shelf bracket — a ubiquitous home storage component sold widely on e-commerce platforms. Design patents cover the non-functional, aesthetic aspects of a product; they do not protect structural or mechanical features. The corrected application number US35/516108 situates this patent within the USPTO’s design patent prosecution track. Design patents in the home goods category have become a common enforcement vehicle in Schedule A litigation due to their relatively narrow claim scope and ease of visual comparison.
The shelf bracket market on Amazon and similar platforms is highly fragmented, with hundreds of sellers — many China-based — offering visually similar products. A design patent covering a specific bracket silhouette or configuration can generate broad Schedule A defendant lists with apparent visual similarity as the threshold. For competitors and marketplace sellers, the continued enforceability of USD1012683S post-dismissal means this patent remains a live commercial risk. Any seller whose bracket products share the ornamental profile of the patented design should conduct an FTO review before continuing to list.
Should your product team run an FTO against USD1012683S?
If your company sells, imports, or distributes shelf brackets — or adjacent home storage hardware — on US e-commerce platforms, USD1012683S is an active design patent with demonstrated enforcement history. Because no court has invalidated or narrowed this patent, its full claim scope remains intact. Product teams launching new bracket SKUs, and procurement teams sourcing from Chinese manufacturers, should treat this patent as a threshold clearance item before US market entry.
PatSnap Eureka’s FTO Search Agent allows R&D and legal teams to map the ornamental claim scope of USD1012683S against your specific product design, surface the closest prior art that could support a design-around or invalidity argument, and identify related design patent families held by Yu Luo or associated entities. Eureka can also monitor for new filings by the same plaintiff, giving your team early warning of Schedule A enforcement campaigns targeting your product category.
Run a freedom-to-operate analysis on USD1012683S to assess your product’s exposure
Run FTO in Eureka →Similar shelf bracket and home goods design patent cases in N.D. Illinois
Browse Schedule A design patent enforcement actions in the N.D. Illinois court involving home hardware and storage products, including comparable multi-defendant actions.
What this case signals for the shelf bracket and home hardware design patent landscape
Schedule A design patent enforcement in N.D. Illinois is a high-volume, high-risk channel for e-commerce sellers in the home hardware and storage category.
Schedule A tactics: volume enforcement with asymmetric leverage
Yu Luo’s approach — naming ten-plus sellers in a single Schedule A complaint — is a well-established enforcement model in N.D. Illinois. It places significant burden on small e-commerce sellers who lack US legal representation, often resulting in defaults or quiet settlements. Sellers in the shelf bracket and home storage category should audit their product listings against active design patents proactively.
Counter-claims in Schedule A cases are rare and tactically significant
MHMY Global Sell’s decision to file a counter-claim elevated this case above the typical Schedule A default posture. Companies facing Schedule A suits should evaluate whether filing a counter-claim — particularly for invalidity or inequitable conduct — creates negotiating leverage sufficient to drive a dismissal, as appears to have occurred here.
Luo v Partnerships — key questions answered
The case closed on 24 November 2025 via voluntary dismissal after 626 days. Counter-claimant MHMY Global Sell filed a Rule 41(c)(2) voluntary dismissal of its counter and third-party claims. The public record does not specify whether the dismissal was with or without prejudice, and no merits ruling was issued on infringement or validity of design patent USD1012683S.
Plaintiff Yu Luo asserted US design patent USD1012683S (application number US35/516108), which protects the ornamental design of a shelf bracket. Design patents protect the non-functional aesthetic appearance of a product and do not cover structural or functional features.
Rule 41(c)(2) governs voluntary dismissal of counter-claims and third-party claims, as distinct from dismissal of the original complaint. Here, MHMY Global Sell dismissed its own counter-claims. Without confirmation of prejudice status, defendants cannot assume they are fully insulated from future claims by the original plaintiff, Yu Luo, on the underlying infringement allegations.
Yes, USD1012683S remains an active and enforceable US design patent. Because the case ended without a merits ruling — no finding on infringement, validity, or enforceability — the patent’s claim scope is unaffected by this litigation. Sellers of shelf brackets on US e-commerce platforms should continue to treat this patent as a live clearance risk.
The public record does not disclose MHMY Global Sell’s specific grounds for its counter-claim or third-party complaint. Filing a counter-claim in a Schedule A case is atypical and may suggest the defendant had substantive invalidity or non-infringement arguments, or sought to use the counter-claim as negotiating leverage. MHMY’s subsequent voluntary dismissal of those claims suggests the dispute was resolved, though whether through settlement or strategic withdrawal is not confirmed by public filings.
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