Guangzhou Liyuan Technology Co Ltd v. Arthur Chao-Chung Wu

• Court: District Court, W.D. Washington
• Decided: January 30, 2026
• Docket: 2:26-cv-00157
• Status: Unknown

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 GUANGZHOU LIYUAN TECHNOLOGY CASE NO. 2:26-cv-00157-JHC 8 CO LTD, Plaintiff, ORDER 9 v. 10 ARTHUR CHAO-CHUNG WU, 11 Defendant. 12

13 I 14 INTRODUCTION 15 This matter comes before the court on Plaintiff’s Emergency Motion for Temporary 16 Restraining Order and Preliminary Injunction. Dkt. # 5. Plaintiff asks the Court to enjoin 17 Defendant from enforcing U.S. Patent No. 12,281,764 B2, which has led to the removal of 18 Plaintiff’s products from Amazon.com. Id. at 7. 19 For the reasons below, the Court DENIES Plaintiff’s motion. 20 II 21 BACKGROUND 22 This matter concerns patent enforcement of U.S. Patent No. 12,281,764 B2 (“Patent 23 ’764”), which Defendant owns. Dkt. # 5 at 3-4. Patent ’764 is for a “convertible light device.” 24 1 Id. Plaintiff is a retailer of camping string lights and primarily serves the U.S. market through 2 Amazon.com (“Amazon”). Id. On January 14, 2026, Plaintiff received a notice from Amazon 3 that their products would be delisted due to Defendant’s complaint of patent infringement. Id.

4 Amazon provided an internal appeal of this decision, and Plaintiff’s efforts with such an appeal 5 have failed. Id. 6 Plaintiff filed his complaint on January 15, 2026, and this motion on January 30, 2026. 7 Dkt. ## 1, 5. For now, there is no attorney of record for Defendant. See generally Dkt. # 5 at 36. 8 Plaintiff’s attorney certifies that they have attempted to provide notice to Defendant’s attorney; 9 however, at this time, it is unclear if that was received. Id. 10 III DISCUSSION 11 A. Legal Standard 12 To obtain a temporary restraining order (TRO), a plaintiff must show that (1) they are 13 “likely to succeed on the merits”; (2) they are “likely to suffer irreparable harm in the absence 14 of” a TRO; (3) “the balance of equities tips in [their] favor”; and (4) a TRO “is in the public 15 interest.” Stormans, Inc. v. Selecky, 586 F.3d 1109, 1127 (9th Cir. 2009) (quoting Winter v. Nat. 16 Res. Def. Council, Inc., 555 U.S. 7, 20 (2008)) (called the Winter factors); see also Amazon.com, 17 Inc. v. Barnesandnoble.com, Inc., 239 F.3d 1343, 1350 (Fed.Cir.2001). The Ninth Circuit 18 employs a “sliding scale” approach, under which the four elements are balanced “so that a 19 stronger showing of one element may offset a weaker showing of another.” All. for the Wild 20 Rockies v. Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011). The Federal Circuit has suggested, 21 “[o]ur case law and logic both require that a movant cannot be granted a preliminary injunction 22 23 24 1 unless it establishes both of the first two factors, i.e., likelihood of success on the merits and 2 irreparable harm.” Amazon.com, Inc., 239 F.3d at 1350.1 3 In the context of a TRO, “monetary injury is not normally considered irreparable[.]” hiQ 4 Labs, Inc. v. LinkedIn Corp., 31 F.4th 1180, 1188 (9th Cir. 2022) (citation modified); see also 5 Sampson v. Murray, 415 U.S. 61, 90 (1974) (“The possibility that adequate compensatory or 6 other corrective relief will be available at a later date . . . weighs heavily against a claim of 7 irreparable harm.”). But “[r]eputational harm and loss of goodwill can be irreparable harm . . . 8 [as] can threatened loss of prospective customers.” Beyond Blond Prods., LLC, v. Heldman, 479 9 F. Supp. 3d 874, 888 (C.D. Cal. 2020). 10 Finally, “courts have recognized very few circumstances justifying the issuance of an ex 11 parte TRO.” Reno Air Racing Ass’n., Inc. v. McCord, 452 F.3d 1126, 1131 (9th Cir. 2006); see 12 also LCR 65(b)(1) (issuance of TRO without notice disfavored).

13 B. Application to Plaintiff’s motion for TRO 14 Plaintiff does not show a likelihood of success on the merits. “[A] patent is presumed 15 valid, and proof of its invalidity requires ‘clear and convincing’ evidence. Intel Corp. v. U.S. 16 Int'l Trade Comm’n, 946 F.2d 821, 829 (Fed. Cir. 1991). This presumption of validity exists 17 “during preliminary injunction proceedings as at other stages of litigation.” Titan Tire Corp. v. 18 Case New Holland, Inc., 566 F.3d 1372, 1377 (Fed. Cir. 2009). 19 At this preliminary stage, no such clear and convincing evidence has been presented. The 20 motion includes hundreds of pages of exhibits, but to the extent that this evidence shows 21 anything it is only that there is a dispute over if Patent ’764’s construction is overbroad. 22

23 1 The Court is guided by the law of the United States Court of Appeals for the Federal Circuit when a preliminary injunction rests on substantive patent law issues. Hybritech Inc. v. Abbott Lab’ys, 24 849 F.2d 1446, 1451 n.12 (Fed. Cir. 1988). 1 Plaintiffs misunderstand their burden. See Dkt. #5 at 11, 21 (“Plaintiff need only raise a 2 substantial question of validity sufficient to defeat Defendant’s showing of likely success on the 3 merits,” citing cases in which it was the patent holder moving for a preliminary injunction). As 4 ||moving parties, it 1s Plaintiff, not Defendant, who must prove a likelihood of success on the 5 || merits and with the present showing that has not been done. See Reebok Int’l Ltd. v. J. Baker, 6 32 F.3d 1552, 1555 (Fed.Cir.1994) (“The burden is always on the movant to show 7 || entitlement to a preliminary injunction.”). Plaintiffs infringement argument fails for the same 8 reason. See Dkt. #5 at 12 (“Defendant cannot establish a likelihood of success and, at minimum, 9 serious questions exist as to infringement.”’). 10 To the second Winter factor, the primary harm alleged is mostly monetary. See Dkt. #5 11 at 38-32. Regarding Plaintiff's speculations as to a lowered market placement and loss of 12 customers due to the de-listing, is unclear that this could not be calculated as monetary damages. 13 Given the foregoing, the Court need not address the other Winter factors. See Winter, 14. ||555 US. at 20; All. for the Wild Rockies, 632 F.3d at 1135 (Winter requires a plaintiff to make a 15 showing on all of the Winter factors). 16 IV CONCLUSION 17 is For the above reasons, the Court DENIES the motion.

19 Dated this 30th day of January, 2026.

20 21 Joke Chur John H. Chun 22 United States District Judge 23 24