Yiwu Jieya E-Commerce Co Ltd v. Xu

CourtDistrict Court, W.D. Washington
DecidedSeptember 19, 2025
Docket2:25-cv-01595
StatusUnknown

This text of Yiwu Jieya E-Commerce Co Ltd v. Xu (Yiwu Jieya E-Commerce Co Ltd v. Xu) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Yiwu Jieya E-Commerce Co Ltd v. Xu, (W.D. Wash. 2025).

Opinion

1 2 3 4

5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 YIWU JIEYA E−COMMERCE CO. LTD., CASE NO. 2:25-cv-01595-LK 11 Plaintiff, ORDER GRANTING MOTION 12 v. FOR A TEMPORARY RESTRAINING ORDER 13 LIANG XU et al., 14 Defendants. 15

16 This matter comes before the Court on Plaintiff Yiwu Jieya E-Commerce Co. Ltd.’s Motion 17 for Entry of Temporary Restraining Order. Dkt. No. 15. Plaintiff seeks an order requiring 18 Defendants Liang Xu and JUDYBRIDAL to withdraw their patent infringement complaints to 19 Amazon and refrain from submitting further complaints about the same patent. Dkt. No. 15-2 at 20 1–2. Defendants oppose the motion. Dkt. No. 23. For the reasons set forth below, the Court grants 21 the motion. 22 I. BACKGROUND 23 Plaintiff operates a storefront on the Amazon.com marketplace through which it sells 24 various consumer products, including the rotating desk organizers at issue in this case. Dkt. No. 1 15 at 1. On August 6, 2025, “Amazon notified Plaintiff that a patent infringement complaint had 2 been filed, identifying the rights owner as ‘JUDYBRIDAL.’” Dkt. No. 14 at 8; see also Dkt. No. 3 14-8 (notification from Amazon of the complaint). That complaint alleged that Plaintiff’s rotating 4 desk organizers infringe U.S. Patent No. 12,274,337 B2 (the “’337 Patent”). Dkt. No. 14 at 2–3;

5 see also Dkt. No. 14-2 (the ’337 Patent). Plaintiff’s desk organizers all share the same design, 6 structure, and features, but each one is assigned a distinct Amazon Standard Identification Number 7 (“ASIN”) based on its color. Dkt. No. 14 at 5. Plaintiff contends that “Defendant Liang Xu is listed 8 as the inventor and assignee of [the ’337 Patent]” but “Amazon’s infringement notice identified 9 “JUDYBRIDAL” as the “rights owner of the ’337 Patent.” Id. at 3–4. 10 The same day Amazon notified Plaintiff of the complaint, it removed the accused products 11 from Plaintiff’s storefront, and the products have remained removed. Id. at 8. Plaintiff sought 12 reinstatement of its products through Amazon’s internal appeal process—including by filing 13 appeals on August 8, 22, and 29—but its efforts were unsuccessful. Dkt. No. 15 at 15.1 14 Meanwhile, on August 20, 2025, Plaintiff filed a complaint with this Court. Dkt. No. 1. On

15 September 9, Plaintiff filed an amended complaint, Dkt. No. 14, and this motion for a TRO, Dkt. 16 No. 15. The amended complaint asserts claims for (1) declaratory judgment of patent invalidity 17 and unenforceability, (2) declaratory judgment of non-infringement, (3) tortious interference with 18 contractual relations, (4) violation of the Washington Patent Troll Prevention Act, (“PTPA”), 19 Section 19.350 et seq. of the Revised Code of Washington, (5) violation of the Washington 20 Consumer Protection Act, (“CPA”), Section 19.86 et seq. of the Revised Code of Washington, 21 1 Plaintiff contends that the takedown notice “warn[ed] that violations remain for 180 days and may result in account 22 deactivation,” Dkt. No. 24 at 3, but its deactivation contention is not supported by the current record. The takedown notice states that “[l]eaving this or other policy violations unaddressed may result in account deactivation.” Dkt. No. 23 14-8 at 3 (emphasis added). The parties’ briefs do not address whether an account could be deactivated if a seller unsuccessfully contests a complaint. Amazon’s “Account health FAQ” page states generally that when there are issues, Amazon “may take action on [the seller’s] account” and that such actions “vary and may include, but are not limited 24 to, listing or account deactivation.” Dkt. No. 15-10 at 3–4. 1 (6) “Attempted Monopolization (15 U.S.C. § 2) Walker Process Sherman Act Violation,” and 2 (7) “Sham Enforcement/Anticompetitive Conduct.” Dkt. No. 14 at 9–17 (citation modified). The 3 complaint requests, among other relief, an order declaring that the ’337 Patent is invalid and 4 unenforceable, declaring that the “Accused Products do not infringe any valid and enforceable

5 claim of the ’337 Patent,” finding that Defendants violated the statutes listed above, and awarding 6 injunctive and monetary relief. Id. at 17–19. On September 5, 2025, Plaintiff’s counsel requested 7 that Defendants withdraw their Amazon complaint, but “Defendants nevertheless proceeded, on 8 September 8, 2025, to file an additional complaint targeting another identical product of 9 Plaintiff[.]” Dkt. No. 15 at 2; see also Dkt. No. 15-13 (September 9, 2025 notification from 10 Amazon of the additional complaint).2 11 On September 10, the Court issued an order stating that Plaintiff had not shown that it was 12 entitled to emergency relief without giving Defendants an opportunity to respond, and thus ordered 13 Defendants to respond by September 15, 2025. Dkt. No. 20. Defendants filed a timely response, 14 Dkt. No. 23, and Plaintiff filed a reply, Dkt. No. 24.

15 II. DISCUSSION 16 A. Legal Standard 17 Federal Rule of Civil Procedure 65 empowers the court to issue a temporary restraining 18 order (“TRO”). Fed. R. Civ. P. 65(b). Like a preliminary injunction, a TRO is “an extraordinary 19 remedy never awarded as of right.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 24 (2008); 20 see also Washington v. Trump, 847 F.3d 1151, 1159 n.3 (9th Cir. 2017) (the standards applicable 21 to TROs and preliminary injunctions are “substantially identical”). The Court will not 22 “mechanically” grant an injunction for every violation of law. Weinberger v. Romero-Barcelo, 456 23

2 The products at issue are ASINs B0C5M4FXD3, B0C8C6ZFXW, B0CXM6G39D, B0CJ4VR1DK, B0C58QHVHZ, 24 B0C58QSJPV, B0DG8L177D, and B0C58MCR4C (collectively, the “Accused Products”). Dkt. No. 15 at 1–2. 1 U.S. 305, 313 (1982). Instead, plaintiffs seeking a TRO must establish that (1) they are “likely to 2 succeed on the merits,” (2) they are “likely to suffer irreparable harm in the absence of preliminary 3 relief,” (3) “the balance of equities tips in [their] favor,” and (4) “an injunction is in the public 4 interest.” Winter, 555 U.S. at 20. The mere “possibility” of irreparable harm is insufficient; instead,

5 the moving party must “demonstrate that irreparable injury is likely in the absence of an 6 injunction.” Id. at 22. 7 The Ninth Circuit employs a “sliding scale” approach, under which the four elements are 8 balanced “so that a stronger showing of one element may offset a weaker showing of another.” 9 All. for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011). For example, “serious 10 questions going to the merits and a balance of hardships that tips sharply towards the plaintiff can 11 support issuance of a [TRO], so long as the plaintiff also shows that there is a likelihood of 12 irreparable injury and that the injunction is in the public interest.” Id. at 1135 (citation modified). 13 The moving party bears the burden of persuasion and must make a clear showing that it is entitled 14 to such relief. Winter, 555 U.S. at 22.

15 B. Plaintiff is Entitled to a Temporary Restraining Order 16 In their response brief, Defendants contest only the irreparable harm element. See generally 17 Dkt. No. 23. Still, the Court considers whether Plaintiff has met its burden on all four elements. 18 1.

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Yiwu Jieya E-Commerce Co Ltd v. Xu, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yiwu-jieya-e-commerce-co-ltd-v-xu-wawd-2025.