CAO Group, Inc. v. [Schedule A defendants]

I'll research this case before writing. Let me start with the core case metadata and patent.

Good foundation. Now let me verify the patent family, prior/parallel litigation, and any PTAB activity.

Let me dig into the parallel P&G and GuruNanda litigation, the patent family, and any PTAB challenges.

Case Overview and Background

The parties. The plaintiff, CAO Group, Inc., is a Utah operating company headquartered in Sandy/Salt Lake City, Utah, founded in 2000 by materials engineer Densen Cao, PhD. It develops and sells dental and medical devices — LED curing lights, dental lasers, and, most relevantly, the clinical-grade "Sheer White!" teeth-whitening strip line, which CAO sells through its own site and authorized dental distributors such as Henry Schein (CAO's own complaint language is quoted in the RPX litigation document at insight.rpxcorp.com/litigation_documents/15896825). CAO is therefore not an NPE/PAE: it practices the patent family in suit. The defendants are the familiar "Schedule A" cast — individuals, corporations, LLCs, and partnerships operating e-commerce storefronts (Amazon/Walmart/eBay-type sellers), named only in a sealed-then-unsealed exhibit and alleged to sell unauthorized whitening strips into the United States, including Illinois. The only individual defendant name that surfaced publicly on the docket is "Ceonam Direct," identified as Defendant No. 3 in CAO's August 8, 2025 notice of voluntary dismissal (Dkt. 35). The full Schedule A has not been reliably reported in any source I could verify.

The patent and accused technology. One utility patent is at issue: U.S. Patent No. 10,603,259 B2, "Peroxide gel compositions" (inventor Steven D. Jensen; assigned to CAO Group; application 15/488,293 filed April 2017; issued March 31, 2020; priority traced to a February 2006 filing) — see the PubChem patent record and the Unified Patents portal entry (portal.unifiedpatents.com/patents/patent/US-10603259-B2). In one sentence: it claims a dental bleaching device — a flexible, planar backing strip coated with a dried, "gelatinous, non-coalescent, visco-elastic" peroxide/solvent/thickener composition (polyethyloxazoline and/or PVP) that adheres to teeth, conforms to the dental arch, does not crack when flexed, and stays on the strip during use. The '259 is one member of a large continuation family sharing a substantively identical specification — U.S. 9,789,036 → 10,646,419 and 10,603,259 → 11,219,582 ('582, Jan. 11, 2022) → 11,826,444 → 11,826,445 — as CAO itself recites in its 2025 complaint against Ivoclar (E.D. Mich. No. 1:25-cv-01430). CAO also holds design patents D740,117, D655,163, and D655,165 covering strip外观, per Chinese-language TRO tracking sites (unverified). The accused products here are third-party/knock-off whitening strips sold online; because the case was sealed at filing and dismissed within four months, the specific accused SKUs were never publicly litigated, though the complaint's Exhibits 1–3 appear to be product-listing screenshots.

Posture, venue, and why it matters. Filed April 14, 2025 in the N.D. Ill. Eastern Division, randomly assigned to Judge Martha M. Pacold (Magistrate Judge Daniel P. McLaughlin designated), cause of action 35 U.S.C. § 271 (Dkt. 1–9). The case is a textbook example of the Schedule A "TRO model" colliding with a skeptical judge — and it lost. On April 21, 2025, Judge Pacold denied CAO's motion to file under seal, reasoning that CAO wanted a pre-judgment asset freeze before revealing defendants' identities, and held that Grupo Mexicano de Desarrollo v. Alliance Bond Fund (527 U.S. 308) and Zorro Productions v. Schedule A Defendants (N.D. Ill. 2023) bar that tactic; she struck the sealed complaint and ordered public filing (Dkt. 14). The TRO/asset-restraint/expedited-discovery motion was denied the next day (Dkt. 15), while alternative service by email under Rule 4(f)(3) was allowed (Dkt. 16). She then raised joinder concerns (Dkt. 13–14, 18) and gave CAO until May 29 to amend, warning that improperly joined defendants would be dismissed without prejudice (Dkt. 21) — the recurring Rule 20/§ 1400(b) problem for bundling unrelated foreign e-commerce sellers into one patent suit. After an amended complaint (Dkt. 23) and partial expedited discovery (Dkt. 27, 29–30), CAO voluntarily dismissed, and on August 11, 2025 the court terminated the case, noting the dismissal took effect without court intervention under Rule 41(a)(1)(A)(i) and citing Waetzig v. Halliburton Energy Services, 145 S. Ct. 690 (2025) (Dkt. 37). Full docket: dockets.justia.com/docket/illinois/ilndce/1:2025cv04054/476528.

Three things make this file interesting. First, market context and end-of-term timing: the '259 traces to a 2006 priority date and, per Unified Patents, carries an expiration of roughly February 7–8, 2026 — meaning this 2025 campaign is late-life enforcement of a patent whose term is essentially running out, which explains the aggressive, broad-brush

I'll research this case systematically, starting with the docket and patent basics.

Now let me pull the actual docket and the asserted patent details.

Let me check CourtListener for the full docket and search PTAB proceedings on the '259 patent family.

CAO Group, Inc. v. Schedule A Defendants, No. 1:25-cv-04054 (N.D. Ill.)

Bottom line

This was a short-lived, unopposed Schedule A e-commerce enforcement action that never got past the pleading/serve-and-dismiss stage. Filed 2025-04-14 and terminated 2025-08-11 — roughly four months later — by plaintiff's own notice of voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i). There was no answer, no counterclaim, no motion to dismiss or transfer, no stay motion, no Markman proceeding, no summary judgment, no trial, no verdict, no post-trial motion, and no appeal. The only substantive rulings were (1) denial of the motion to seal, (2) denial of the TRO/asset-freeze/expedited-discovery motion, (3) grant of alternative electronic service under Rule 4(f)(3), (4) a joinder warning, and (5) a partial grant of expedited third-party discovery. I found no PTAB IPR or PGR on U.S. Patent No. 10,603,259.

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The patent

Strategic note on term: the family claims 2006-02-08 priority, and the '419 sibling is recorded with a 2026-02-07 expiration date (and is subject to a terminal disclaimer). If the '259 carries the same terminal disclaimer/term, its enforceable life runs out around February 2026 — which materially explains the compressed, damages-oriented (rather than injunction-oriented) posture of CAO's recent campaigns. (Inference from the patent record — confirm against the '259 terminal disclaimer and USPTO Patent Center.)

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Chronological developments

1. Filing and initial pleadings (April–May 2025)

I'll research the docket and counsel of record for this case.

Now let me identify each attorney's firm and role.

Plaintiff's Counsel of Record — CAO Group, Inc. v. Schedule A Defendants, No. 1:25-cv-04054 (N.D. Ill.)

Bottom line: Three attorney appearances were filed for CAO Group in this case. The filing/lead role is held by Nicholas S. Lee of Dickinson Wright PLLC (Chicago), working with Sameeul Haque of Haque III Legal Practice, LLC (Chicago), and Briana Y. Hammons, a Dickinson Wright associate who appeared later in the case. The pair Lee + Haque is a recurring two-firm Schedule A team that has appeared together for CAO Group and other brand owners in numerous N.D. Ill. e-commerce infringement suits; the docket does not formally designate "lead" versus "local" counsel (N.D. Ill. has no local-counsel requirement for bar members, and all three are Illinois-licensed), but Lee is functionally lead.

1. Nicholas S. Lee — lead counsel (functional), first-filed appearance

• Appearance: Dkt. 8, filed 4/14/2025 (same day as the complaint). Signed the amended complaints (Dkt. 20, 5/8/2025; Dkt. 22, 5/29/2025), the memorandum addressing the Court's joinder/asset-restraint concerns (5/5/2025), the expedited-discovery motion (Dkt. 27, 6/11/2025), and status reports.
• Firm / office: Dickinson Wright PLLC, 71 S. Wacker Dr., Suite 2700, Chicago, IL 60606. (Registered patent attorney, USPTO Reg. No. 54,262; USPTO practitioner records list Dickinson Wright PLLC as his firm as of late 2026.)
• Experience: ~20 years of IP litigation, counseling and procurement; formerly a shareholder at Bishop Diehl & Lee, Ltd. (Schaumburg, IL), which represented CAO Group in its earlier Schedule A campaigns in N.D. Ill. (e.g., No. 1:24-cv-01211 before Judge Durkin, where the '259, '419, '582, '444 and '445 patents were asserted). He has an unusually deep docket of Schedule A / e-commerce TRO cases in N.D. Ill. and elsewhere (200+ federal matters in practitioner databases), including Wiesner Healthcare Innovation v. Schedule A, Bright Hand LLC v. Schedule A, and Intake Breathing Technology v. Regenexo. B.S. biochemistry/chemistry (Purdue); J.D. DePaul (2004); Illinois Super Lawyers "Rising Star" 2012–2015.

2. Sameeul Haque — co-counsel / second chair (separate firm)

• Appearance: Dkt. 9, filed 4/14/2025 (docketed 4/15/2025). Also filed the 7/1/2025 status report.
• Firm / office: Haque III Legal Practice, LLC, 205 N. Michigan Ave., Suite 810, Chicago, IL 60601.
• Experience: Illinois-licensed since 2019 (Chicago-Kent J.D.); selected to Illinois Rising Stars 2026–2027 for IP litigation. Formerly with Bishop Diehl & Lee, where he was part of the CAO Group team and co-appeared with Lee on a long string of N.D. Ill. Schedule A patent cases (Bright Hand, Intake Breathing, Wiesner Healthcare, Guannian Group v. IP Power Holdings). He appears to be the "second signature" firm in the Lee/Haque pairing rather than an independent lead.

3. Briana Y. Hammons — associate, supporting role

• Appearance: 7/1/2025 (attorney appearance entered the same day as the second status report).
• Firm / office: Dickinson Wright PLLC, Chicago office.
• Experience: Associate in the firm's commercial and business litigation group; J.D. Temple University Beasley School of Law (2024), B.A. Howard University (2017). No identified prior patent-litigation track record — she is a 2024 graduate and appears to be a junior team member. Treat any "patent experience" characterization for her as unsupported.

What is not on the docket

• No in-house counsel appearance. CAO Group (a Utah corporation; founder/CEO Dr. Densen Cao) filed its LR 3.2 Notice of Affiliates but no in-house attorney has entered an appearance.
• No pro hac vice motions and no separate local-counsel firm — all three lawyers are members of the N.D. Ill. bar.
• No fourth plaintiff-side attorney appears in the docket sources reviewed (docket mirrors of the CM/ECF sheet through the 8/11/2025 termination). The sealing dispute in this case (Dkt. 4 motion denied, Dkt. 14, 4/21/2025) concerned the complaint and Schedule A, not counsel identity — appearances were public from day one.
• Brian E. Lahti (who filed CAO's C.D. Cal. suit against GuruNanda, No. 8:25-cv-02074) is not counsel in this case.

Verification caveats

• I could not pull the PACER docket directly; entries above are drawn from docket mirrors (TRO101, kjtro.com, Justia, UniCourt) that reproduce the CM/ECF text and document numbers, plus firm bios, Super Lawyers, and USPTO practitioner records. Document numbers for the two later events (Hammons appearance; Dkt. 37 notice of voluntary dismissal) should be confirmed on PACER before being cited in a filing.
• Lee's firm affiliation at the exact moment of the 4/14/2025 filing deserves a caveat: aggregators list Dickinson Wright as plaintiff's firm for this case, and his USPTO/firm records now show Dickinson Wright, but in 2024–early 2025 he appeared under his own name/solo address (Vernon Hills, IL) in at least one N.D. Ill. case, and a February 2025 order noted he had "apparently switched law firms." The appearance form itself (Dkt. 8) is the controlling record.
• The case was terminated 8/11/2025 on CAO's notice of voluntary dismissal as to the remaining defendant (Dkt. 36/37; Minute entry invoking Rule 41(a)(1)(A)(i) and Waetzig v. Halliburton). CAO has since refiled Schedule A actions through the same Lee/Haque team (e.g., N.D. Ill. Nos. 1:25-cv-12503 and 1:25-cv-14512), which is where continued activity by this counsel group should be tracked.

I'll research this case and its docket to identify defense counsel.

Bottom line

No defense counsel of record appears in the docket for No. 1:25-cv-04054. Every attorney appearance entered in this case was filed on behalf of the plaintiff, CAO Group, Inc. No Schedule A defendant — named or Doe‑style — filed an appearance, answer, motion, or Rule 12/§ 101 challenge before the case was terminated. This is unfortunately a "no answer exists" situation rather than a research gap on my end, and I'll show the basis for that conclusion and where residual uncertainty lies.

What the docket shows

From the Justia docket mirror and TRO-tracker mirrors of the N.D. Ill. CM/ECF sheet (case assigned to Judge Martha M. Pacold; Mag. J. Daniel P. McLaughlin):

Sources: Justia docket, https://dockets.justia.com/docket/illinois/ilndce/1:2025cv04054/476528; mirrors at https://kjtro.com/case/ilnd/1-25-cv-04054.html and https://selleraegis.com/causeDetail.html?slug=1-25-cv-4054-1fJ7Pkg.

The procedural posture explains why no defense counsel appeared: the court refused the asset freeze and refused to keep the complaint sealed, so plaintiff lost the leverage that normally forces Schedule A defendants to retain counsel and settle quickly. The case then died by plaintiff's own Rule 41(a)(1) notice roughly four months after filing — before any defendant had an obligation to respond.

Plaintiff's counsel of record (for contrast / conflict-checking)

Note: CAO Group used a different firm in the two 2024 predecessor suits (24-cv-00901 and 24-cv-01211) and switched to Dickinson Wright for the 2025 filings — reported by the TRO-tracking press, e.g. https://maijiazhichi.com/archives/57499.

Related-case defense counsel (NOT counsel in 1:25-cv-04054)

Because the caption here is a Schedule A placeholder, the attorneys most likely to surface if CAO re-files against the same storefronts are those who appeared for whitening-strip defendants in the 2024 companion cases. I flag these only as context — neither is shown as having appeared in 25-cv-04054:

• Steven G. Kalberg — appeared 04/03/2024 (Dkt. 28) for defendants BYS Technology, DEEPSOUND, Carbonline, Moose Store, ACU, and BLUE in CAO Group, Inc. v. Schedule A, No. 1:24-cv-01211 (N.D. Ill.) (https://dockets.justia.com/docket/illinois/ilndce/1:2024cv01211/[455246](/patent/455246)). Chicago-area IP attorney; regular defense-side appearance in N.D. Ill. Schedule A matters. (Firm affiliation as of 2026 not verified in my sources — confirm before cite.)
• Adam Edward Urbanczyk — appeared 05/28/2024 (Dkt. 78) for defendants Fairywill, IMOSTY Whitening US, beapoint, fairywill_global, tstarlight, and wendydy in the same 24-cv-01211 case (https://tro101.com/cases/ilnd-1-2024-cv-01211). Chicago sole/boutique practitioner who handles a high volume of Schedule A defense appearances.

Caveats you should carry forward

1. Free-source docket coverage is not exhaustive. The mirrors above render 32–37 entries; a handful of document numbers (roughly 26, 28–32, 34–36) are not itemized in the free feeds. I could not individually verify each of those slots. A PACER pull of the full docket (or a CourtListener RECAP check) is the only way to close that gap definitively; if a defense appearance is hiding, it would be in one of those entries. Nothing in the docket narrative — the court's 06/24 and 07/28 orders directing plaintiff to file status reports, the absence of any joint status report signed by defense counsel, and the termination by unilateral notice — is consistent with a defense appearance having occurred.
2. Sealing. The complaint, Schedule A, and Notice of Claims were originally filed under seal (Dkts. 5–6) and were unsealed only after Judge Pacold's 04/21 and 05/01 orders. Any sealed filing would not be visible in free mirrors, but sealed appearances are not a thing — appearances are docketed publicly.
3. Follow-on litigation to watch. CAO Group filed a further Schedule A case in the same district in July 2025, No. 1:25-cv-08205, with Lee appearing for plaintiff on 07/18/2025. If your real question is "who is defending the whitening-strip defendants now," that docket — and any 2026 re-filing — is where appearances would be found.

If you want, I can next pull the full unsealed Schedule A from Dkt. 23 (Exhibit 1) to map defendant storefronts, or trace the 24-cv-00901/01211 default-judgment outcomes that the press reports value in the tens of millions — both are directly relevant to whether a re-filing is likely.