Shenzhen City Sanhu Technology Co., Ltd. v. Lindsay Albanese et al.

Shenzhen City Sanhu Technology Co., Ltd., a Chinese consumer products company, initiated this patent infringement lawsuit against fashion stylist and entrepreneur Lindsay Albanese and her company, Hats On LLC, which operates under the trade name TopTote. Lindsay Albanese is the inventor and founder of the Lindsay Albanese brand, known for creating serviceable style products, with the TOPTOTE hat clip being her first patented invention. The defendants, Lindsay Albanese and Hats On LLC, are operating companies selling the accused product, the TOPTOTE hat clip, which is a device designed to carry and store hats.

The asserted patent in this litigation is U.S. Patent No. 10,413,047, which generally covers a hat holder device. Technically, the patent describes a hat holder that includes a first and second strap, each with ferromagnetic members at their ends, designed to be separably joined by magnetic attraction. A hook is coupled to the first strap, allowing for portable hat carrying and storage.

The case, initially filed in the Eastern District of New York (1:23-cv-07691), was transferred to the Central District of California (8:23-cv-02047) on November 1, 2023, after the New York court determined that California was the proper venue due to the defendants' business location and where the alleged infringing activities occurred. District Judge James V. Selna and Magistrate Judge John D. Early were assigned to the case in the Central District of California. The case concluded relatively quickly, being voluntarily dismissed without prejudice by the plaintiff on June 6, 2024, approximately 218 days after filing, which allows Shenzhen City Sanhu Technology Co., Ltd. the theoretical right to refile the claims in the future. The prompt dismissal suggests the parties may have reached an out-of-court agreement or the plaintiff re-evaluated its litigation strategy, though the public record does not specify the exact reasons. This case is notable for highlighting patent assertion in the consumer accessories market, particularly concerning a seemingly simple yet popular product like a hat holder. The plaintiff being a Chinese consumer products company and the relatively swift voluntary dismissal without prejudice could indicate evolving strategies in cross-border patent enforcement.

Shenzhen City Sanhu Technology Co., Ltd. v. Lindsay Albanese et al. (8:23-cv-02047) was a patent infringement case that originated in the Eastern District of New York before being transferred to the Central District of California and subsequently dismissed.

Here's a chronological overview of the key legal developments and outcome:

• Filing & Initial Pleadings:

  • 2023-10-16: Shenzhen City Sanhu Technology Co., Ltd. (Plaintiff) initially filed a patent infringement action in the U.S. District Court for the Eastern District of New York against Lindsay Albanese and Hats On LLC, operating as TopTote (Defendants), asserting infringement of U.S. Patent No. 10,413,047 ("Hat Holder").
  • The Eastern District of New York court issued an Order to Show Cause for improper venue, noting that the defendant's business and the alleged misconduct of contacting Amazon to claim infringement occurred in California, not New York.
  • 2023-10-25: The Plaintiff filed a response to the Order to Show Cause.

• Pre-trial Motions of Substance — Transfer:

  • 2023-10-30: An order was issued transferring the case from the Eastern District of New York to the Central District of California due to improper venue.
  • 2023-11-01: The case was officially filed in the U.S. District Court for the Central District of California under case number 8:23-cv-02047.

• Claim Construction (Markman) & Discovery Milestones:

  • The case was voluntarily dismissed before reaching the stages of claim construction (Markman) or significant discovery milestones. There were no rulings on infringement, validity, or claim construction.

• Trial Events, Verdict, and Post-Trial Motions:

  • No trial, verdict, or post-trial motions occurred as the case was dismissed at an early stage.

• Settlement, Dismissal, Judgment, or Appeal — Final Disposition:

  • 2024-06-06: The Plaintiff filed a notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i).
  • The case was voluntarily dismissed without prejudice, meaning Shenzhen City Sanhu Technology Co., Ltd. retains the right to refile the claims against the same defendants on the same patent in the future, subject to applicable statutes of limitations. This dismissal occurred 218 days after the case was filed in the Central District of California, well before any scheduling order deadlines or merits briefing.

• Parallel PTAB IPR/PGR Proceedings:

  • U.S. Patent No. 10,413,047 B2 has been subject to an Inter Partes Review (IPR) proceeding. An IPR AIA trial proceeding was filed before the Patent Trial and Appeal Board (PTAB) on 2025-02-04, identified as TRIAL NO: IPR2025-00346, with "KLIPSTA PTY LTD" listed as the opponent. The effective date for this IPR was 2024-12-19. There is no information indicating this IPR proceeding had any direct effect on the district court litigation, which was dismissed in June 2024, prior to the IPR's filing date.

The plaintiff, Shenzhen City Sanhu Technology Co., Ltd., was represented by the following counsel:

• Jiyuan Zhang

  • Role: Lead Counsel (appeared Pro Hac Vice)
  • Firm: J. Zhang And Associates, P.C.
  • Office Location: Not explicitly stated in the provided snippets, but likely based outside of the Central District of California given the pro hac vice admission.
  • Experience: Jiyuan Zhang represented Shenzhen City Sanhu Technology Co., Ltd. in the initial filing of this patent infringement case in the Eastern District of New York before its transfer.

• Steven L. Sugars

  • Role: Local Counsel
  • Firm: Steven L. Sugars, APC (based on general legal directory knowledge for local counsel in California, assuming Sugars has his own practice. Further search is needed to confirm the exact firm name and office location if a specific firm is not mentioned on the docket).
  • Office Location: Not explicitly stated in the provided snippets, but typically within the Central District of California for local counsel.
  • Experience: The docket entry only designates him as local counsel. Further information on his specific patent litigation experience is not available in the provided snippets.

The public docket for Shenzhen City Sanhu Technology Co., Ltd. v. Lindsay Albanese et al. (8:23-cv-02047) indicates that the case was voluntarily dismissed by the plaintiff on June 6, 2024, without prejudice. This dismissal occurred relatively early in the litigation, 218 days after filing and before any substantive court rulings.

A review of the available docket information from sources like Justia and PacerMonitor for the Central District of California case (8:23-cv-02047), as well as the transferred Eastern District of New York case (1:23-cv-07691), primarily details filings made by the plaintiff and orders related to the case transfer. These records do not explicitly list counsel of record for the defendants, Lindsay Albanese and Hats On LLC, in the district court patent infringement action.

Given the voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), which allows a plaintiff to dismiss an action without a court order before the defendant serves an answer or a motion for summary judgment, it is possible that the defendants did not formally appear through counsel in the Central District of California, or their appearance was limited and not prominently recorded in the readily available public docket summaries.

While a related Inter Partes Review (IPR2025-00346) concerning the patent-in-suit (US10413047) lists Benjamin E. Maskell of Maskell Law PLLC and Thomas Tatonetti of Tatonetti IP, Inc. as counsel for patent owner Lindsay Albanese, this is in the context of a PTAB proceeding and not the district court infringement case.

Therefore, based on the publicly available information, no counsel of record representing the defendant(s) in this specific patent infringement case (8:23-cv-02047) can be identified.