REN v. AilunUS
2:25-cv-00730
| W.D. Pa. | Jul 7, 2025Background
- Plaintiffs Quan Ren and Kui Cao, residents of China, allege patent infringement related to a “watch cover” against 51 defendants, mostly foreign entities identified in Schedule A.
- Defendants are accused of manufacturing, importing, and selling infringing products in the US, including Pennsylvania, primarily via online storefronts.
- Plaintiffs filed motions seeking a temporary restraining order (TRO), preliminary injunction, expedited discovery, and permission to serve defendants via email or electronic publication.
- The defendants are alleged to have online operations, making products available to US (and possibly Pennsylvania) customers, but Plaintiffs' proof of Pennsylvania-specific sales is equivocal.
- The court’s analysis centers on whether it has personal jurisdiction over the defendants and whether joinder of all 51 unrelated defendants is proper.
- The court denies the TRO and injunction motions, finding deficiencies in proof of jurisdiction and concerns about improper joinder. Plaintiffs are given leave to amend or show cause why the case should not be severed or dismissed for misjoinder.
Issues
| Issue | Plaintiffs' Argument | Defendants' Argument | Held |
|---|---|---|---|
| Personal Jurisdiction | Online storefronts, interactive websites, and potential sales | Mere operation of online stores not enough; lacking | Plaintiffs failed to show likely jurisdiction over |
| (including, possibly, into PA) sufficient for jurisdiction | evidence of specific PA-targeted sales | all defendants. | |
| Rule 4(k)(2) Nationwide Jurisdiction | Defendants not subject to jurisdiction of any single state | Defendants likely subject to at least one US forum | Plaintiffs failed to show defendants are outside |
| and sufficient US-wide contacts | all states’ jurisdiction; TRO inappropriate | ||
| Joinder of Multiple Defendants | Defendants’ similar behavior and types of alleged infringement | Independent acts by unrelated defendants do not | Allegations of interconnectedness are conclusory; |
| warrants collective suit | justify joinder | joinder is improper | |
| TRO/Preliminary Injunction | Patent valid, infringement ongoing, irreparable harm presumed | Relief would overly harm defendants' business, | TRO/Prelim. injunction denied; equities and merits |
| Asset freeze needed due to risks of offshoring | lack of info on proportion of infringing products | do not support remedy on this record |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts rule for personal jurisdiction).
- Daimler AG v. Bauman, 571 U.S. 117 (limits of general jurisdiction for foreign corporate defendants).
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (paradigm forums for general jurisdiction).
- Toys “R” Us, Inc. v. Step Two, S.A., 318 F.3d 446 (online sales insufficient by themselves for personal jurisdiction).
- K.A. ex rel. Ayers v. Pocono Mountain Sch. Dist., 710 F.3d 99 (four-factor test for preliminary injunction).
- Kos Pharms., Inc. v. Andrx Corp., 369 F.3d 700 (preliminary injunction is an extraordinary remedy).