Shandong Yunxiang Century Intelligent Technology Co. v. Huang

Background

Shandong Yunxiang Century Intelligent Technology Co., Ltd. and Shandong Jiuhui Information Technology Co., Ltd., which the opinion collectively calls “Shandong,” brought the case concerning U.S. Patent No. D962,680S, a design patent covering an “ornamental design for a gel seat cushion.” The opinion states that both companies are Chinese corporations with their principal places of business in China. Yannan Huang, who resides in China, is listed as the patent’s applicant and inventor.

Shandong alleged that Huang asserted an infringement claim against its seat cushions through Amazon. Amazon then removed Shandong Yunxiang’s seat-cushion listing, and the product remained unavailable on Amazon’s platform. Shandong alleged that Huang had not purchased or otherwise obtained the products before complaining to Amazon and had not reasonably investigated or compared them with the patent.

Shandong asserted five claims: declaratory judgment of noninfringement, invalidity, and unenforceability of the patent; unfair competition; and tortious interference.

Motion and analysis

Huang moved to dismiss under Federal Rule of Civil Procedure 12(b)(2) for lack of personal jurisdiction, Rule 12(b)(3) for improper venue, and Rule 12(b)(6) for failure to state a claim.

The court first considered personal jurisdiction. General jurisdiction allows a court to hear any claim against a defendant, while specific jurisdiction depends on a connection between the defendant’s forum-related conduct and the claims. The court held that it did not have general jurisdiction over Huang.

The court also held that Shandong had not established specific jurisdiction. Shandong relied on Huang’s use of Amazon’s intellectual-property enforcement system and argued that this conduct was directed at Shandong’s U.S.-based business operations and foreseeably caused harm in the United States. The court found those allegations insufficient to show that Huang purposefully directed activities at California. It also stated that Amazon was not a California resident and that the alleged harm did not support jurisdiction because neither Shandong company was a California resident.

Disposition

The court granted Huang’s motion to dismiss. Although the court stated that amendment appeared unlikely to establish personal jurisdiction, it granted Shandong leave to amend out of caution. The amendment was permitted solely to add new jurisdictional allegations and had to be filed within 21 days of the order. The opinion does not separately state a disposition on Huang’s improper-venue or failure-to-state-a-claim arguments after ruling that personal jurisdiction was lacking.

The court continued the case-management conference from November 18, 2025, to January 27, 2026, at 2:00 p.m.