Huzhou Xinju Electronic Commerce Co., Ltd. v. Semisilicon Technology Corp.
- Nathanael Cousins
- 5:26-cv-08217
- U.S. District Court · District of Minnesota
- 2
In Huzhou Xinju Electronic Commerce Co. v. Semisilicon Technology Corp., Judge Cousins denied Xinju's request to immediately block Semisilicon from pursuing patent complaints against Xinju on Amazon.
Online sellers and importers who face patent-based takedown complaints through Amazon's APEX enforcement process may be interested in this ruling, as it shows the difficulty of obtaining emergency court relief to block such complaints while a declaratory judgment case is pending, particularly when the patent holder has filed its own infringement suit elsewhere.
What happened
This case involves Huzhou Xinju Electronic Commerce Co., Ltd. ('Xinju'), which sells LED backlight strip products on Amazon under the Ailofy brand. Xinju filed suit in the Northern District of California seeking a court declaration that its products do not infringe a patent held by Semisilicon Technology Corp. ('Semisilicon'). The dispute stems from Semisilicon's complaints filed through Amazon's patent enforcement process, which led to actions against Xinju's products. Notably, Semisilicon had filed its own patent infringement lawsuit against Xinju in a Texas federal court six days before Xinju filed this California case.
Xinju asked the court to immediately order Semisilicon to withdraw its Amazon patent complaint and to stop filing further takedown requests based on the patent, while the case proceeds. To get this kind of emergency relief — called a temporary restraining order — a party must clearly show: a likelihood of winning on the merits of the case, a likelihood of suffering irreparable (serious, non-compensable) harm without the order, that the balance of hardships favors the requesting party, and that granting the order serves the public interest. All four factors must be demonstrated.
Chief United States Magistrate Judge Nathanael M. Cousins denied Xinju's motion for a temporary restraining order. The court found that Xinju had not clearly shown it was likely to succeed on any of the required factors. The court also noted that Semisilicon had filed a motion to dismiss or transfer the California case, raising significant questions about whether this court has authority over Semisilicon and whether the Texas case — filed first — should take priority. The denial means Semisilicon may continue its Amazon-related patent enforcement activities while the litigation proceeds.
The detailed version
- Huzhou Xinju Electronic Commerce Co., Ltd. v. Semisilicon Technology Corp. · No. 5:26-cv-08217
- Nathanael M. Cousins
- Aug. 26, 2026
Background
Plaintiff Huzhou Xinju Electronic Commerce Co., Ltd. ('Xinju') filed this action in the Northern District of California seeking a declaratory judgment — a court ruling establishing legal rights before a full dispute plays out — that its Ailofy TV LED Backlight Strip products do not infringe U.S. Patent No. 8,884,546 (the '546 Patent'), held by Defendant Semisilicon Technology Corp. ('Semisilicon').
The conflict originates in Amazon Patent Express Evaluation ('APEX') proceedings, an Amazon-administered process through which patent holders can file infringement complaints against sellers. Semisilicon used APEX to file complaints concerning Xinju's LED backlight products. Six days before Xinju filed this declaratory judgment action, Semisilicon filed its own patent infringement lawsuit against Xinju in the U.S. District Court for the Eastern District of Texas, involving the same patent and the same accused products. Both lawsuits arise from the APEX complaints.
Motion at Issue
Xinju moved for a temporary restraining order (TRO) — an emergency court order issued before the opposing party has a full opportunity to be heard — and an order to show cause why a preliminary injunction should not be issued. Specifically, Xinju sought to require Semisilicon to withdraw its patent complaint filed with Amazon and to prohibit Semisilicon from submitting further takedown complaints to Amazon based on the '546 Patent.
Legal Standard
Under Federal Rule of Civil Procedure 65(b)(1)(A), a TRO may be granted when specific facts in an affidavit or verified complaint clearly show that immediate and irreparable injury will result to the movant before the opposing party can be heard. The Supreme Court's framework from Winter v. National Resources Defense Council, Inc., 555 U.S. 7 (2008) requires the moving party to clearly show: (1) a likelihood of success on the merits; (2) a likelihood of irreparable harm absent preliminary relief; (3) that the balance of equities tips in the moving party's favor; and (4) that the injunction is in the public interest.
Court's Analysis and Ruling
Judge Cousins found that Xinju had not clearly shown it satisfied any of the four Winter factors necessary to obtain a TRO. The opinion does not detail each factor's analysis beyond this conclusion.
Additionally, the court noted that Semisilicon had filed a pending motion to dismiss or transfer under Federal Rule of Civil Procedure 12(b)(2) — a challenge to the court's personal jurisdiction (i.e., authority over Semisilicon as a party) — and that this motion raises 'serious issues' of both personal jurisdiction and the 'first to file' rule. The first-to-file rule is a doctrine that generally favors allowing the court where a case was first filed — here, the Eastern District of Texas — to proceed, particularly when two cases involve the same parties and issues.
Accordingly, the court denied Xinju's Motion for Temporary Restraining Order and Order to Show Cause.
Significance
The denial means Semisilicon is not currently restrained from pursuing its Amazon-based patent complaints or its Texas lawsuit while this case continues. The pending Rule 12(b)(2) motion raises the possibility that the California case could be dismissed for lack of personal jurisdiction over Semisilicon or transferred to the Eastern District of Texas under the first-to-file rule, though the court did not resolve that motion in this order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.