Judge Ellis Dissolves Preliminary Injunction Against Amazon Seller Dirza Direct in Bike Wall Hanger Design Patent Case.

The opinion and order is Document 95 in Pang v. Dirza Direct, No. 1:24-cv-13141 (N.D. Ill.), signed October 14, 2026. The plaintiff, Xiaogang Pang, the owner of U.S. Patent D982,486, filed the case on December 20, 2024 against thirty-four defendants. After the court questioned joinder, the amended complaint of March 19, 2025 named only Dirza Direct, which the order says admits operating an Amazon store under that name. The court entered a TRO on May 22, 2025 and granted a preliminary injunction on July 2, 2025, before Dirza Direct appeared; no order setting the injunction's terms was ever entered.

The patent and accused product

The D'486 patent, filed October 21, 2022 and issued April 4, 2023, claims the ornamental design for an adjustable bike wall hanger. The accused products are bike wall hangers sold on Amazon under ASINs B098PYT567 and B09226DB63, first publicly available on July 6, 2021.

The reexamination record

In a 2024 reexamination, the USPTO found the accused product shares several features with the claimed design, including dual rod hooks, a telescopic beam, an adjustment slot, a center hinge, and an end plate, but has a more generic wall bracket than the claimed design's "almost Victorian like silhouette." It concluded that difference cannot be seen as de minimis and prohibits a finding of anticipation. The patent owner agreed and pointed out other differences. The USPTO confirmed the patent without changes, and on August 31, 2026 denied a later request for ex parte reexamination that again cited the accused product.

What the court decided

Because the injunction issued ex parte, in circumstances resembling a TRO, the court placed the burden on the patent owner to justify keeping it. Applying the rule that the test for design patent anticipation mirrors the test for infringement under 35 U.S.C. 289, the court held that, given the recognized differences, it could not find that Pang has a substantial likelihood of success on the merits. It rejected a forfeiture argument based on Dirza Direct's more than thirteen months of litigation, citing Rule 54(b), and dissolved the injunction.