The case

The case is Qiu v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 2:26-cv-02306 (W.D. Pa.), filed October 22, 2026 and assigned to Chief Judge Cathy Bissoon. The complaint is signed by Nicholas Najera of Ni, Wang & Massand, PLLC in Dallas, Texas, whose motion to appear pro hac vice was filed the same day. Qiu also moved that day for leave to file Schedule A and Exhibits 1 and 2 to the complaint under seal. The complaint pleads jurisdiction under 28 U.S.C. 1331 and 1338, personal jurisdiction based on the defendants' alleged targeting of Pennsylvania consumers through their storefronts and, in the alternative, Fed. R. Civ. P. 4(k)(2), and venue under 28 U.S.C. 1391(c)(3).

The patent and the plaintiff

The complaint describes Qiu as a private citizen residing in Fengshun County, China, and the named inventor and applicant of U.S. Design Patent No. D1,135,374, which it says was filed June 11, 2025 and issued July 21, 2026. It says the patent claims the ornamental design for a shoulder bag, as shown and described, in fifteen figures. It says Qiu is affiliated with two Amazon storefronts, OIAWH US and YFWE-US, that are authorized to practice the design and sell shoulder bags embodying it.

What it alleges

The complaint alleges, on information and belief, that the defendants are Amazon storefronts operating from China, under common control, that sell the same shoulder bags with minor variations and with similar or identical product images, as it says Exhibit 1 shows. It alleges the storefronts offer shipping to Pennsylvania and, on information and belief, have sold the accused bags there, and that the infringement is willful.

Count I pleads design patent infringement under 35 U.S.C. 271 and presents a side by side comparison of the claimed design and an accused product.

Relief requested

Qiu asks for temporary, preliminary and permanent injunctions, an order directing online marketplaces, payment providers and search engines to stop providing services the defendants use to sell infringing goods, disable their advertisements and remove links to their storefronts from search results, damages including all of the defendants' profits and no less than a reasonable royalty, increased damages up to three times under 35 U.S.C. 284, and attorneys' fees and costs.