Binglin Zhong v. Shanghai Jingsun Tech. Co., No. 25 C 2973 (N.D. Ill. July 18, 2025) (Kennelly, J.).

Judge Kennelly denied plaintiff Zhong’s motion for preliminary injunction against defendant Millionhome for alleged infringement of a design patent covering a surge protector, finding that Zhong failed to establish irreparable harm.

Zhong argued two points regarding irreparable harm: that Millionhome’s infringement impaired Zhong’s reputation in the market, and that Millionhome was unable to satisfy a judgment. The Court found both arguments unsupported by sufficient evidence.

The Court held that the fact that Millionhome received 600 positive online reviews did not mean that Zhong’s reputation had been damaged. Positive reviews for infringing products do not necessarily harm the reputation of the patentholder’s covered products.

The Court also found Zhong’s argument that Millionhome could not satisfy the judgment unconvincing. Zhong’s argument was that despite $1.2M in alleged infringing sales, Millionhome only had $25k in its Amazon account. The Court equated an Amazon account to a store till and held that how much was in Millionhome’s till did not prove its overall worth or cash reserves. The Court also noted that Zhong provided no evidence about Millionhome’s overall assets or cash on hand.