One Motion, Two Injunctions: Reverse TRO and Preliminary Injunction in the TYKOR Design Patent Matter

Based on publicly searchable decisions, this appears to be the first design patent matter in the Western District of Washington to move from reverse TRO to preliminary injunction on a single application.

• Four days after the TRO application was filed, the court issued a reverse temporary restraining order directing the patent owner to withdraw its Amazon complaints within 24 hours.
• The court converted that same motion into a preliminary injunction application and entered a PI 17 days later, without requiring security.
• A substantial quantity of inventory approaching its disposal deadline was preserved, and the core listings returned to business.
• In March 2026, the parties settled and dismissed with prejudice, concluding the matter.

A takedown may require only a single patent complaint. Reinstatement often requires the seller to complete an entire chain of proof running the other way.

On June 23, 2025, a U.S. design patent complaint caused TYKOR's core product listings to be removed by Amazon. The platform appeal did not resolve the problem; product rankings continued to fall, and a quantity of inventory approaching its disposal deadline faced the risk of being written off.

Upon engagement, Attorneys Hongchang Deng and Yi Yi of this firm immediately filed a declaratory judgment ("DJ") action in the U.S. District Court for the Western District of Washington and, on July 18, 2025, applied for a temporary restraining order.

Four days later, the court issued a reverse temporary restraining order (TRO) directing the patent owner to withdraw its Amazon patent complaints within 24 hours and barring it from submitting further complaints against TYKOR's products, on the same patent, to Amazon or other third-party platforms. The court simultaneously converted the TRO application into an application for a preliminary injunction.

On August 4, 2025, the court entered a preliminary injunction (PI), extending the protection against repeat complaints through judgment and expressly declining to require TYKOR to post security.

In other words, this matter did not go through a cycle of denial, supplementation, and renewed application. A single motion produced first a reverse TRO and then, through the court's conversion of the proceeding, a PI — clearing the critical obstacle to reinstatement and protecting the client's platform operations for the remainder of the case.

I. From Platform Appeal to Judicial Relief

Once the platform appeal failed, the central question was no longer how to explain the position to Amazon one more time. It was whether the complainant could be required to withdraw its complaints and to stop using the platform complaint mechanism to compound the harm while a federal court examined validity and infringement.

We therefore filed a declaratory judgment action on TYKOR's behalf, seeking declarations that the asserted design patent was invalid and that TYKOR's products did not infringe, together with related relief.

But a DJ action does not restore listings by itself. What actually changed the client's operating position was the reverse TRO application that followed.

II. A Reverse TRO Binds the Complainant, Not Amazon

This matter illustrates the enforcement boundary of a reverse TRO clearly.

The motion had asked the court to direct Amazon to reactivate the listings. The court declined that portion of the request, reasoning that Amazon was not a party and the record was insufficient to bind it by injunction.

The court instead took the path better fitted to the Federal Rules: it bound the complainant directly — ordering it to withdraw the Amazon complaints within 24 hours and barring it from asserting the same patent against TYKOR's products before Amazon or other third-party platforms.

That approach did not have the court substitute its judgment for the platform's operational decisions; it removed the basis on which the platform had delisted the products. For cross-border sellers, that design of relief is typically more direct than filing a DJ complaint alone: it converts "persuade the platform to believe the seller" into "require the complainant to answer for its patent assertions in court."

III. Why the Court Was Willing to Intervene Early

TROs and preliminary injunctions are extraordinary relief. An applicant must establish likelihood of success, irreparable harm, the balance of equities, and the public interest — all four.

Here, on the prior public sale evidence in the record, the court preliminarily found that TYKOR had shown a likelihood of success on invalidity; it also found that the ranking decline, loss of market position, and pressure from time-limited inventory caused by the delisting constituted harm not adequately remediable by later money damages. The equities and the public interest likewise did not favor a competitor using a facially ordinary intellectual property complaint to shut down another party's business in substance.

An important distinction: the court's determinations at the TRO and PI stages were preliminary. It did not finally adjudicate validity or infringement.

How the evidence is organized and the argument developed is what determines the outcome in cases of this kind, but it concerns the specifics of the representation and is not detailed here. This much can be said: the application must establish both the merits and the harm on first submission, so that the court is in a position to act decisively early in the case.

IV. How a Single Application Produced Both a TRO and a PI

The procedural path was compressed:

• July 14, 2025 — TYKOR filed its declaratory judgment action.
• July 18, 2025 — TRO application filed.
• July 22, 2025 — the court granted the TRO in part, ordered the defendant to withdraw its complaints within 24 hours, and converted the same motion into a PI application.
• August 4, 2025 — the court held the PI hearing. The defendant filed no opposition and did not appear to explain why a PI should not issue; TYKOR confirmed to the court that the defendant had complied with the TRO. The court entered the PI, without security.

"A single application" does not mean steps were skipped. On the contrary, it depended on the initial submission covering, at once, likelihood of success on the merits, urgent harm, notice efforts, the target of the injunction, and the scope of enforceable relief — allowing the court first to halt the immediate harm by TRO and then, after completing notice and hearing, to convert and extend the same motion into a PI.

V. Where This Matter Sits as Precedent in the Western District of Washington

Accuracy about "firsts" matters.

TYKOR was not the first design patent reverse TRO in the Western District of Washington. Before it, Dongguan Zhouda Technology Co. v. Dai obtained a TRO requiring withdrawal of Amazon complaints in June 2025. But the first TRO application in that case was denied for insufficient notice and failure to satisfy the requirements for issuance without notice, and a TRO issued only on a second application; as of the entry of the PI in TYKOR on August 4, 2025, the public docket in that case showed its PI still contested.

Accordingly, based on decisions and dockets publicly searchable as of July 21, 2026, TYKOR appears to be the first matter in the Western District of Washington, in the design patent platform complaint context, in which a single TRO application was converted by the court and ultimately produced a PI.

That statement is a conclusion drawn from a search of public materials, not a "first case" certification by the court. As a matter of procedural outcome, however, the case did achieve a combination not previously completed in a public example: a reverse TRO on the first application, with a PI following from the same motion.

VI. An Injunction Is Not the End Point: From Resumed Operations to Dismissal With Prejudice

After the PI issued, the defendant appeared and answered, and the case entered ordinary proceedings and discovery. The reverse injunction did not substitute for adjudication on the merits, nor did it declare the patent invalid. Its value was to stop the harm from compounding before a final result, preserving the client's operating position and its room to negotiate.

On March 11, 2026, the parties filed a stipulation of dismissal with prejudice under Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, concluding the case.

From the complaint and delisting in June 2025, to the reverse TRO in July and the PI in August, to settlement and dismissal with prejudice in March 2026, the matter ran the full path from emergency mitigation through sustained protection to final resolution.

VII. What This Means for Cross-Border Sellers

The significance of TYKOR is not that every platform takedown can be resolved by a reverse TRO. TROs and PIs remain high-threshold relief that depends heavily on the specific evidence.

But the case does show this: where the patent underlying a platform complaint is subject to clear doubt, and the delisting is causing continuing, urgent harm that money cannot adequately remedy, a seller is not confined to repeating appeals inside the platform. With a properly designed DJ action, reverse TRO, and follow-on PI, a business crisis triggered by a platform complaint can be converted into a patent dispute a federal court can review and address in time.

Which situations resemble this one? The following self-assessment may help:

• The patent underlying the complaint is subject to verifiable and evident doubt (for example, clear indications of prior public disclosure or prior sale).
• The delisted listings account for a large share of store sales or profit, and the loss of ranking, reviews, and traffic entry points is hard to measure in money.
• There is a real, dated harm milestone — inventory approaching a disposal deadline, or an imminent peak season.
• The complainant's own standing is questionable, such that even a later judgment might prove uncollectible.
• The platform's internal appeal process has been exhausted without resolving the problem.

The more of these that apply, the more it is worth assessing a move from platform appeal to federal court. Conversely, where the doubts about the patent are vague and the harm is readily measurable in money, the threshold for a reverse TRO is difficult to meet — something counsel should say plainly at the intake assessment stage.

For the client, what this application produced was concrete: the listings were restored, the inventory was preserved, ranking and market position did not continue to erode during the litigation, and the subsequent settlement negotiations had leverage behind them.

Frequently Asked Questions

Q: What is a reverse TRO?

A: An ordinary TRO is sought by a rights holder to restrain infringement. A reverse TRO is sought by the seller subject to the complaint, as plaintiff, asking the court to order the complainant to withdraw its platform complaints and to bar further complaints. It generally attaches to a declaratory judgment action: the seller first sues for a declaration that the patent is invalid or that it does not infringe, then uses a TRO application to address the harm compounding during the litigation.

Q: How does a reverse TRO differ from an Amazon platform appeal?

A: A platform appeal asks Amazon to change its own assessment; the decision rests with the platform and carries no compulsion. A reverse TRO is a federal court order directed at the complainant, and non-compliance exposes it to contempt. Here, after the platform appeal failed, it was the court's order that produced the withdrawal.

Q: What evidence does a reverse TRO application require?

A: Two sets. First, merits evidence showing that the patent assertion is likely untenable — for example, indications of prior public disclosure or prior sale. Second, harm evidence showing that the delisting is causing losses money cannot remedy — listing performance data, changes in ranking and traffic, and inventory risk with a defined deadline. Both must be complete on first submission; how they are organized and argued varies by case and requires counsel's assessment of the specific facts.

Q: How quickly can a result come?

A: Here, four days from the TRO application to the court's order, and 17 days from application to PI. But that depends on the completeness of the evidence, the court's calendar, and the circumstances of the case. It is not a timetable that can be promised.

Q: Once a TRO issues, will Amazon restore the listings automatically?

A: No. The court here expressly declined to order Amazon directly, because Amazon was not a party. What the court ordered was that the complainant withdraw its complaints within a set period; once withdrawn, the seller then pursues reinstatement through the platform's process on the basis of that withdrawal. This is the enforcement boundary of a reverse TRO, and a rule the application must be designed to respect.

Case Information

• Case name: Cixishihualongdianziyouxiangongsi d/b/a TYKOR v. Seven Sparta Corp.
• Case No.: 2:25-cv-01313-JHC
• Court: United States District Court for the Western District of Washington
• Presiding judge: Hon. John H. Chun
• Counsel for plaintiff: LawMay P.C., with Washington local counsel
• Key rulings: TRO, July 22, 2025; PI, August 4, 2025
• Disposition: dismissed with prejudice by stipulation, March 11, 2026

Timeline

• 2025-06-23 — patent owner complains to Amazon; TYKOR listings removed
• 2025-07-14 — TYKOR files declaratory judgment action
• 2025-07-18 — TRO application filed
• 2025-07-22 — court issues reverse TRO, ordering withdrawal within 24 hours, and converts the motion to a PI application
• 2025-08-04 — court enters PI, without security
• 2026-03-11 — parties settle; case dismissed with prejudice

This article is based on public decisions and public case information and is provided to describe the matter and general legal questions only. It does not constitute legal advice on any specific matter. The court's determinations at the TRO and PI stages were preliminary and were not a final adjudication of validity or infringement. Outcomes depend on the specific facts, evidence, applicable law, and the court's discretion. Past results do not guarantee or predict similar outcomes in future matters.