The complaint
Hao Liu v. Wenzhou Yubo Shoe Materials Co., Ltd., d/b/a yubaixiecai, No. 4:26-cv-01686 (E.D. Tex., Sherman Division), is an 11-page complaint filed November 10, 2026, ECF No. 1, with a jury demand. The complaint describes Liu as an individual and a citizen of the People's Republic of China residing in Qingdao, Shandong Province, and as the author and sole copyright claimant of the work. It describes the defendant as a company organized in the People's Republic of China in July 2023, based in Wenzhou, Zhejiang, that operates the Amazon.com seller account "yubaixiecai" and offers the accused product under the brand name "Skemic." It alleges, upon information and belief, that the defendant is not registered to do business in Texas. It pleads jurisdiction under 28 U.S.C. §§ 1331 and 1338(a) and venue under 28 U.S.C. §§ 1391(c)(3) and 1400(a). (Compl. caption; paras. 4 to 13.)
The work
The complaint alleges that Liu created the work, a two-dimensional graphic artwork titled "Environmental Design Slogans," in 2024 for use on product packaging, and that it combines a green header banner, a circular graphic, stacked text with a green highlight box, an oversized numeral, and a closing line. It alleges first publication in the United States on February 1, 2025, and registration as No. VA 2-513-236, effective May 24, 2026. The Copyright Office public record for VA0002513236 shows the title "Environmental Design Slogans," Hao LIU as author and claimant, authorship of 2-D artwork, creation in 2024, first publication on February 1, 2025, and registration on May 24, 2026. The record states that the registration is based on the artwork in the deposit and that copyright does not protect names, titles, short phrases or slogans. (Compl. paras. 1, 14 to 19.)
What the complaint alleges
The complaint alleges that the defendant offers on Amazon.com a product titled "Water Shoes For Women Men Slip-On Comfortable For Beach Swim Surf Yoga Lightweight Breathable Soft," item model number YM044, through five listings that, as captured on November 9, 2026, identified yubaixiecai as the seller and Amazon as the shipper and showed a price of $6.99. It alleges that the listings depict a clear plastic bag whose design reproduces the work's selection, coordination, and arrangement of graphic and textual elements in substantially the same relative positions and proportions. It alleges a test purchase from the yubaixiecai storefront on November 7, 2026, for delivery to Plano, Texas. It alleges, upon information and belief, that the defendant had access to the work before reproducing it, that the infringement began after the May 24, 2026 registration date (each listing shows a "Date First Available" of September 24, 2026), and that the infringement is willful. (Compl. paras. 9 to 10, 21 to 27.)
The count and relief
Count I alleges copyright infringement under 17 U.S.C. § 501: reproduction and public display of the work in the listing photographs under §§ 106(1) and 106(5) and, upon information and belief, reproduction on the packaging and distribution of copies through sales under §§ 106(1) and 106(3). The prayer asks for a finding of willful infringement; preliminary and permanent injunctive relief; impoundment and destruction of infringing copies under 17 U.S.C. § 503; actual damages and profits under § 504(b) or, at Liu's election, statutory damages under § 504(c), including enhanced statutory damages of up to $150,000 for willful infringement; costs and attorneys' fees under § 505; prejudgment and postjudgment interest; and other relief. (Compl. paras. 28 to 36; prayer.)