In a swift enforcement action resolved in under five months, Rinne Corp secured a comprehensive default judgment against dozens of anonymous online sellers for willful infringement of its design patent covering a slide bucket lid mouse trap. The U.S. District Court for the Northern District of Illinois, under Chief Judge Manish S. Shah, entered judgment in Case No. 1:25-cv-11827 on February 24, 2026, granting permanent injunctive relief, $25,000 in statutory damages per defaulting defendant, and immediate asset restraint orders targeting major e-commerce platforms including Amazon, eBay, Temu, and Walmart.

The case exemplifies the increasingly prevalent “Schedule A” litigation strategy — a mass-enforcement mechanism targeting anonymous offshore counterfeiters through U.S. federal courts. For patent attorneys managing brand protection portfolios, IP professionals monitoring e-commerce enforcement trends, and R&D teams developing consumer products, this outcome reinforces both the power and precision of design patent enforcement in the digital marketplace.

Primary keyword focus: Design patent infringement, slide bucket lid mouse trap patent litigation.

Aperçu du dossier

Les parties

Le brevet en cause

This case involved U.S. Design Patent USD1039648S (application number US29/782229), covering the ornamental design of a slide bucket lid mouse trap. Design patents protect the *visual characteristics* of a product, not its functional utility, making any product with a substantially similar appearance potentially infringing under the “ordinary observer” test established in Egyptian Goddess, Inc. v. Swisa, Inc., 543 F.3d 665 (Fed. Cir. 2008).

• • US D1,039,648S — Ornamental design of a slide bucket lid mouse trap

Chronologie du litige et historique de la procédure

Filed in the Northern District of Illinois — a preferred venue for Schedule A IP enforcement actions due to its procedural familiarity with such cases — the complaint was lodged on September 29, 2025. The Northern District of Illinois has developed a well-established framework for handling Schedule A litigation, enabling relatively expedient TRO, preliminary injunction, and default judgment proceedings.

The 148-day resolution from filing to closed judgment reflects a textbook Schedule A trajectory: defendants, typically anonymous foreign sellers, do not appear or respond, triggering default proceedings under Federal Rule of Civil Procedure 55. Chief Judge Manish S. Shah, an experienced federal jurist in the Northern District, presided over the matter.

The absence of defendant legal representation — common in Schedule A cases — meant no contested claim construction, no invalidity challenges, and no discovery disputes, allowing Plaintiff’s motion for default judgment to proceed on an uncontested record.

Le verdict et l'analyse juridique

Résultat

On February 24, 2026, Chief Judge Shah granted Rinne Corp’s Motion for Entry of Default and Default Judgment in full. The court’s order included three categories of relief:

1. Permanent Injunction against all defaulting defendants
2. Statutory Damages of $25,000 per defaulting defendant
3. Asset Restraint and Transfer Orders directed at third-party payment processors and marketplace platforms

Damages and Injunctive Relief

Pursuant to 15 U.S.C. § 1117(c)(2) (Lanham Act willful counterfeiting) and 17 U.S.C. § 504(c)(2) (Copyright Act willful infringement), the court awarded $25,000 in statutory damages per defaulting defendant for willful use of counterfeit trademarks and copyrights. Critically, the order specifies this award applies once per defendant, even where a defendant operated under multiple aliases — a measured approach to preventing disproportionate stacking while still reflecting the willful nature of the infringement.

The permanent injunction is notably broad in scope, restraining defendants and all persons acting in concert with them from using Rinne Corp’s intellectual property in connection with any unauthorized product, passing off counterfeit products, or manufacturing/distributing unauthorized products. Significantly, the injunction extends to named third-party e-commerce and payment platforms, including Amazon, eBay, Temu, Walmart, Shein, Alibaba/AliExpress, PayPal, Stripe, Payoneer, and LianLian — each required to disable infringing listings and freeze associated financial accounts within seven calendar days of receiving the order.

Analyse des causes du verdict et importance juridique

The case was brought as an infringement action grounded in design patent, trademark, and copyright claims. Because defendants defaulted, the court accepted Plaintiff’s well-pleaded allegations as admitted. The willfulness finding — critical to obtaining enhanced statutory damages — was supported by the defendants’ conduct: operating commercial storefronts selling products that replicated Rinne Corp’s protected intellectual property without authorization.

Under the design patent framework, infringement is assessed through the eyes of an “ordinary observer” comparing the patented design with the accused product in the context of prior art. While no contested infringement analysis was required here due to default, the complaint’s allegations of substantial similarity formed the factual predicate for the court’s award.

This case reinforces several important principles for design patent and Schedule A practitioners:

• Default judgment remains an effective enforcement tool when defendants fail to appear, enabling plaintiffs to obtain permanent injunctions and statutory damages without contested litigation.
• Third-party platform orders directing marketplaces and payment processors to freeze assets and disable listings are now routine in Northern District of Illinois Schedule A cases, providing tangible financial recovery mechanisms.
• Willfulness can be established through default where the pleadings adequately allege knowing, unauthorized use of protected IP.