Bounce Curl, LLC v. Schedule A Defendants: Hair Accessory Design Patent Case Dismissed in 53 Days
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📋 Case Summary
| Case Name | Bounce Curl, LLC v. Schedule A Defendants |
| Case Number | 1:25-cv-14359 |
| Court | Illinois Northern District Court |
| Duration | Nov 2025 – Jan 2026 53 days |
| Outcome | Plaintiff Strategic Dismissal |
| Patent at Issue | |
| Accused Products | Hair Accessory Products (Online Marketplace Sellers) |
Case Overview
The Parties
⚖️ Plaintiff
A hair care brand specializing in styling products, including brushes, combs, and curl-defining accessories, actively protecting its product designs.
🛡️ Defendant
Anonymous online marketplace sellers, identified collectively, accused of infringing design patents, typical in multi-defendant e-commerce actions.
The Patent at Issue
This case involved **U.S. Design Patent No. USD1028527S** (Application No. US29/880941). This ornamental design patent protects the visual appearance of hair care products. Design patents are distinct from utility patents as they cover how an article looks, not how it functions. Infringement is assessed under the “ordinary observer” test, considering if an ordinary purchaser would mistake the accused product’s design for the patented design.
- • USD1028527S — Ornamental design of hair care products
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The Verdict & Legal Analysis
Outcome
Pursuant to **Rule 41(a)(1) of the Federal Rules of Civil Procedure**, Bounce Curl, LLC voluntarily dismissed the action **without prejudice** as to defendant AniberhgZhen. This dismissal occurred before any substantive litigation commenced, with no damages formally awarded. Preliminary injunctive relief, such as temporary restraining orders (TROs) or asset freezes, may have been pursued and resolved confidentially, consistent with Schedule A litigation practices.
Key Legal Issues
The operative cause of action was **design patent infringement** under 35 U.S.C. § 271. Infringement is determined by the “ordinary observer” test, established in Egyptian Goddess, Inc. v. Swisa, Inc., asking whether an ordinary purchaser would mistake the accused product’s design for the patented design. This case exemplifies the **Schedule A litigation model** in the Illinois Northern District Court, where anonymous defendants are identified through expedited discovery and cases often resolve rapidly via voluntary dismissal once commercial objectives are met.
Freedom to Operate (FTO) Analysis
This case highlights critical IP risks in hair accessory design. Choose your next step:
📋 Understand This Case’s Impact
Learn about the specific risks and implications from this litigation.
- View the patent involved and its family
- See related design patent filings in hair care
- Understand e-commerce enforcement trends
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High Risk Area
Hair accessory product designs
1 Patent at Issue
Focus on ornamental design
Strategic Dismissal
Common in Schedule A cases
✅ Key Takeaways
Rule 41(a)(1) without-prejudice dismissals are strategic tools in Schedule A cases, preserving refiling rights.
Search related case law →The Northern District of Illinois remains a preferred venue for design patent e-commerce enforcement due to robust TRO infrastructure.
Explore N.D. Illinois filings →Frequently Asked Questions
U.S. Design Patent No. USD1028527S (Application No. US29/880941), covering the ornamental design of hair care products including brushes, combs, and styling tools.
Pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure, Bounce Curl voluntarily dismissed the action against defendant AniberhgZhen without prejudice — preserving the right to refile — likely following a resolution, platform compliance, or strategic reallocation prior to any substantive court ruling.
It reinforces the viability of design patent enforcement via Schedule A proceedings in the Northern District of Illinois, signaling an active enforcement landscape for beauty and personal care brands protecting ornamental product designs against online marketplace sellers.
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References
- PACER Filings for Case No. 1:25-cv-14359
- U.S. Patent and Trademark Office — Design Patent USD1028527S
- Egyptian Goddess, Inc. v. Swisa, Inc. (543 F.3d 665 (Fed. Cir. 2008))
- Federal Rules of Civil Procedure — Rule 41(a)(1)
- Cornell Legal Information Institute — 35 U.S.C. § 271
This article is for informational purposes only and does not constitute legal advice. All case information is drawn from publicly available court records. For platform capabilities, visit PatSnap.