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Bounce Curl v. Schedule A Defendants — Hair Brush Design Patent | PatSnap
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Case ID1:25-cv-10383
FiledAug 2025
ClosedDec 2025
Patent Litigation

Bounce Curl v. Schedule A Defendants: Default Judgment on Hair Brush Design Patent

Bounce Curl, LLC secured a default judgment and permanent injunction against more than 50 anonymous e-commerce seller aliases operating on Amazon, Temu, Walmart, and PayPal, all found to infringe U.S. Design Patent No. D1,028,527 covering the Bounce Curl hair brush design. The case resolved in 116 days with profit disgorgement awards totaling over $35,000 enforced directly through third-party payment processors.

Resolution time
116days
116-day resolution — fast for a multi-defendant Schedule A design patent action
Patents asserted
1
USD1,028,527 — Bounce Curl hair brush ornamental design, issued May 28, 2024
Outcome
Default Judgment
All defendants failed to appear; allegations deemed admitted; permanent injunction entered
Cost ruling
$10,000 Bond Released
Plaintiff’s surety bond returned; profit awards enforced via PayPal, Amazon, Temu, Walmart
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Design patent ambush: Bounce Curl targets 50+ e-commerce counterfeiters

Bounce Curl, LLC filed suit on August 29, 2025 in the U.S. District Court for the Northern District of Illinois before Judge Andrea R. Wood, asserting infringement of U.S. Design Patent No. D1,028,527 — a design patent for a hair brush issued on May 28, 2024 — against a cohort of anonymous seller aliases operating e-commerce storefronts on platforms including Amazon, Temu, and Walmart. This is a classic ‘Schedule A’ enforcement action, a litigation model heavily used in the Northern District of Illinois to pursue large numbers of offshore or pseudonymous online counterfeiters simultaneously.

The case closed on December 23, 2025 via default judgment, entered because all named defendants failed to answer or otherwise appear. Under default judgment procedure, the complaint’s allegations are deemed admitted, enabling the court to find patent infringement under 35 U.S.C. § 271 and award disgorgement of profits under 35 U.S.C. § 289 — the design patent-specific damages provision that permits recovery of a defendant’s total profits from infringing sales. Individual profit awards ranged from the statutory floor of $250 to $11,679.73 for a single seller alias, with the total across all defendants exceeding $35,000. A permanent injunction was also entered against all defaulting defendants.

Resolution in 116 days is consistent with — and arguably towards the faster end of — Schedule A default judgment timelines, suggesting no defendants mounted any defense or filed motions to vacate. The TRO-to-default pipeline, including asset freezes through payment processors, appears to have functioned as intended, effectively cutting off defendants’ access to funds before they could transfer proceeds. What the public record does not reveal is whether any of the frozen assets were sufficient to satisfy the profit awards, or whether some defendants had already moved funds beyond the reach of the third-party providers.

Case at a glance
Case no.1:25-cv-10383
CourtIllinois Northern
JudgeAndrea R. Wood
FiledAugust 29, 2025
ClosedDecember 23, 2025
Duration116 days
OutcomeDefault Judgment
Verdict causeInfringement Action
BasisDefault Judgment
Prior Art Intelligence
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Case data sourced from PACER / Illinois Northern District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to Default Judgment in 116 days

116-day resolution — fast for a multi-defendant Schedule A design patent action

Case timeline: Complaint filed AUG 29 2025, OCT–NOV — 116 days total Horizontal timeline showing the three key events in Bounce Curl, LLC v The Partnerships and Unincorporated Associations Identified on Schedule A from filing to resolution. Source: PACER, Illinois Northern District Court. AUG 29 2025 Complaint filed Pre-trial proceedings DEC 23 2025 Default Judgment 116 DAYS TOTAL
Default judgment

Default judgment entered: what the ruling means for both parties

Legal mechanism

Default judgment: allegations admitted, liability automatic

When defendants fail to appear, a court may enter default judgment under Fed. R. Civ. P. 55. The complaint’s factual allegations are deemed admitted, bypassing trial. The court still conducts an independent inquiry into damages and jurisdiction. Here, Judge Wood found personal jurisdiction on the basis that defendants targeted U.S. and Illinois consumers via their storefronts, and awarded profits under 35 U.S.C. § 289 — the design patent profit disgorgement statute.

Liability deemed admitted
Plaintiff outcome

Permanent injunction and asset freeze secured across major platforms

Bounce Curl obtained a permanent injunction, disgorgement of profits, and ongoing authority to serve the order on new financial accounts as they are discovered. Third-party providers — Amazon, Temu, Walmart, and PayPal — were ordered to freeze and release funds within seven days. The $10,000 surety bond was returned. The enforcement architecture here means Bounce Curl can continue recovering funds without returning to court for each new account identified.

Injunction + profit disgorgement
Defendant outcome

Permanent sales ban and frozen accounts for all seller aliases

All 50+ seller aliases are permanently enjoined from offering, selling, or importing the infringing hair brush product. Their financial accounts on covered platforms are frozen up to the profit award amounts. Defendants who failed to appear lose any right to contest liability or quantum of damages at this stage, though a defendant can in principle move to vacate a default judgment under Rule 60(b) if they can show good cause — a high bar they have not yet cleared.

Permanent injunction entered
Commercial implications

Schedule A enforcement raises the cost of design patent copying on marketplaces

This case illustrates the effectiveness of the Northern District of Illinois Schedule A model for design patent holders. By combining a TRO with platform-level asset freezes, brand owners can neutralise infringing storefronts and recover profits before sellers can relocate funds. For marketplace sellers operating in competitive accessories categories, this signals elevated enforcement risk even for newly registered design patents — D1,028,527 was issued only in May 2024, barely 15 months before the default judgment.

Marketplace enforcement signal
Legal analysis based on PACER docket records for case 1:25-cv-10383 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffBounce Curl, LLCCompanyHair care accessories brand — holder of U.S. Design Patent No. D1,028,527Search in Eureka ↗
DefendantThe Partnerships and Unincorporated Associations Identified on Schedule AIndividual50+ anonymous e-commerce seller aliases operating on Amazon, Temu, Walmart, and PayPalSearch in Eureka ↗
Plaintiff counselAmy Crout ZieglerAttorneyCounsel for Bounce Curl, LLCSearch in Eureka ↗
Plaintiff counselAndrew Daniel BurnhamAttorneyCounsel for Bounce Curl, LLCSearch in Eureka ↗
Plaintiff counselJennifer Van NachtAttorneyCounsel for Bounce Curl, LLCSearch in Eureka ↗
Plaintiff counselJustin R. GaudioAttorneyCounsel for Bounce Curl, LLCSearch in Eureka ↗
Plaintiff counselJustin Tyler JosephAttorneyCounsel for Bounce Curl, LLCSearch in Eureka ↗
Plaintiff counselLucas Allen PetersonAttorneyCounsel for Bounce Curl, LLCSearch in Eureka ↗
Plaintiff law firmGreen, Burns & Crain, Ltd.Law FirmRepresenting Bounce Curl, LLCSearch in Eureka ↗
Plaintiff law firmHusch Blackwell LLPLaw FirmRepresenting Bounce Curl, LLCSearch in Eureka ↗
Presiding judgeJudge Andrea R. WoodJudgeIllinois Northern District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“This action having been commenced by Plaintiff Bounce Curl, LLC (“Plaintiff” or “Bounce Curl”) against the fully interactive, e-commerce stores1 operating under the seller aliases identified on Schedule A attached hereto (collectively, the “Seller Aliases”), and Plaintiff having moved for entry of Default and Default Judgment against the defendants identified on Schedule A (collectively, the “Defaulting Defendants”); This Court having entered upon a showing by Plaintiff a temporary restraining order and preliminary injunction against Defaulting Defendants which included an asset restraining order; Plaintiff having properly completed service of process on Defaulting Defendants, the combination of providing notice via electronic publication and e-mail, along with any notice that Defaulting Defendants received from payment processors, being notice reasonably calculated under all circumstances to apprise Defaulting Defendants of the pendency of the action and affording them the opportunity to answer and present their objections; and 1 The e-commerce store URLs are listed on Schedule A hereto under the Online Marketplaces. Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 1 of 10 PageID #:1421 2 Defaulting Defendants having failed to answer the Complaint or otherwise plead, and the time for answering the Complaint having expired, so that the allegations of the Complaint are uncontroverted and are deemed admitted This Court finds, in the absence of adversarial presentation, that it has personal jurisdiction over the Defaulting Defendants since the Defaulting Defendants directly target their business activities toward consumers in the United States, including Illinois. Specifically, Defaulting Defendants have targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more Seller Aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars and/or funds from U.S. bank accounts, and have sold the same product shown in Exhibit 1 to the Complaint [3], that infringes Plaintiff’s U.S. Patent No. D1,028,527 (the “Infringing Products”). Plaintiff’s U.S. Patent No. D1,028,527 (the “Bounce Curl Design”) is shown in the below chart. Patent Number Claim Issue Date D1,028,527 May 28, 2024 Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 2 of 10 PageID #:1422 3 Patent Number Claim Issue Date Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 3 of 10 PageID #:1423 4 This Court further finds that Defaulting Defendants are liable for patent infringement (35 U.S.C. § 271). IT IS HEREBY ORDERED that Plaintiff’s Motion for Entry of Default and Default Judgment is GRANTED in its entirety, that Defaulting Defendants are deemed in default and that this Final Judgment is entered against Defaulting Defendants. IT IS FURTHER ORDERED that: 1. Defaulting Defendants, their officers, agents, servants, employees, attorneys, and all persons acting in active concert or participation with them be permanently enjoined and restrained from: a. offering for sale, selling, and importing Infringing Product; b. aiding, abetting, contributing to, or otherwise assisting anyone in offering for sale, selling, and importing the Infringing Product; and c. effecting assignments or transfers, forming new entities or associations or utilizing any other device for the purpose of circumventing or otherwise avoiding the prohibitions set forth in Subparagraphs (a) and (b). 2. Upon Plaintiff’s request, any third party with actual notice of this Order who is providing services for any of the Defaulting Defendants, or in connection with any of Defaulting Defendants’ Online Marketplaces, including, without limitation, any online marketplace platforms such as PayPal, Inc. (“PayPal”), Amazon.com, Inc. (“Amazon”), WhaleCo Inc. (“Temu”) and Walmart, Inc. (“Walmart”) (collectively, the “Third Party Providers”) shall within seven (7) calendar days after receipt of such notice disable and cease displaying any advertisements used by or associated with Defaulting Defendants in connection with the sale of the Infringing Product. Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 4 of 10 PageID #:1424 5 3. Pursuant to 35 U.S.C. § 289, Plaintiff is awarded profits from each of the Defaulting Defendants for the sale of the Infringing Product sold through at least the Defaulting Defendants’ Seller Aliases according to the below chart: No. Defaulting Defendant / Seller Alias Profit Award 1 A1GKJ1HQKQTZD1 $250 2 A3BIKMO9H8M97V $250 3 AiMuShangDian $250 4 ansuqindaer $250 5 BaiBaiBai Shop $250 6 DangYangShiManShiYangBaiHuoDian(Ge RenDuZi) $250 7 fengmingz $250 8 Firefly US $250 9 FQW-US $250 10 HengTon $250 11 JIAOQINGYONG $250 12 JiuDunYingDeShangMao $250 13 juxinshangdian $250 14 Lingyuyu $250 15 MaChunShangMao $250 16 MengXunN $250 17 Rongsijieneng $250 18 sen miao shang mao $250 19 SMZCY $250 20 taoqizhou $250 21 xilinhui $250 22 XingHuaShiYe $250 23 xxsnn $250 24 yangxiaodizahuodian $250 25 YingQiDianShangDian $250 26 zhaocaimaoSP $250 28 Anshengsshop November $548.78 29 chenguangsshop February $466.73 30 Elitevs $250 31 EWBF $3,179.94 33 kaiqiangshop $706.18 34 Mingdiushop January $1,919.36 35 Qilingshop Autumn $633.85 36 Rhcollection $351.51 Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 5 of 10 PageID #:1425 6 37 Shui Miaomiao Home $2,205.07 39 Yingyeshop July $887.70 40 yinuoshop $800.84 42 BA ANAN $250 43 BuluBulu $11,679.73 44 Chao Zeng $250 45 Cobear $250 46 Fumo store $1,439.80 47 gansujinshengmaoyi $250 48 gaoshandianzishangwu $2,443.20 49 GREER $1,047.30 50 Guo Ben $350.73 51 hao zhi sheng mao yi $250 52 jindan Xia $250 53 linxiao $250 54 NBIJFN $250 55 sahdousahf $250 56 WuGuZher $454.65 57 xiangD $250 58 youye maoyi $250 4. Plaintiff may serve this Order on Third Party Providers, including PayPal, Amazon, Temu and Walmart, by e-mail delivery to the e-mail addresses Plaintiff used to serve the Temporary Restraining Order on the Third Party Providers. 5. Any Third Party Providers holding funds for Defaulting Defendants, including PayPal, Amazon, Temu and Walmart, shall, within seven (7) calendar days of receipt of this Order, permanently restrain and enjoin any financial accounts connected to Defaulting Defendants’ Seller Aliases or Online Marketplaces from transferring or disposing of any funds, up to the above identified damages award, or other of Defaulting Defendants’ assets. 6. All monies, up to the above identified amount of the profit award in Defaulting Defendants’ financial accounts, including monies held by Third Party Providers are hereby released to Plaintiff as partial payment of the above-identified damages, and Third Party Providers are Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 6 of 10 PageID #:1426 7 ordered to release to Plaintiff the amounts from Defaulting Defendants’ financial accounts within seven (7) calendar days of receipt of this Order. 7. Until Plaintiff has recovered full payment of monies owed to it by any Defaulting Defendant, Plaintiff shall have the ongoing authority to serve this Order on Third Party Providers in the event that any new financial accounts controlled or operated by Defaulting Defendants are identified. Upon receipt of this Order, Third Party Providers shall within seven (7) calendar days: a. locate all accounts and funds connected to Defaulting Defendants’ Seller Aliases and Online Marketplaces, including, but not limited to, any financial accounts connected to the information listed in Schedule A hereto, the e-mail addresses identified in Exhibits to the Declaration of Merian Odesho, and any e-mail addresses provided for Defaulting Defendants by third parties; b. restrain and enjoin such accounts or funds from transferring or disposing of any money or other of Defaulting Defendants’ assets; and c. release all monies, up to the above identified damages award, restrained in Defaulting Defendants’ financial accounts to Plaintiff as partial payment of the above-identified damages within seven (7) calendar days of receipt of this Order. 8. In the event that Plaintiff identifies any additional online marketplaces or financial accounts owned by Defaulting Defendants, Plaintiff may send notice of any supplemental proceeding to Defaulting Defendants by e-mail at the e-mail addresses identified in Exhibits to the Declaration of Merian Odesho and any e-mail addresses provided for Defaulting Defendants by third parties. Case: 1:25-cv-10383 Document #: 53 Filed: 12/23/25 Page 7 of 10 PageID #:1427 8 9. The ten thousand dollar ($10,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. This is a Final Judgment.”
Source: PACER Docket, Case 1:25-cv-10383, Illinois Northern District Court

The default judgment finding is grounded in the court’s independent jurisdiction analysis — notably, the court satisfied itself of personal jurisdiction even without adversarial briefing, relying on defendants’ targeted sales to U.S. and Illinois consumers. Profit awards under § 289 were set at $250 per defendant as a floor for those with no quantifiable sales data, rising to over $11,600 for the highest-revenue alias. The permanent injunction extends to downstream facilitation, meaning third-party platforms face ongoing compliance obligations.

PACER case 1:25-cv-10383 · Public docket record Explore in Eureka ↗
Patent at issue

USD1,028,527 — Bounce Curl ornamental hair brush design

Publication No.USD1028527S
Application No.US29/880941
Patent details
ProductOrnamental design for a hair brush — curl-styling accessory
Cited in actionAugust 29, 2025

U.S. Design Patent No. D1,028,527 (application no. 29/880,941) covers the ornamental design of a hair brush as shown and described in the patent drawings. Issued May 28, 2024, this is a design patent — it protects the visual appearance of the product, not its functional attributes. Design patents in the U.S. have a 15-year term from grant. The ‘D’ designation distinguishes it from utility patents; infringement is assessed by whether an ordinary observer would find the accused product substantially similar to the claimed design.

The strategic significance of this patent lies in its breadth of application to the anonymous marketplace seller ecosystem. Within 15 months of issuance, Bounce Curl was able to identify over 50 seller aliases across major platforms offering a product it contends is substantially similar to its registered design. For brands in the hair care accessories space, this case demonstrates that early design patent filing — combined with vigilant marketplace monitoring — can generate enforceable rights against copycat listings well before infringement volumes become commercially significant.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should you conduct an FTO against USD1,028,527?

Any brand, private-label seller, or manufacturer developing hair brushes — particularly curl-styling accessories — for sale on Amazon, Temu, Walmart, or similar marketplaces should assess their exposure to D1,028,527. The Northern District of Illinois Schedule A mechanism means enforcement can be rapid and asset-freezing. Products that share visual similarity with the Bounce Curl design are at risk even if independently developed, because design patent infringement is assessed by overall visual impression, not intent.

PatSnap Eureka’s FTO Search Agent can map the visual and structural claim scope of D1,028,527, identify earlier prior art that could support an IPR petition challenging validity, and flag related pending design applications in Bounce Curl’s portfolio. For in-house IP teams managing marketplace product lines, Eureka’s design patent landscape analysis provides the clearance data needed before a new SKU goes live on a major platform.

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Related litigation

Similar Schedule A design patent cases in N.D. Illinois

Cases involving hair care and accessories design patents pursued via Schedule A enforcement actions in the Northern District of Illinois against anonymous e-commerce sellers.

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Strategic implications

What this case signals for the hair care accessories IP landscape

Schedule A design patent enforcement is an increasingly viable tool for small brands. This case shows how quickly asset freezes can neutralise anonymous marketplace infringers.

New design patents can be enforced immediately — this case shows how fast

D1,028,527 issued May 2024; suit filed August 2025; default judgment December 2025. Brands with recently issued design patents should not wait for large-scale infringement before acting. The Northern District of Illinois Schedule A pipeline can move from filing to permanent injunction in under four months when defendants fail to appear.

Payment processor freezes are the real enforcement lever in marketplace cases

The operative remedy here is not the injunction — it is the coordinated asset freeze across Amazon, Temu, Walmart, and PayPal. IP owners who secure TROs early can lock infringing revenues before defendants transfer funds offshore. This makes swift filing strategy as important as underlying patent strength in Schedule A cases.

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Frequently asked questions

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Monitor design patent enforcement risk in your product category

If you sell hair care accessories on major marketplaces, D1,028,527 and similar design patents represent active enforcement risk. Use PatSnap Eureka to run an FTO, track new filings, and monitor Schedule A actions before your SKU becomes the target.

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