Bounce Curl v. Schedule A Defendants: Default Judgment on Hair Brush Design Patents
Bounce Curl, LLC secured a default judgment in the Northern District of Illinois against a network of online marketplace sellers accused of exactly copying its patented curl brush designs. The court found willful infringement of two design patents and associated copyrights, issuing a permanent injunction and ordering asset freezes across platforms including Amazon, eBay, and Temu. The case closed in 179 days.
Design patent enforcement against e-commerce counterfeiters: a swift default win
Bounce Curl, LLC filed suit on 29 July 2024 in the U.S. District Court for the Northern District of Illinois, asserting infringement of two design patents — USD1025614S and USD1028527S — covering its signature curl hair brush. Defendants comprised a ‘Schedule A’ roster of online marketplace sellers, including named entities such as Adi Shavit, HANRICH, MAJA STORE, and ZHENGDONGZHUNMINGSHANGHANG, alongside numerous unnamed partnerships and associations operating storefronts across Amazon, eBay, DHGate, and Temu.
With no defendants entering an appearance or contesting the claims, Judge Georgia N. Alexakis granted Bounce Curl’s Motion for Entry of Default and Default Judgment on 24 January 2025. The court found both design patents valid and enforceable, concluded that defendants had willfully infringed by exactly copying the patented product, and issued a permanent injunction. Third-party platform providers were ordered to freeze connected accounts and release restrained funds to Bounce Curl within 14 days of the order.
Resolution in 179 days is notably swift for patent litigation, though the default posture — defendants neither appeared nor contested — largely explains the pace. The verdict’s explicit finding of egregious and willful conduct, combined with the carve-out protecting Candy Brush, LLC’s designs, suggests some complexity in the underlying marketplace relationships. The actual quantum of statutory damages awarded per defendant remains redacted from the public record in the chart referenced in the judgment.
Filing to Default Judgment in 179 days
179 days — faster than the typical N.D. Ill. patent case; default posture accelerated resolution
Default judgment entered: what the ruling means for both parties
Default judgment: court rules without defendant contest
A default judgment is entered when defendants fail to appear or respond. The court accepts well-pleaded allegations as true and assesses appropriate relief. Here, Judge Alexakis found liability for both patent infringement under 35 U.S.C. § 271 and copyright infringement under 17 U.S.C. § 501 without adversarial testing of the merits, consistent with the Schedule A e-commerce enforcement model commonly used in N.D. Ill.
No defendants appearedBounce Curl secures injunction and asset recovery
Bounce Curl obtained a permanent injunction blocking all infringing sales, a platform-level takedown mechanism covering Amazon, eBay, Temu, and PayPal, and the release of frozen funds from defendants’ accounts as partial payment of statutory damages. The willfulness finding strengthens any supplemental enforcement proceedings Bounce Curl may initiate under Fed. R. Civ. P. 69 against defendants with residual assets.
Permanent injunction grantedSellers face permanent ban and asset seizure
Non-appearing defendants are now subject to a permanent injunction, account disablement across major e-commerce platforms, and financial account freezes. The willfulness finding exposes them to enhanced damages if Bounce Curl pursues supplemental proceedings. Notably, the court carved out Candy Brush, LLC’s designs from the injunction’s scope, suggesting at least one party successfully negotiated exclusion from the order’s reach.
Accounts frozen across platformsDesign patent enforcement via Schedule A is a growing litigation model
This case exemplifies an increasingly prevalent IP enforcement strategy: filing omnibus actions against anonymous online marketplace sellers, obtaining TROs and asset freezes, and securing default judgments at speed. For brands in the beauty and personal care space, it demonstrates the viability of design patents as enforceable assets against counterfeit operations. Competitors and platform operators should note the multi-platform reach of such orders.
E-commerce enforcement modelFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Bounce Curl, LLC | Company | Hair care brand and design patent holder — owner of USD1025614S and USD1028527SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations identified in Schedule A | Individual | Network of online marketplace sellers alleged to have copied and sold infringing curl brush productsSearch in Eureka ↗ |
| Co-Defendant | Adi Shavit | Individual | Search in Eureka ↗ |
| Co-Defendant | cheweihao | Individual | Search in Eureka ↗ |
| Co-Defendant | deyundashanghang | Individual | Search in Eureka ↗ |
| Co-Defendant | duanqinlongshangmao | Individual | Search in Eureka ↗ |
| Co-Defendant | HANRICH | Individual | Search in Eureka ↗ |
| Co-Defendant | luhuamengcheng | Individual | Search in Eureka ↗ |
| Co-Defendant | MAJA STORE | Individual | Search in Eureka ↗ |
| Co-Defendant | Others too numerous to list: baodingjinyueshangwu, Ahamed Maja Amzy Gasun | Individual | Search in Eureka ↗ |
| Co-Defendant | yuantedinggu | Individual | Search in Eureka ↗ |
| Co-Defendant | ZHENGDONGZHUNMINGSHANGHANG | Individual | Search in Eureka ↗ |
| Plaintiff counsel | Kevin John Keener | Attorney | Counsel for Bounce Curl, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Keener & Associates PC | Law Firm | Representing Bounce Curl, LLCSearch in Eureka ↗ |
| Presiding judge | Judge Georgia N Alexakis | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment language is notably emphatic: the court characterised defendants’ conduct as ‘egregious, willful, wanton, malicious, and deliberate,’ findings that go beyond bare liability. This phrasing typically signals the court’s intent to support enhanced statutory damages under 35 U.S.C. § 289 and 17 U.S.C. § 504. The Candy Brush carve-out in Paragraphs 9–10 is unusual in a default judgment context, suggesting Bounce Curl itself agreed to limit the injunction’s scope, possibly to avoid broader marketplace disruption or pre-empt a third-party challenge.
USD1025614S & USD1028527S — Bounce Curl hair brush ornamental designs
USD1025614S (App. No. 29/920,466) and USD1028527S (App. No. 29/880,941) are U.S. design patents protecting the ornamental appearance of Bounce Curl’s hair brush. Design patents under 35 U.S.C. § 171 cover only the visual, non-functional aspects of a product — meaning competitors may produce functionally equivalent brushes provided the overall ornamental impression differs sufficiently from the patented designs. Both patents were asserted alongside copyright registrations, reflecting Bounce Curl’s layered IP strategy.
For brands in the hair care tools segment, design patents on consumer products are increasingly enforceable assets — particularly against marketplace sellers who replicate appearance rather than underlying technology. The court’s finding that defendants ‘exactly copied’ the patented product underscores the evidential value of design patent claims when visual similarity is stark. Brands in adjacent personal care categories should audit whether their hero products carry design patent protection before market expansion.
Should you run an FTO against USD1025614S and USD1028527S?
Any brand, manufacturer, or marketplace seller developing or sourcing curl brushes, detangling brushes, or styling brush products should assess freedom to operate against Bounce Curl’s two design patents. The court’s broad injunction and willfulness finding establish that Bounce Curl actively enforces these rights across global e-commerce channels. Even minor visual similarity to the patented designs may trigger enforcement, given the default judgment precedent now on record.
PatSnap Eureka’s FTO Search Agent can map the ornamental claim scope of USD1025614S and USD1028527S against your product’s design drawings, flag visually similar granted patents in the brush and hair tool category, and surface prior art that may support a design-around. R&D and sourcing teams can generate an FTO memo in minutes — critical before launching any new brush SKU in markets where Bounce Curl operates.
Run a freedom-to-operate analysis on USD1025614S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois
Explore comparable hair tool and consumer goods design patent enforcement actions filed in the Northern District of Illinois using the Schedule A multi-defendant model.
What this case signals for the beauty brand IP enforcement landscape
Bounce Curl’s swift default win illustrates how design patents and the Schedule A enforcement model can neutralise counterfeit networks across major e-commerce platforms.
Design patents are potent tools against e-commerce copycats
USD design patents protect ornamental appearance rather than function — making them well-suited to enforcement against sellers who exactly copy a product’s look. Bounce Curl’s ability to assert two design patents simultaneously, alongside copyrights, maximised the damages and injunction scope available from a single filing.
Schedule A actions compress enforcement timelines significantly
By naming multiple anonymous sellers in a single action with a supporting Schedule A, Bounce Curl resolved infringement against at least ten identified entities in 179 days. Brands monitoring counterfeit activity on Amazon, Temu, or eBay should assess whether consolidated Schedule A filings in N.D. Ill. fit their enforcement strategy.
Bounce v Partnerships — key questions answered
Bounce Curl asserted two U.S. design patents: USD1025614S (App. No. 29/920,466) and USD1028527S (App. No. 29/880,941), both covering the ornamental design of its curl hair brush. The complaint also included copyright infringement claims. The court found both patents valid, enforceable, and willfully infringed.
A Schedule A action names multiple anonymous or pseudonymous online sellers in a single complaint, with a supporting schedule identifying defendants by their marketplace usernames or storefronts. This model is common in N.D. Ill. for counterfeit enforcement because it allows a plaintiff to obtain a single TRO and asset freeze across dozens of accounts simultaneously. Bounce Curl used this approach to target sellers on Amazon, eBay, DHGate, and Temu in one filing.
The default judgment issued a permanent injunction barring infringing sales, ordered third-party platforms including Amazon, eBay, Temu, and PayPal to freeze defendants’ accounts within 7 days and release funds to Bounce Curl within 14 days, awarded statutory damages per defendant under 35 U.S.C. § 289 and 17 U.S.C. § 504, and preserved Bounce Curl’s right to pursue supplemental collection proceedings under Fed. R. Civ. P. 69.
The judgment expressly excludes Candy Brush, LLC’s designs — specifically designs numbered 2035, 2037, 2038, and 2041 — from the injunction’s scope and voided prior TRO-based takedowns of Candy Brush products. The public record does not fully explain this exclusion, but it suggests either a licensing arrangement, a disputed ownership claim, or a negotiated agreement between Bounce Curl and Candy Brush prior to judgment. No adverse inference is to be drawn from the listed designs, per the court’s order.
The court’s willfulness finding — characterising defendants’ conduct as egregious, wanton, and deliberate — is legally significant because it supports enhanced or maximum statutory damages under both patent and copyright law. Under 35 U.S.C. § 289, a design patent plaintiff may recover the infringer’s total profits. Under 17 U.S.C. § 504(c)(2), willful copyright infringement can yield statutory damages up to $150,000 per work. The specific per-defendant award figures are contained in a chart referenced but not fully reproduced in the public judgment text.
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