Deckers Outdoor v. Schedule A Defendants — Default Judgment on UGG Design Patent in 107 Days
Deckers Outdoor Corporation pursued anonymous e-commerce sellers across platforms including Amazon, eBay, AliExpress, and Temu for infringing its UGG boot design patent (US D901,870). The Northern District of Illinois entered a full default judgment with permanent injunctions and profit disgorgement awards within 107 days of filing.
Fast default judgment in UGG design patent counterfeit enforcement
On October 10, 2023, Deckers Outdoor Corporation filed suit in the Northern District of Illinois (Case No. 1:23-cv-14710) against a group of anonymous e-commerce sellers — identified only as ‘The Partnerships and Unincorporated Associations Identified on Schedule A’ — for infringing US Patent D901,870, which protects the ornamental design of Deckers’ iconic UGG footwear. The defendants operated storefronts across major online marketplaces including Amazon, eBay, AliExpress, Temu, DHgate, Walmart, Etsy, and Wish.com, targeting US consumers with counterfeit shoe listings.
On January 25, 2024, Judge Jeremy C. Daniel granted Deckers’ Motion for Entry of Default and Default Judgment in its entirety. The court found personal jurisdiction on the basis that defendants actively targeted US and Illinois consumers through e-commerce stores accepting US dollar payments and offering US shipping. The judgment imposed permanent injunctions barring sale and import of the infringing products, ordered third-party platforms and payment processors to disable seller accounts within seven days, and awarded individualised profit disgorgement under 35 U.S.C. § 289 ranging from $250 to $6,625 per defendant.
The 107-day resolution timeline is consistent with Deckers’ well-established playbook of aggressive Schedule A enforcement actions, which are designed to move quickly before defendants can dissipate assets or evade service. The court’s asset restraining order — obtained at the TRO stage — was critical to ensuring funds were available for collection. The public record does not reveal whether any defendants subsequently sought to vacate the default, nor the total aggregate amount collected across all named sellers.
Filing to settlement in 107 days
107 days — faster than the majority of comparable design patent infringement cases at first instance
Default judgment entered — permanent injunction and profit disgorgement ordered
How default judgment works in Schedule A cases
A default judgment is entered when defendants fail to appear or respond to a complaint within the required timeframe. In Schedule A enforcement actions, anonymous e-commerce sellers frequently fail to engage with US courts, allowing plaintiffs like Deckers to obtain judgment without a contested merits hearing. The court still requires the plaintiff to establish a prima facie case — here, patent infringement under 35 U.S.C. § 271 — before granting the order.
35 U.S.C. § 271 — infringement liability§ 289 profit disgorgement, not reasonable royalty
Deckers elected damages under 35 U.S.C. § 289, the design patent-specific remedy that entitles a patent holder to the infringer’s total profits from the article of manufacture. This is typically more favourable than the reasonable royalty standard under § 284. Per-defendant awards here ranged from $250 to $6,625, reflecting actual traced sales proceeds — amounts that payment processors were ordered to release directly to Deckers within seven days.
§ 289 — total infringer profitsPlatform freeze orders binding Amazon, eBay, Temu, and others
The judgment compelled major third-party platforms and payment processors — including Amazon, eBay, AliExpress, Alibaba, PayPal, Temu, DHgate, Etsy, Walmart, and Wish.com — to disable seller accounts and freeze associated funds within seven calendar days. This multi-platform asset freeze is a hallmark of Schedule A litigation and substantially limits a defendant’s ability to move funds offshore before collection.
Multi-platform asset freezeIllinois courts as a venue of choice for e-commerce IP enforcement
The Northern District of Illinois has become a preferred venue for Schedule A patent and trademark enforcement actions. The court upheld personal jurisdiction over foreign e-commerce sellers on the basis that they accepted US dollar payments and offered shipping to Illinois — a broadly applied standard consistent with prior rulings in this district. Greer, Burns & Crain, Ltd., representing Deckers, is a repeat practitioner of this enforcement model in this court.
N.D. Ill. — Schedule A venueFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Deckers Outdoor Corporation | Company | Global outdoor footwear brand — holder of US Design Patent D901,870 (UGG boot design)Search in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Company | Anonymous e-commerce sellers on major online marketplaces, collectively identified on Schedule ASearch in Eureka ↗ |
| Plaintiff counsel | Amy Crout Ziegler | Attorney | Counsel for Deckers Outdoor CorporationSearch in Eureka ↗ |
| Plaintiff counsel | Justin R. Gaudio | Attorney | Counsel for Deckers Outdoor CorporationSearch in Eureka ↗ |
| Plaintiff counsel | Justin Tyler Joseph | Attorney | Counsel for Deckers Outdoor CorporationSearch in Eureka ↗ |
| Plaintiff counsel | Marcella Deshonda Slay | Attorney | Counsel for Deckers Outdoor CorporationSearch in Eureka ↗ |
| Plaintiff counsel | Quinn Bradley Guillermo | Attorney | Counsel for Deckers Outdoor CorporationSearch in Eureka ↗ |
| Plaintiff counsel | Thomas Joseph Juettner | Attorney | Counsel for Deckers Outdoor CorporationSearch in Eureka ↗ |
| Presiding judge | Judge Jeremy C. Daniel | Chief Judge | Illinois Northern District Court — Chief JudgeSearch in Eureka ↗ |
Stipulation of dismissal — official text
The default judgment is comprehensive in scope: Deckers secured a permanent injunction, individualised profit awards under § 289, mandatory platform delisting across eight major marketplaces, and payment processor asset releases — all within a single order. The court’s personal jurisdiction finding, grounded in defendants’ active targeting of US consumers, follows established N.D. Ill. precedent and is unlikely to be disturbed absent a successful motion to vacate. The award structure — with per-defendant amounts individually calibrated to traced sales — suggests Deckers submitted transaction-level evidence, strengthening the enforceability of each sub-award.
US D901,870 — UGG® Footwear Ornamental Design Patent
US Patent D901,870 protects the ornamental design of the UGG footwear product — one of the most recognised silhouettes in the global footwear market. Issued on November 17, 2020, and filed under application number US 29/699,054, the patent covers the visual appearance of the shoe as depicted in the patent drawings, not its functional elements. Design patents in the US are enforceable against products that, to an ordinary observer, appear substantially the same as the patented design.
The UGG design is commercially significant: it is one of Deckers’ core brand identifiers and has been the subject of multiple enforcement actions in the Northern District of Illinois and elsewhere. For competitors and marketplace sellers, the patent represents a clear risk boundary — particularly for sheepskin-style boot designs with similar toe-box, shaft, and sole proportions. Deckers’ active enforcement posture, combined with the patent’s 2020 issue date, means it will remain in force well into the 2030s, sustaining litigation risk for the footwear supply chain.
Should you run an FTO analysis against US D901,870?
Any company designing, manufacturing, importing, or selling footwear products with a silhouette that could be compared to the UGG boot design should treat US D901,870 as a priority FTO target. This is particularly relevant for brands sourcing from third-party manufacturers in China or selling through Amazon, eBay, Temu, or other US-accessible marketplaces. The threshold in design patent infringement is the ‘ordinary observer’ test — a lower bar than claim-by-claim utility patent analysis — meaning visual similarity alone can create exposure.
PatSnap Eureka’s FTO Search Agent enables product and IP teams to map D901,870’s claim scope against new footwear designs before launch, identify related design patents in Deckers’ portfolio, and monitor for new filings in the UGG design family. Claim monitoring alerts can flag continuation or related applications that could extend protection. For marketplace sellers and ODM footwear suppliers, running this analysis before listing is significantly cheaper than defending a Schedule A action.
Run a freedom-to-operate analysis on USD0901870S to assess your product’s exposure
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What this case signals for the footwear design patent enforcement landscape
Deckers’ rapid default judgment illustrates a mature, repeatable enforcement model that any brand in the footwear or fashion space should understand.
Schedule A litigation is a proven, scalable tool for design patent holders
Deckers’ ability to obtain a full default judgment — including platform freezes and profit disgorgement — within 107 days confirms that Schedule A enforcement is an operationally efficient model for brands with clear design patents. The key prerequisites are a registered design patent, evidence of targeted US sales, and the ability to serve defendants electronically. Brands without registered design patents cannot access this pathway.
Early asset restraint is the critical lever — not the final judgment
The TRO-stage asset restraining order, obtained before defendants were even notified, is what made profit collection possible here. By the time judgment was entered, funds were already frozen at the payment processor level. Practitioners advising brand enforcement programmes should treat TRO asset freeze applications as the primary objective in Schedule A filings, not a secondary step.
Deckers v The — key questions answered
Case 1:23-cv-14710 is a design patent infringement action filed by Deckers Outdoor Corporation in the Northern District of Illinois against anonymous e-commerce sellers for selling counterfeit UGG-style footwear that Deckers alleged infringed US Patent D901,870. The court entered a full default judgment on January 25, 2024.
US D901,870 is a US design patent issued on November 17, 2020, protecting the ornamental appearance of Deckers’ UGG footwear. Design patents cover visual appearance only — not functional features. Infringement is assessed using the ‘ordinary observer’ test: whether an ordinary purchaser would mistake the accused product for the patented design.
The court awarded per-defendant profit disgorgement under 35 U.S.C. § 289, ranging from $250 to $6,625 per seller alias, based on traced sales proceeds. Third-party payment processors including PayPal, Amazon Pay, Alipay, and others were ordered to release frozen funds to Deckers within seven days of receiving the order. The $10,000 surety bond posted by Deckers was also returned.
The Northern District of Illinois found personal jurisdiction because the defendants actively targeted US and Illinois consumers — operating e-commerce stores that accepted US dollar payments and offered shipping to the US, including Illinois. This approach to jurisdiction in Schedule A cases is well-established in this district and does not require physical presence in the US.
A Schedule A case is an enforcement action filed against a large group of anonymous online sellers whose identities are disclosed in a sealed schedule attached to the complaint. The Northern District of Illinois is a preferred venue because its courts have developed consistent procedures for granting TROs, asset freezes, and electronic service on foreign defendants — making it operationally efficient for brand enforcement programmes.
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