Deckers Outdoor v. Schedule A Defendants: UGG® Design Patent Default Judgment
Deckers Outdoor Corp. secured a default judgment and permanent injunction against anonymous e-commerce sellers infringing UGG® footwear design patent USD927161S. Filed in the Northern District of Illinois, the case resolved in 353 days with disgorgement of profits ordered under 35 U.S.C. § 289 and account freezes across major platforms including Amazon, Temu, TikTok, and PayPal.
UGG® design patent enforcement against Schedule A counterfeit sellers
On July 23, 2024, Deckers Outdoor Corp. — owner of the UGG® brand — filed suit in the Northern District of Illinois against a group of anonymous defendants identified only as ‘Partnerships and Unincorporated Associations Identified on Schedule A,’ a standard litigation format for targeting coordinated counterfeit sellers operating across multiple e-commerce marketplaces. The asserted patent is USD927161S (application no. 29/712480), a design patent protecting the ornamental appearance of UGG® footwear products.
The case concluded on July 11, 2025, through a default judgment after defendants failed to appear or contest the action. Judge Franklin U. Valderrama granted Deckers’ Motion for Entry of Default and Default Judgment in its entirety, entering a permanent injunction barring defendants from offering, selling, or importing the infringing product. Damages were calculated as disgorgement of profits under 35 U.S.C. § 289 — the design patent profits statute — rather than compensatory damages, and third-party platform providers including Amazon, Temu, TikTok, eBay, and PayPal were ordered to freeze and release defendants’ funds within specified timeframes.
The 353-day resolution is consistent with typical Schedule A default proceedings in the Northern District of Illinois, which have become a favoured venue for brand owners targeting offshore e-commerce infringers. The outcome suggests defendants either could not be located for service or strategically declined to defend. The public record does not disclose the specific monetary amounts awarded to Deckers under the § 289 profits calculation, as those figures appear in the per-defendant schedule referenced in the judgment but not reproduced in publicly available filings.
Filing to Default Judgment in 353 days
353 days — faster than the N.D. Ill. median for default judgment IP cases
Default judgment entered: what the ruling means for both parties
Default judgment: defendants forfeit all defenses by non-appearance
A default judgment under Fed. R. Civ. P. 55 is entered when a defendant fails to plead or otherwise defend. Here, all Schedule A defendants failed to appear, allowing the court to accept Deckers’ well-pleaded allegations as true and award the relief sought. This mechanism is commonly deployed in Schedule A brand enforcement actions where offshore sellers are unlikely to contest proceedings and the primary objective is injunctive relief and asset freezing at the platform level.
Fed. R. Civ. P. 55 defaultDeckers obtains permanent injunction and platform-level asset freeze
Deckers secured the full relief sought: a permanent injunction barring defendants from selling or importing the infringing UGG® product, plus disgorgement of profits under 35 U.S.C. § 289. Critically, the order compels major third-party platforms — including Amazon, Temu, TikTok, PayPal, and Alibaba — to freeze and release defendants’ funds within ten business days. The $10,000 cash bond posted at the TRO stage is also returned to Deckers’ counsel.
Full relief granted — § 289 profitsDefendants face permanent sales ban and frozen marketplace accounts
By failing to appear, Schedule A defendants lost any opportunity to challenge validity, non-infringement, or damages quantum. The permanent injunction covers not only current sales but also affiliates, agents, and any new entities formed to circumvent the order. All financial accounts connected to defendants’ seller aliases across listed platforms are subject to permanent restraint, with funds released directly to Deckers as partial satisfaction of the profits award. The order also grants Deckers ongoing authority to serve it on newly identified accounts.
Permanent injunction — account freeze§ 289 profits remedy amplifies deterrence in design patent enforcement
Design patent holders can recover an infringer’s total profits from the sale of any article applying the patented design under 35 U.S.C. § 289 — without the need to apportion to the infringing feature. Combined with Schedule A procedures and TRO-stage platform cooperation, this creates a powerful enforcement template. The Deckers judgment is consistent with broader industry practice among footwear and fashion brands using N.D. Ill. as a preferred venue for multi-defendant e-commerce IP enforcement.
Design patent § 289 enforcementFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Deckers Outdoor Corp. | Company | Global footwear brand owner (UGG®, HOKA) — holder of design patent USD927161SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous e-commerce sellers across Schedule A marketplace platformsSearch in Eureka ↗ |
| Plaintiff counsel | Amy Crout Ziegler | Attorney | Counsel for Deckers Outdoor Corp.Search in Eureka ↗ |
| Plaintiff counsel | Justin R. Gaudio | Attorney | Counsel for Deckers Outdoor Corp.Search in Eureka ↗ |
| Plaintiff counsel | Justin Tyler Joseph | Attorney | Counsel for Deckers Outdoor Corp.Search in Eureka ↗ |
| Plaintiff counsel | Thomas Joseph Juettner | Attorney | Counsel for Deckers Outdoor Corp.Search in Eureka ↗ |
| Plaintiff law firm | Greer, Burns & Crain, Ltd. | Law Firm | Representing Deckers Outdoor Corp.Search in Eureka ↗ |
| Presiding judge | Judge Franklin U. Valderrama | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s default judgment order accepts Deckers’ pleaded facts as established and grants the entirety of the requested relief. The § 289 profits award — calculated per-defendant via a schedule incorporated by reference — reflects the design patent statute’s total-profits rule rather than apportioned compensatory damages. The permanent injunction’s broad scope, extending to affiliates and new entities, is standard in Schedule A proceedings and is designed to prevent circumvention through shell account creation. The order’s authority to serve third-party platforms on an ongoing basis for newly identified accounts is a notable forward-looking enforcement mechanism.
USD927161S — UGG® footwear ornamental design patent
USD927161S (application no. 29/712480) is a U.S. design patent protecting the ornamental appearance of UGG® footwear. Design patents cover the non-functional visual characteristics of a product — here, the distinctive look of UGG® shoes or boots as embodied in the patent’s drawings. Design patents grant a term of 15 years from grant and are infringed by any article whose appearance is substantially similar to the patented design in the eyes of an ordinary observer.
For Deckers, USD927161S represents a critical IP layer protecting the visual identity of one of the world’s most recognisable footwear brands. UGG® products command significant retail premiums, making them high-value counterfeiting targets on platforms such as Amazon, Temu, and TikTok Shop. Design patent protection — especially when paired with trademark rights — allows Deckers to pursue both injunctive and profits-based remedies simultaneously, and the § 289 total-profits rule means even modest sales volumes by multiple defendants can yield meaningful aggregate recovery.
Should you run an FTO against USD927161S before launching footwear products?
Any brand, private-label operator, or ODM supplier considering footwear products with a silhouette or visual profile resembling the UGG® portfolio should treat an FTO analysis against Deckers’ design patent estate — including USD927161S — as a prerequisite to marketplace launch. The N.D. Ill. default judgment record demonstrates that Deckers actively monitors e-commerce platforms and moves quickly from filing to TRO to default relief. Products listed on Amazon, Temu, TikTok Shop, or Alibaba are particularly exposed given the platform cooperation mechanisms now embedded in Deckers’ enforcement orders.
PatSnap Eureka’s FTO Search Agent can map USD927161S and the broader Deckers design patent portfolio against your product’s visual characteristics, identify design-around opportunities, and flag co-pending applications that may extend protection. Eureka’s claim chart tools and prosecution history analysis help product teams assess ordinary observer similarity risk before committing to tooling or inventory — dramatically reducing the cost of a design conflict identified post-launch.
Run a freedom-to-operate analysis on USD0927161S to assess your product’s exposure
Run FTO in Eureka →Similar UGG® and footwear design patent enforcement cases in N.D. Ill.
Cases involving footwear design patent enforcement and Schedule A proceedings in the Northern District of Illinois, including comparable Deckers Outdoor actions and § 289 profits awards.
What this case signals for the footwear and e-commerce IP landscape
Deckers’ judgment illustrates how design patents and Schedule A procedures combine to create fast, platform-level enforcement against anonymous online infringers.
Schedule A + design patent = the dominant online brand enforcement template
The N.D. Ill. Schedule A procedure, combined with design patent claims and § 289 profits disgorgement, has become the go-to enforcement toolkit for footwear and consumer goods brands. The ability to freeze marketplace accounts at the TRO stage — before defendants can liquidate funds — is a structural advantage that compensatory damages frameworks alone cannot replicate.
Platform cooperation is now a core pillar of design patent strategy
The judgment’s explicit enumeration of Amazon, TikTok, Temu, eBay, PayPal, and Alibaba as compelled cooperators reflects how IP enforcement has shifted from court-to-defendant to court-to-platform. Brands without established platform notice protocols risk slower asset recovery even when they prevail on the merits.
Deckers v Partnerships — key questions answered
The Northern District of Illinois entered a default judgment in favour of Deckers Outdoor Corp. on July 11, 2025. Defendants failed to appear, and Judge Valderrama granted a permanent injunction and disgorgement of profits under 35 U.S.C. § 289 for infringement of UGG® design patent USD927161S. Third-party platforms including Amazon, Temu, TikTok, and PayPal were ordered to freeze and release defendants’ funds.
USD927161S (application no. 29/712480) is a U.S. design patent owned by Deckers Outdoor Corp. that protects the ornamental appearance of UGG® footwear products. Design patents cover the visual, non-functional characteristics of a product and are infringed when an accused article is substantially similar to the patented design in the eyes of an ordinary observer.
Section 289 of the Patent Act allows a design patent holder to recover the total profits the infringer earned from selling any article that applies the patented design. Unlike utility patent damages, no apportionment to the infringing feature is required. This can result in large awards relative to litigation cost, particularly in high-volume counterfeit sales scenarios, making § 289 a powerful tool in e-commerce enforcement actions.
Schedule A proceedings allow plaintiffs to file against large groups of anonymous defendants — typically offshore e-commerce sellers — identified by seller aliases rather than legal names. The procedure is frequently used in the Northern District of Illinois. It enables TRO applications with platform-level asset freezes before defendants are formally served, making it effective where defendants are unlikely to appear or can rapidly dissipate funds.
The judgment names Amazon, Temu (WhaleCo), TikTok (ByteDance entities), eBay, Alibaba, Wish.com, Walmart, Etsy, DHgate, PayPal, Alipay, Ant Financial, and Amazon Pay. Each is required to disable advertisements, freeze financial accounts connected to defendants’ seller aliases, and release funds to Deckers within ten business days of receiving the order. Deckers retains ongoing authority to serve the order on these providers when new accounts are identified.
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