Deckers Outdoor v. Schedule A: UGG Design Patent Default Judgment in 92 Days
Deckers Outdoor Corporation secured a default judgment against 28 e-commerce sellers operating through Alibaba and Amazon storefronts, all found to have infringed U.S. Design Patent D927,161 — the registered UGG boot design. The Illinois Northern District Court awarded damages ranging from $250 to $67,135 per defendant and issued permanent injunctions, resolving the case in just 92 days.
UGG Design Patent Enforcement: 28 E-Commerce Sellers Defaulted
On January 9, 2025, Deckers Outdoor Corporation filed suit in the U.S. District Court for the Northern District of Illinois against a Schedule A roster of e-commerce storefronts — predominantly China-based sellers operating across Alibaba and Amazon marketplaces — alleging infringement of U.S. Design Patent D927,161, which protects the ornamental design of the iconic UGG boot. The defendants were identified by seller aliases rather than corporate names, a common litigation structure in Schedule A counterfeit enforcement actions.
The court entered a temporary restraining order and preliminary injunction early in the proceedings, freezing defendants’ financial accounts held by PayPal, Alibaba, and Amazon. With no defendant appearing to contest the claims, Judge Sharon Johnson Coleman granted Deckers’ motion for entry of default and default judgment on April 11, 2025. The court awarded infringer’s profits under 35 U.S.C. § 289, with per-defendant awards ranging from a statutory minimum of $250 up to $67,135 for the highest-volume seller, TaiYuanKuoSaiShangMaoYouXianGongSi.
The 92-day resolution is consistent with the accelerated timelines typical of Schedule A design patent actions, where TRO-based asset freezes and electronic service combine to produce rapid default outcomes. The public record does not disclose how restrained funds mapped to the full damages awards for each defendant, nor whether any sellers subsequently moved to vacate the default. The one-defendant carve-out — bebealy (Defendant No. 21) — suggests at least one party may have engaged with the proceedings, though the record is silent on that defendant’s ultimate status.
Filing to Default Judgment in 92 days
92 days from filing to default judgment — well below the district average for design patent enforcement actions
Default judgment granted: what the ruling means for Deckers and the market
Default judgment under Rule 55 — liability conceded by silence
When defendants fail to answer a complaint, the court may enter default and subsequently default judgment. Here, all 28 Defaulting Defendants failed to plead within the required period. The court treated the well-pleaded allegations of U.S. Design Patent D927,161 infringement as admitted, established personal jurisdiction based on U.S.-targeted sales, and awarded damages without a merits trial. This is a plaintiff win on the record, not a negotiated or contested outcome.
Rule 55 Default JudgmentDeckers wins injunctions, damages, and asset releases
Deckers obtained permanent injunctions barring all 28 defendants from offering, selling, or importing the infringing product and requiring Alibaba, Amazon, and PayPal to disable storefronts and release frozen funds within seven days. Damages were assessed under 35 U.S.C. § 289 (infringer’s total profits), and the $10,000 surety bond posted for the TRO was returned. The judgment also grants Deckers ongoing authority to serve the order on third-party providers if new accounts are identified.
Permanent injunction + § 289 damages28 sellers face frozen assets and permanent market ban
Defaulting Defendants received no merits hearing. Their financial accounts — held through PayPal, Alibaba, and Amazon — were permanently restrained up to the individual damages award amount and ordered released to Deckers within seven days. A default judgment of this type is enforceable but leaves open a motion to vacate under Rule 60(b) if a defendant can show good cause, excusable neglect, or lack of proper service. The public record is silent on any such challenge being filed.
Assets frozen; motion to vacate possibleSchedule A tactics remain Deckers’ sharpest enforcement tool
This case reinforces that Schedule A design patent enforcement — combining TRO asset freezes, electronic service, and rapid default — is highly effective against marketplace counterfeiters. The carve-out of bebealy from the default motion suggests defendants who engage can alter the litigation trajectory. For competitors and marketplace operators, the Alibaba and Amazon third-party compliance obligations embedded in the order signal continued pressure on platforms to act as enforcement partners, not passive hosts.
Platform enforcement; Schedule A modelFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Deckers Outdoor Corp. | Company | Footwear brand and IP licensor — holder of U.S. Design Patent D927,161 (UGG boot)Search in Eureka ↗ |
| Defendant | The Partnerships And Unincorporated Associations Identified On Schedule A, | Individual | 28 anonymous e-commerce storefronts, primarily China-based, selling counterfeit UGG-design bootsSearch in Eureka ↗ |
| Plaintiff counsel | Amy Crout Ziegler | Attorney | Counsel for Deckers Outdoor Corp.Search in Eureka ↗ |
| Plaintiff counsel | Andrew Daniel Burnham | Attorney | Counsel for Deckers Outdoor Corp.Search in Eureka ↗ |
| Plaintiff counsel | Jennifer Van Nacht | 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 Sharon Johnson Coleman | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order establishes liability under 35 U.S.C. § 271 without a contested merits determination — the court accepted Deckers’ well-pleaded allegations as admitted due to non-appearance. The § 289 profit awards vary significantly across defendants, reflecting restrained account balances rather than litigated damages figures. The permanent injunction extends to affiliates and agents, and the order’s third-party compliance mechanism binding Alibaba, Amazon, and PayPal gives the judgment extraterritorial operational reach. Notably, the order expressly preserves Deckers’ right to serve supplemental proceedings against newly identified accounts, making this a continuing enforcement instrument rather than a one-time resolution.
US D927,161 — UGG Boot Ornamental Design Patent
U.S. Design Patent D927,161 protects the ornamental design of the UGG boot — specifically its visual appearance and silhouette as depicted in the patent drawings. The patent issued on August 10, 2021, from application No. 29/712,480. Design patents under 35 U.S.C. § 171 protect the ornamental characteristics of a functional article, and infringement is assessed by whether an ordinary observer would find the accused design substantially similar to the patented design. The UGG design is one of the most globally recognised silhouettes in casual footwear.
For footwear brands and IP competitors, D927,161 represents a significant design enforcement asset. Because design patents are infringed by visual similarity — not functional equivalence — the barrier to establishing infringement against lookalike boot designs is structurally lower than for utility patents. The § 289 total-profits remedy further amplifies commercial risk for infringers. Any manufacturer, retailer, or marketplace seller offering a boot design substantially similar to the UGG silhouette faces direct infringement exposure, particularly if selling into the U.S. market through Amazon or Alibaba storefronts.
Should you run an FTO against US D927,161?
Any company developing, sourcing, or distributing boots with a visual profile resembling the UGG silhouette — particularly sheepskin-style or shearling-lined ankle boots — should conduct a freedom-to-operate analysis against D927,161 before entering the U.S. market. This is equally relevant for private-label footwear brands, OEM manufacturers supplying U.S. retailers, and marketplace sellers on Amazon or Alibaba. The default judgment in this case confirms that Deckers actively enforces this patent through rapid TRO proceedings.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of D927,161 against your product design portfolio, identify prior art that may limit the patent’s enforceability, and flag related design patents in Deckers’ portfolio that could present additional risk vectors. For in-house IP teams and product counsel, early FTO clearance is substantially cheaper than defending a Schedule A TRO action with frozen payment accounts.
Run a freedom-to-operate analysis on USD0927161S to assess your product’s exposure
Run FTO in Eureka →Similar UGG Design Patent Schedule A Cases in N.D. Illinois
Related Schedule A design patent enforcement actions filed in the Northern District of Illinois targeting e-commerce counterfeiters of UGG and footwear design patents.
What this case signals for the footwear design patent IP landscape
Deckers’ rapid default judgment illustrates how design patent holders can combine § 289 profits recovery with TRO asset freezes to neutralise marketplace counterfeiters before trial.
§ 289 total-profits rule makes design patents highly lethal against counterfeiters
Under 35 U.S.C. § 289, a design patent infringer owes the patent holder their total profits from the infringing article — not a reasonable royalty. Combined with pre-judgment asset freezes through payment processors, this creates a mechanism that extracts revenue already earned by counterfeiters. Brands with registered design patents should audit their enforcement readiness against marketplace sellers.
Electronic service and TRO asset freezes define Schedule A speed
The 92-day case lifecycle reflects a well-practised playbook: file, obtain TRO with asset freeze, serve electronically, await non-response, move for default. For brand owners whose designs are counterfeited on Alibaba or Amazon, the Northern District of Illinois remains a preferred venue for this model. Early registration of design patents is the prerequisite — D927,161’s 2021 issue date enabled this 2025 action.
Deckers v Partnerships — key questions answered
The Northern District of Illinois entered a default judgment in favour of Deckers Outdoor Corporation on April 11, 2025. All 28 named defendants failed to appear. The court granted permanent injunctions and awarded damages under 35 U.S.C. § 289 ranging from $250 to $67,135 per defendant. Asset freezes via PayPal, Alibaba, and Amazon were made permanent and funds ordered released to Deckers.
U.S. Design Patent D927,161 protects the ornamental design of the UGG boot — its visual appearance and silhouette as depicted in the patent drawings. It issued on August 10, 2021 from application 29/712,480. Design patents protect aesthetic appearance, not function; infringement turns on whether an ordinary observer finds the accused design substantially similar to the patented one.
Damages were awarded under 35 U.S.C. § 289, which entitles a design patent holder to the infringer’s total profits from the sale of infringing articles. Awards ranged from a minimum of $250 (for 20 defendants) to $67,135 for the highest-volume seller. The awards likely reflect the balances frozen in defendants’ payment processor accounts at the time of the TRO, though the court order does not detail the underlying sales calculation methodology.
The publicly available judgment excludes bebealy (Defendant No. 21) from the default judgment motion. The record does not state the reason, but this carve-out typically indicates the defendant made contact with the court or plaintiff’s counsel, filed an appearance, or reached a separate resolution. The public record is silent on bebealy’s ultimate disposition.
The order required these third-party providers, within seven calendar days of receipt, to: (1) disable and cease displaying advertisements associated with defaulting defendants; (2) permanently restrain financial accounts from transferring funds up to the damages award; and (3) release all restrained funds to Deckers. The order also grants Deckers ongoing authority to serve supplemental proceedings if new accounts controlled by defendants are identified.
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