Deckers Outdoor v. Schedule A Defendants: UGG Design Patent Default Judgment
Deckers Outdoor Corp. obtained a default judgment and permanent injunction against anonymous online marketplace sellers accused of infringing its UGG footwear design patent (USD927161S). The Illinois Northern District Court awarded $26,668 in infringer profits under 35 U.S.C. § 289, with Amazon and PayPal ordered to freeze and release defendant funds within seven days.
UGG maker wins default judgment against ghost-seller network
Deckers Outdoor Corp., the California-based footwear company behind the UGG brand, filed suit on 7 January 2025 in the U.S. District Court for the Northern District of Illinois against a group of anonymous online sellers — the so-called ‘Schedule A’ defendants — alleging direct and indirect infringement of design patent USD927161S, which covers the ornamental appearance of UGG footwear. The case is a textbook example of the ‘Schedule A’ enforcement model widely used against counterfeit and copycat e-commerce sellers.
The case closed on 18 July 2025 via default judgment after defendants failed to appear or respond. Judge Joan B. Gottschall granted Deckers’ motion, permanently enjoining defendants from offering, selling, or importing the infringing product and awarding $26,668 in profits under § 289 — the design patent damages statute that entitles a patent holder to the infringer’s total profits from applicable articles. Third-party platforms PayPal and Amazon were ordered to freeze and remit defendant funds within seven calendar days.
At 192 days from filing to closure, the timeline is consistent with uncontested Schedule A actions, where the absence of a defence typically accelerates resolution. What remains unknown from the public record is the total number of discrete seller aliases captured under ‘Schedule A,’ the volume of infringing units sold across each marketplace, and whether any defendants subsequently moved to vacate the default. The platform-enforcement mechanism — directing Amazon and PayPal to act as financial intermediaries — is increasingly standard in these proceedings and signals Deckers’ systematic approach to online design-patent enforcement.
Filing to Default Judgment in 192 days
192 days — faster than most contested district court IP cases, consistent with uncontested default proceedings
Default judgment entered: what the order means for both sides
Default judgment: liability without contest
A default judgment is entered when defendants fail to appear or respond to a complaint. The court accepts the well-pleaded allegations as true and proceeds to assess remedies. Here, Judge Gottschall found defendants liable for patent infringement under 35 U.S.C. § 271 without any merits adjudication — meaning the design patent’s validity was never challenged on the record, leaving USD927161S fully intact and unadjudicated on the merits.
Uncontested liability findingDeckers secures injunction and profit disgorgement
Deckers obtained everything it sought: a permanent injunction barring defendants from selling or importing the infringing footwear, $26,668 in profits under § 289, and direct access to defendant funds held by Amazon and PayPal. The § 289 remedy is particularly powerful for design patents — it captures total article profits, not apportioned damages. The platform enforcement mechanism ensures near-immediate collection without separate judgment enforcement proceedings.
Full injunctive and monetary reliefPermanent ban and frozen marketplace accounts
Defaulting defendants are permanently enjoined from selling the identified infringing product under any seller alias. Financial accounts linked to their marketplace profiles — on Amazon and via PayPal — were immediately frozen and funds remitted to Deckers. The order also bars corporate restructuring or alias changes designed to circumvent the injunction, making re-entry to the same marketplaces under new identities legally risky.
Platform accounts frozen and remittedDesign patent enforcement via marketplace platforms scales effectively
This outcome reinforces the commercial viability of the Schedule A enforcement model for design patents. By directing Amazon and PayPal to act as enforcement intermediaries, Deckers bypassed the traditional judgment-collection process. For other footwear and consumer goods brands holding design patents, this case is consistent with a pattern of using § 289 profit disgorgement and platform cooperation to deter copycat sellers at scale — particularly those operating across multiple marketplace aliases.
Scalable platform enforcement modelFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Deckers Outdoor Corp. | Company | Global footwear brand owner (UGG) — holder of design patent USD927161SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous e-commerce sellers on online marketplaces, identified collectively on Schedule ASearch 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 Joan B. Gottschall | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order makes two legally distinct findings: first, liability under 35 U.S.C. § 271 for direct and indirect infringement; second, damages under § 289 based on infringer profits. The § 289 award of $26,668 suggests the court accepted Deckers’ profit evidence as submitted, consistent with default judgment procedure where uncontested factual allegations are taken as true. The permanent injunction’s reach — covering affiliates, new entities, and circumvention devices — reflects standard Northern District of Illinois Schedule A practice and is designed to foreclose defendants from re-entering the market under different identities.
USD927161S — UGG footwear ornamental design patent
USD927161S (application number US29/712480) is a U.S. design patent protecting the ornamental appearance of UGG-branded footwear. Design patents cover only the non-functional, aesthetic aspects of a product — meaning competitors are free to make functionally similar boots, provided they do not replicate the specific visual design claimed. The patent’s scope is defined by its drawings, and infringement is assessed under the ‘ordinary observer’ test: whether an ordinary observer, familiar with the prior art, would be deceived into thinking the accused design is the same as the patented design.
For a brand like Deckers, design patents on iconic silhouettes such as the UGG boot are a cornerstone of IP strategy — particularly against low-cost online counterfeiters who replicate the look rather than the function of a product. USD927161S represents a direct enforcement asset against marketplace sellers. Given that this patent has not been challenged in inter partes review or in any contested district court proceeding, its enforceability remains untested on the merits — a factor that sophisticated competitors and future defendants should weigh when assessing litigation risk.
Should you run an FTO analysis against USD927161S?
Any manufacturer, importer, or online seller of footwear with a visual profile similar to the UGG aesthetic should assess exposure to USD927161S before listing products on Amazon, eBay, or other U.S.-facing marketplaces. This case demonstrates that Deckers actively monitors marketplace listings and pursues default judgments — including platform-level fund seizures — against sellers who do not engage. The ‘ordinary observer’ standard for design patent infringement can capture products that are not identical but are visually similar.
PatSnap Eureka’s FTO Search Agent can map the claim scope of USD927161S against your product’s design drawings, identify prior art that might support an IPR challenge, and flag other Deckers design patents in the footwear category that may present parallel risk. For brands and distributors operating in the fashion footwear space, a proactive FTO review is considerably less costly than responding to a Schedule A complaint with frozen marketplace funds.
Run a freedom-to-operate analysis on USD0927161S to assess your product’s exposure
Run FTO in Eureka →Similar design patent infringement cases in footwear and e-commerce
Explore comparable Schedule A design patent enforcement actions in the Northern District of Illinois involving footwear and online marketplace defendants.
What this case signals for the footwear design patent landscape
Schedule A default judgments are a structured enforcement tool — understanding the pattern helps brands and defendants alike.
§ 289 makes design patents unusually potent against online sellers
Unlike utility patent damages requiring apportionment, § 289 entitles a design patent holder to the infringer’s total profits on the infringing article. For low-margin marketplace sellers, this can mean full revenue disgorgement. Brands with registered design patents on iconic product shapes — like UGG footwear — can pursue financially meaningful remedies even against small-volume sellers.
Platform cooperation is now a standard enforcement lever in Schedule A cases
Courts in the Northern District of Illinois routinely issue orders directing Amazon, PayPal, and similar platforms to freeze and transfer defendant funds. This effectively turns platforms into enforcement agents. Brands using this model can recover funds rapidly without separate collection litigation — a significant operational advantage over traditional enforcement paths.
Deckers v Partnerships — key questions answered
The Northern District of Illinois entered a default judgment in favour of Deckers Outdoor Corp. on 18 July 2025. Defendants were found liable for infringement of design patent USD927161S, permanently enjoined from selling the infringing footwear, and ordered to disgorge $26,668 in profits. Amazon and PayPal were directed to freeze and remit defendant funds within seven days.
USD927161S (application no. US29/712480) is a U.S. design patent held by Deckers Outdoor Corp. covering the ornamental appearance of UGG-branded footwear. Design patents protect the visual, non-functional aspects of a product. Infringement is assessed under the ordinary observer test — whether an ordinary observer would mistake the accused design for the patented design.
Damages of $26,668 were awarded under 35 U.S.C. § 289, which entitles a design patent holder to the infringer’s total profits from the sale of articles bearing the infringing design. Unlike utility patent damages, § 289 does not require apportionment — the full profit on the infringing article is recoverable. The court accepted Deckers’ profit evidence as submitted, consistent with default judgment procedure.
Schedule A cases are a procedural model used in the Northern District of Illinois where a brand owner sues a large number of anonymous online sellers — typically identified only by marketplace aliases — in a single action. The plaintiff files a sealed complaint with a list of defendants (Schedule A), obtains emergency relief such as asset freezes, and often achieves default judgment when defendants fail to appear. Courts routinely order platforms like Amazon and PayPal to cooperate in fund seizure.
Yes. A default judgment does not constitute a merits adjudication of patent validity. Because no defendant contested validity in this proceeding, USD927161S has not been scrutinised on novelty or obviousness grounds in district court. A third party with standing — such as a competitor or a defendant in a future suit — could potentially challenge the patent via inter partes review (IPR) at the USPTO. The default provides no collateral estoppel against such a challenge.
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