Default Judgment Entered in Automatic Smoker Patent Case Against Amazon Seller

Case Overview

The Parties

The Patent at Issue

This landmark case involved **U.S. Patent No. 12,324,440 B1** (Application No. US18/900993), entitled “Automatic Smoker.” It covers an automated cooking device designed to deliver smoked flavor with minimal user intervention. The patent falls within the consumer kitchen appliance and outdoor cooking equipment technology sector — a rapidly growing market segment.

• • US 12,324,440 B1 — Automated cooking device designed to deliver smoked flavor

The Accused Product

The defendant allegedly manufactured and sold products through Amazon that practiced the invention claimed in U.S. Patent No. 12,324,440. Plaintiff submitted screenshot evidence and purchased infringing products that were shipped directly to Illinois, providing concrete jurisdictional and infringement evidence entered into the docket at Document No. 02-03.

Legal Representation

Plaintiff’s Counsel: Bayramoglu Law Offices LLC, with attorneys Joseph Wendell Droter, Katherine Marilyn Kuhn, Nazly Aileen Bayramoglu, Nihat Deniz Bayramoglu, and William Brees appearing on record. No defense counsel appeared.

Litigation Timeline & Procedural History

Filed in the Northern District of Illinois — a preferred venue for Schedule A patent enforcement actions due to its experienced bench and established procedural framework for e-commerce IP cases — the case moved at an accelerated pace consistent with default proceedings.

Chief Judge Jorge L. Alonso presided. The plaintiff executed service through electronic publication and email, a method the court explicitly validated as “reasonably calculated under all circumstances” to apprise the defendant of the pending action — an important procedural affirmation for future e-commerce enforcement matters.

The defendant failed to answer or appear at any stage. With the answer deadline expired and allegations deemed admitted, the court proceeded directly to default judgment without trial, completing resolution in under 100 days from filing.

The Verdict & Legal Analysis

Outcome

The court granted plaintiff’s Motion for Entry of Default and Default Judgment in full, entering the following relief:

• Monetary Damages: $22,632.95 awarded pursuant to 35 U.S.C. § 284 for willful infringement
• Permanent Injunction: Prohibiting manufacturing, distributing, importing, offering for sale, or selling any product practicing the invention claimed in U.S. Patent No. 12,324,440
• Third-Party Platform Orders: Amazon, PayPal, Alibaba, AliExpress, Wish.com, Dhgate, Ant Financial, Alipay, and Amazon Pay were directed to freeze and release restrained funds within 7–14 calendar days
• Surety Bond Released: The $15,000 surety bond posted by plaintiff was ordered returned to Bayramoglu Law Offices LLC

Verdict Cause Analysis

The court’s willful infringement finding under 35 U.S.C. § 271 rested on several key determinations:

• Personal Jurisdiction: The court found jurisdiction over the foreign defendant because it actively targeted U.S. and Illinois consumers — operating an interactive Amazon storefront accessible to Illinois residents, offering U.S. shipping, and completing sales of infringing goods that were physically delivered to Illinois. This mirrors the jurisdictional analysis applied in similar Northern District of Illinois Schedule A cases.
• Infringement Evidence: Plaintiff’s purchase-and-ship testing strategy — buying accused products through the defendant’s Amazon listing and receiving delivery in Illinois — provided direct, physical evidence of infringement that was entered into the record. This tactic remains one of the most effective evidentiary approaches in e-commerce patent enforcement.
• Willfulness: Because the defendant neither appeared nor contested any allegation, all complaint allegations — including willful infringement — were deemed admitted by operation of default. The court separately found unjust enrichment liability under Illinois State Common Law.
• Unjust Enrichment: The inclusion of a state common law unjust enrichment claim alongside the federal patent claim provides an additional recovery pathway that practitioners should note when structuring Schedule A complaints.

Legal Significance

While default judgments carry limited precedential weight on substantive patent law questions, this case reinforces several procedurally significant principles:

• Electronic service validation in cross-border e-commerce disputes remains judicially endorsed in the Northern District of Illinois
• Platform-level injunctions extending to Amazon, PayPal, and financial intermediaries continue to be granted as standard relief
• Purchase-based infringement evidence shipped to the forum state satisfies both jurisdictional and infringement burdens simultaneously

Strategic Takeaways

• For Patent Holders: Schedule A litigation continues to offer a high-speed enforcement mechanism. The 97-day resolution and full monetary award demonstrate the efficiency available when defendants fail to appear. Registering patents with the U.S. Customs and Border Protection (CBP) and recording them with Amazon’s Brand Registry can complement litigation strategy.
• For Accused Infringers/Marketplace Sellers: Non-appearance forfeits all defenses and results in deemed admission of willfulness — the most expensive outcome possible. Foreign sellers operating U.S.-facing Amazon storefronts should treat U.S. patent notices as requiring immediate legal response.
• For R&D Teams: Products in the automated cooking appliance category — particularly devices that practice “automatic smoking” functionality — face active patent enforcement. Freedom-to-operate (FTO) analysis against U.S. Patent No. 12,324,440 should be conducted before market entry.

Industry & Competitive Implications

The automatic smoker and smart outdoor cooking appliance market has experienced significant growth, driven by consumer interest in automated, app-connected food preparation devices. U.S. Patent No. 12,324,440 represents an assertion position within this competitive landscape.

This case reflects a broader pattern in which Chinese manufacturers holding U.S. patents — often acquired or prosecuted specifically to enforce against competing Chinese sellers operating on the same platforms — use Schedule A litigation to police the Amazon marketplace. The strategy has become a recognized enforcement model, with the Northern District of Illinois serving as a primary venue.

For companies operating in the consumer appliance, outdoor cooking, or smart kitchen technology sectors, this case signals:

• Active enforcement posture by patent holders in the automatic smoker category
• Platform-level vulnerability — Amazon accounts and associated payment accounts are freezable assets
• Speed of exposure — companies can face permanent injunctions and frozen accounts within weeks of a complaint filing

Licensing inquiries or design-around investment in this technology area should be evaluated against the enforcement risk profile this case exemplifies.