Default Judgment Entered in Chocolate Mold Design Patent Case: Xingshao Li v. Schedule A Defendants

Introduction: Swift Default Judgment Closes Online Marketplace Patent Case in 56 Days

In one of the faster resolutions recorded in the Northern District of Illinois’s busy intellectual property docket, Xingshao Li v. The Individuals, Partnerships, and Unincorporated Associations Identified on Schedule A (Case No. 1:25-cv-15031) concluded in just 56 days with a decisive default judgment favoring the plaintiff. Filed December 11, 2025, and closed February 5, 2026, the case centered on design patent infringement of USD1052361S — a registered design patent covering a chocolate bar mold product.

The rapid closure underscores a well-established litigation strategy: filing against anonymous, Schedule A online marketplace sellers who, when served, frequently fail to appear, triggering default proceedings. For patent attorneys tracking design patent enforcement trends, IP professionals managing e-commerce infringement portfolios, and R&D teams assessing competitive risk in consumer product categories, this case offers instructive procedural and strategic data points. The court awarded $34,000 in damages and issued a sweeping permanent injunction covering major online platforms including Amazon, eBay, Alibaba, Walmart, and Wish.com.

Case Overview

The Parties

The Patent at Issue

This case centered on design patent USD1052361S, covering the specific visual design of a chocolate bar mold. Design patents are registered with the U.S. Patent and Trademark Office (USPTO) and protect ornamental appearance rather than functional technology.

• • US D1052361S — Ornamental design for a chocolate bar mold
• • Application No. US29/948558
• • Patent Type: Design Patent
• • Technology/Product Category: Kitchen & Baking Accessories (Chocolate Molds)

The Accused Products

The accused products were chocolate bar molds sold through various online marketplace stores operated by the Schedule A defendants. These products were deemed to infringe the ornamental design protected by USD1052361S.

Legal Representation

Plaintiff’s counsel, Ge Lei of Getech Law LLC, is a firm known for its experience in Schedule A e-commerce patent and trademark enforcement actions in the Northern District of Illinois. No counsel appeared for the defendants.

Litigation Timeline & Procedural History

The Northern District of Illinois — specifically its Chicago division — has become a preferred jurisdiction for Schedule A infringement actions due to favorable procedural precedents, judicial familiarity with e-commerce enforcement mechanisms, and the court’s demonstrated willingness to issue ex parte temporary restraining orders (TROs) and asset freezes early in proceedings.

Chief Judge April M. Perry presided over this matter. The 56-day case duration is consistent with uncontested Schedule A default proceedings, where the absence of any defense filing accelerates the path from complaint to judgment. No claim construction proceeding, summary judgment briefing, or trial was necessary — the default posture rendered those stages moot. The speed of resolution is a structural feature of this litigation model, not an anomaly.

The Verdict & Legal Analysis

Outcome

The court granted Plaintiff’s Motion for Entry of Default and Default Judgment in full. The defaulting defendant was formally deemed in default, and judgment entered against them accordingly.

Damages: $34,000 awarded pursuant to 35 U.S.C. § 284, the federal statute governing patent damages, with the court expressly noting the award encompasses willful infringement of Plaintiff’s design patent on products sold through the defendant’s internet store. The willfulness finding is significant — it reflects the court’s characterization of the defendants’ conduct as deliberate rather than inadvertent.

Injunctive Relief Granted

The permanent injunction issued is comprehensive and operationally significant:

1. Direct Prohibition: Defendants permanently barred from using, reproducing, selling, marketing, or distributing any product incorporating USD1052361S without Plaintiff’s authorization.
2. Platform-Level Obligations: Third-party platform providers — including Amazon, eBay, AliExpress, Alibaba, Walmart, Wish.com, and DHgate — ordered to cease hosting defendant storefronts, disable advertisements, and freeze associated accounts within seven calendar days of order receipt.
3. Financial Account Restraint and Release: Payment processors — including PayPal, Alipay, Ant Financial, Amazon Pay, and Walmart Pay — ordered to freeze and release to Plaintiff all funds held in defendant accounts up to the $34,000 damages ceiling within fourteen calendar days.
4. Supplemental Proceedings Authority: Plaintiff granted ongoing authority to pursue supplemental proceedings under Federal Rule of Civil Procedure 69 until full damages recovery is confirmed.

Verdict Cause Analysis

The verdict cause is straightforwardly classified as an infringement action. Because no defendant appeared, there was no validity challenge, no claim construction dispute, and no contested infringement analysis presented to the court. The legal reasoning supporting default judgment rests on:

• Proper service of process on defendants
• Defendants’ failure to appear or respond within the required timeframe
• Plaintiff’s prima facie showing of valid patent ownership and defendant infringement through supporting declarations and evidence of infringing marketplace listings
• The court’s independent review confirming the adequacy of the default judgment motion

The willful infringement finding — though entered on default — carries consequences: it supports enhanced damages under § 284 and strengthens Plaintiff’s position in any supplemental proceedings to recover the full awarded amount.

Legal Significance

This case reinforces several important principles:

• Design patents are enforceable assets in consumer product categories, even for individual inventors.
• Schedule A default judgments remain an efficient enforcement pathway where defendants fail to contest claims.
• Multi-platform injunctions covering major global marketplaces are now standard relief in these cases, reflecting judicial recognition of cross-platform infringement patterns.
• The asset freeze and release mechanism targeting payment processors represents an increasingly routine remedy that effectively monetizes judgments without requiring post-judgment collection proceedings against unlocatable defendants.

Industry & Competitive Implications

The Xingshao Li case reflects broader enforcement trends in the consumer goods e-commerce sector. Schedule A patent litigation has grown substantially as a litigation model because it efficiently addresses a structural market problem: individual and small-scale sellers across dozens of online storefronts can collectively generate significant infringing sales volume while remaining individually difficult and expensive to pursue through traditional litigation.

For platform operators like Amazon, Alibaba, and Walmart, court orders of this type impose direct operational compliance obligations — platform teams must have workflows capable of responding to judicial orders within seven-day windows.

For IP professionals managing design patent portfolios in the consumer products space, this case affirms that even relatively niche product categories — such as kitchen and baking accessories — generate viable enforcement opportunities when design patent rights are properly secured. The $34,000 damages figure, while modest in absolute terms, represents a meaningful recovery in a case resolved in under two months without trial.

The case also signals continued judicial support in the Northern District of Illinois for the Schedule A enforcement model, a factor patent litigators should weigh in venue selection for similar matters.