Dyson Technology v. Schedule A Defendants: Hair Styler Design Patent Dispute Dismissed
Dyson Technology Limited brought a design patent infringement action in the Northern District of Illinois against anonymous online sellers, asserting two design patents covering its hair stylers and hair dryers. The case was voluntarily dismissed without prejudice in 72 days — a timeline consistent with early settlement or defendant-specific resolution in Schedule A enforcement campaigns.
Dyson’s Schedule A campaign targets online sellers of copycat hair devices
On October 8, 2025, Dyson Technology Limited filed a design patent infringement action in the Northern District of Illinois (Case No. 1:25-cv-12324) against a group of anonymous online sellers identified only as ‘The Partnerships and Unincorporated Associations Identified on Schedule A.’ Dyson asserted two design patents — USD0852415S and USD0853642S — covering the distinctive aesthetic design of its hair stylers and hair dryers. The case was assigned to Judge Steven C. Seeger and was represented by Greer, Burns & Crain, Ltd. and Husch Blackwell LLP.
On December 19, 2025, Dyson filed a notice of voluntary dismissal without prejudice pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure, specifically as to a defendant identified as ‘jinhes6.’ The filing states that following this dismissal, the above-captioned case may be terminated. A voluntary dismissal without prejudice does not constitute a merits adjudication; Dyson retains the right to refile claims against jinhes6 or other defendants at a future date.
The 72-day duration from filing to dismissal is consistent with Schedule A enforcement patterns, where rights holders frequently resolve individual defendants through injunctions, account takedowns, or informal agreements before formal litigation concludes. The public record does not disclose whether any monetary settlement, consent injunction, or platform removal was obtained. The without-prejudice designation leaves Dyson’s enforcement options fully intact against this and potentially other unnamed defendants.
Filing to Voluntary dismissal in 72 days
72 days — faster than median N.D. Ill. patent case resolution, suggesting early resolution
Voluntarily dismissed: what Rule 41(a)(1) means for both parties
Rule 41(a)(1) permits dismissal without court approval
Under Rule 41(a)(1) of the Federal Rules of Civil Procedure, a plaintiff may dismiss an action without a court order by filing a notice of dismissal before the opposing party serves an answer or motion for summary judgment. This mechanism is typically used when the plaintiff has achieved its enforcement objective — such as a platform takedown or informal resolution — or has decided not to proceed against a specific defendant at this time.
Plaintiff-initiated exitDismissed without prejudice — but the public record says little more
A dismissal without prejudice means the case ends without a final judgment on the merits, and the plaintiff retains the right to refile. A dismissal with prejudice would permanently bar re-litigation of the same claims. The Verdict here explicitly states ‘without prejudice,’ so Dyson’s enforcement rights against jinhes6 remain intact. However, the public record is silent on whether any settlement, injunction, or account action accompanied this dismissal.
No merits bar; refiling possibleDefendant jinhes6 faces no final judgment — for now
The dismissal without prejudice means defendant jinhes6 has not been adjudicated as an infringer, and no damages or injunction order appears on the public docket. However, the without-prejudice designation means Dyson could refile against this party. Whether any informal resolution, account suspension, or payment occurred off-docket is not disclosed in the public record. The absence of a consent order or permanent injunction on file suggests either an informal resolution or a strategic withdrawal.
No final judgment; exposure remainsSchedule A tactics: fast, targeted, and often off-docket
Schedule A cases — in which a brand targets multiple anonymous online sellers simultaneously — are a well-established IP enforcement strategy in the Northern District of Illinois. Rights holders frequently obtain TROs to freeze marketplace accounts, then resolve defendants individually through informal agreements or default judgments. The 72-day lifecycle of this case is consistent with that pattern, suggesting the litigation served its enforcement purpose before a formal merits ruling was needed.
Schedule A enforcement strategyFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dyson Technology Limited | Individual | Consumer electronics and home appliance company — holder of design patents USD0852415S and USD0853642SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online marketplace sellers identified on Schedule A, specifically defendant jinhes6Search in Eureka ↗ |
| Plaintiff counsel | Andrew Daniel Burnham | Attorney | Counsel for Dyson Technology LimitedSearch in Eureka ↗ |
| Plaintiff counsel | Justin R. Gaudio | Attorney | Counsel for Dyson Technology LimitedSearch in Eureka ↗ |
| Plaintiff counsel | Justin Tyler Joseph | Attorney | Counsel for Dyson Technology LimitedSearch in Eureka ↗ |
| Plaintiff counsel | Lawrence J. Crain | Attorney | Counsel for Dyson Technology LimitedSearch in Eureka ↗ |
| Plaintiff law firm | Greer, Burns & Crain, Ltd. | Law Firm | Representing Dyson Technology LimitedSearch in Eureka ↗ |
| Plaintiff law firm | Husch Blackwell LLP | Law Firm | Representing Dyson Technology LimitedSearch in Eureka ↗ |
| Presiding judge | Judge Steven C. Seeger | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1), which allows a plaintiff to exit litigation unilaterally before an answer is filed, without court approval and without prejudice to refiling. The explicit limitation to defendant ‘jinhes6’ suggests this was a defendant-specific resolution within a broader multi-defendant Schedule A action. No merits determination was made; the court did not rule on infringement, validity, or damages. Dyson’s design patent rights remain fully intact and enforceable against this and other parties.
USD0852415S & USD0853642S — Dyson hair styler and hair dryer ornamental designs
USD0852415S (application no. US29/627707) and USD0853642S (application no. US29/627749) are US design patents protecting the ornamental appearance of Dyson’s hair styler and hair dryer products. Design patents under 35 U.S.C. § 171 cover the visual, non-functional aesthetic of a product rather than its underlying mechanism. For Dyson — whose hair styling devices are among the most visually distinctive and premium-priced in the consumer electronics sector — design patents provide direct protection against products that mimic the look of its devices, which is precisely the harm targeted in this Schedule A action.
Dyson’s hair styling portfolio, anchored by the Dyson Airwrap and Supersonic product lines, occupies a high-margin segment of the global hair care market. The visual identity of these devices is a core commercial asset. Design patents USD0852415S and USD0853642S represent targeted protection for that identity, and their assertion in Schedule A proceedings signals that Dyson actively monitors online marketplaces for visually infringing listings. For competitors, OEM manufacturers, or ODM suppliers developing hair styling devices, these patents represent a meaningful FTO risk if the ornamental design of their products resembles Dyson’s protected aesthetic.
Should you run an FTO against USD0852415S and USD0853642S?
Any company designing, manufacturing, or selling hair stylers, hair dryers, or multi-function styling tools for the US market should assess freedom-to-operate against Dyson’s design patent portfolio. This is particularly urgent for brands selling through Amazon, eBay, Walmart Marketplace, or similar platforms — the precise channels targeted in Schedule A enforcement. Design patent infringement is assessed under the ‘ordinary observer’ test, meaning visually similar products can infringe even without identical features.
PatSnap Eureka’s FTO Search Agent enables R&D and product teams to map their device aesthetics against Dyson’s registered design portfolio, identify visual similarity risks, and surface prior art that could support invalidity arguments. Eureka’s portfolio monitoring tools also allow continuous tracking of new Dyson design filings, so your team is alerted before a new Schedule A action names your products.
Run a freedom-to-operate analysis on USD0852415S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois — hair care devices
Explore comparable Schedule A design patent infringement actions in the Northern District of Illinois targeting online sellers of hair styling and personal care devices.
What this case signals for the hair care device IP landscape
Dyson’s Schedule A campaign signals active design patent enforcement against online counterfeit and copycat sellers in the hair styling device sector.
Design patents are Dyson’s frontline weapon against online copycats
Dyson’s use of design patents USD0852415S and USD0853642S to target anonymous marketplace sellers reflects a broader strategy: design registrations covering distinctive product aesthetics are highly effective in Schedule A enforcement because infringement is visually apparent and platforms respond quickly to TRO-backed takedown demands.
Northern District of Illinois remains the preferred venue for Schedule A brand enforcement
The N.D. Ill. has developed extensive Schedule A jurisprudence, making it the dominant forum for marketplace seller enforcement in the US. IP professionals monitoring Dyson’s enforcement posture should track filings in this district as a leading indicator of brand protection activity against counterfeit hair styling devices.
Limited v Partnerships — key questions answered
Dyson Technology Limited asserted two design patents: USD0852415S (application no. US29/627707) and USD0853642S (application no. US29/627749), both covering the ornamental design of its hair stylers and hair dryers.
Dyson filed a voluntary notice of dismissal without prejudice under Rule 41(a)(1) as to defendant jinhes6 on December 19, 2025. The public record does not disclose why Dyson withdrew; Schedule A cases typically resolve via informal agreements, account takedowns, or payments that do not appear on the public docket.
A dismissal without prejudice means no merits judgment was entered. Dyson retains the right to refile its design patent infringement claims against jinhes6 at a future date. The dismissal does not bar Dyson from pursuing the same defendant again or asserting the same patents in a new action.
Schedule A cases name multiple anonymous online marketplace sellers as defendants, identified by store names or account IDs rather than legal entities. The Northern District of Illinois is the preferred US venue for these actions due to its well-developed procedures for granting TROs against marketplace accounts and its experience with anonymous defendant enforcement campaigns.
Yes. These design patents protect the ornamental appearance of Dyson hair styling devices. Under the ordinary observer test, products that appear substantially similar to the patented designs to a typical consumer may infringe. Manufacturers and online sellers of visually similar hair stylers or dryers targeting the US market should conduct an FTO analysis against these registrations before commercialisation or platform listing.
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