Dyson Technology v. Schedule A Defendants: Default Judgment on Hair Styler Design Patents
Dyson Technology Limited secured a permanent injunction and profit disgorgement award against anonymous online marketplace sellers accused of infringing two design patents covering its hair styling apparatus. The case resolved in 196 days via default judgment, with Amazon and PayPal ordered to freeze and release defendant funds directly to Dyson.
Dyson’s Design Patent Enforcement Against Anonymous Online Sellers
Dyson Technology Limited filed suit on January 17, 2025 in the U.S. District Court for the Northern District of Illinois before Judge Jeffrey I. Cummings, asserting infringement of two U.S. design patents — USD0852415S and USD0853642S — both covering Dyson’s hair styling and hair care apparatus. The defendants, identified only as the partnerships and unincorporated associations listed on Schedule A, are the class of anonymous third-party sellers commonly encountered in online marketplace enforcement campaigns.
The case closed on August 1, 2025 via default judgment after the named defendants failed to appear or respond. The court entered a permanent injunction barring defendants from offering, selling, or importing the infringing products, and awarded Dyson profits under 35 U.S.C. § 289 — the design patent profit disgorgement statute — for each defaulting defendant. Third-party platforms including Amazon and PayPal were ordered to freeze and transfer defendant funds to Dyson within seven calendar days of receiving the order.
The 196-day resolution is consistent with the accelerated pace typical of Schedule A design patent enforcement actions, which frequently proceed to default when defendants are offshore or pseudonymous. The TRO mechanism — combined with platform-level asset freezes — is the operative commercial lever in these cases, and the public record does not disclose the aggregate damages amount recovered from the per-defendant profit chart. What drove the outcome here is straightforward: no defendant entered an appearance, leaving Dyson to prove its case uncontested.
Filing to Default Judgment in 196 days
196-day resolution — consistent with default judgment timelines in Schedule A enforcement actions
Default judgment entered: what the court’s order means for both parties
Default judgment under Federal Rule 55 — no merits contest
A default judgment is entered when a defendant fails to plead or otherwise defend. The court accepts well-pleaded allegations as true and may award relief without a merits trial. Here, every defaulting defendant’s silence allowed Dyson to obtain a permanent injunction and profit disgorgement as a matter of course. The judgment is enforceable against those specific seller aliases but does not bind non-appearing third parties absent proper notice.
Rule 55 default — no appearancePermanent injunction and § 289 profit disgorgement secured
Dyson obtains both injunctive and monetary relief. The permanent injunction covers selling, importing, and aiding further infringement, and extends to new marketplace accounts those defendants may open. Under 35 U.S.C. § 289, design patent holders can elect to recover the infringer’s total profits from the infringing article — often a more favourable measure than lost profits or reasonable royalty. Platform-level fund seizure via Amazon and PayPal makes enforcement practically immediate.
§ 289 total profits — immediate seizureDefendants bear injunction, asset freeze, and profit forfeiture
Defaulting defendants face a permanent sales ban across all online marketplaces, asset freezes on connected PayPal and Amazon accounts, and direct transfer of restrained funds to Dyson. The order explicitly covers new entities or accounts formed to circumvent the injunction. Because no defendant appeared, there is no appeal record and no public challenge to the validity or scope of the asserted design patents in this proceeding.
Asset freeze — circumvention prohibitedPlatform enforcement orders set a repeatable template for Dyson IP protection
This case illustrates the standard Schedule A playbook: TRO filed ex parte, asset freeze via platform APIs, then default judgment converting the freeze into a permanent award. For competitors and marketplace sellers in the personal care appliance space, the outcome signals Dyson’s willingness to pursue design patent enforcement aggressively through coordinated platform take-downs. The per-defendant profit chart structure also allows Dyson to pursue supplemental proceedings as new aliases are identified.
Schedule A enforcement — ongoing authorityFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dyson Technology Limited | Individual | Consumer electronics and personal care IP — holder of USD0852415S and USD0853642SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online marketplace sellers identified collectively via Schedule A seller aliasesSearch 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 ↗ |
| Presiding judge | Judge Jeffrey I Cummings | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order is comprehensive in both injunctive scope and monetary mechanism. By invoking 35 U.S.C. § 289, Dyson elected total-profit disgorgement — a remedy unique to design patents that can exceed reasonable royalty calculations. The per-defendant profit chart structure preserves flexibility for supplemental proceedings. The order’s explicit extension to new entities and seller aliases formed post-judgment is consistent with N.D. Illinois practice in Schedule A cases, and the platform-enforcement provisions targeting Amazon and PayPal reflect established Northern District template language for anonymous defendant actions.
USD0852415S & USD0853642S — Dyson Hair Styling Apparatus Design Patents
USD0852415S and USD0853642S are U.S. design patents protecting the ornamental appearance of Dyson’s hair styling and hair care apparatus, filed as applications US29/627707 and US29/627749 respectively. Design patents in the U.S. cover the non-functional visual characteristics of a product, granting the holder the exclusive right to the patented ornamental design for 15 years from grant. The paired filing strategy — two applications from what appears to be the same product family — is commonly used to capture multiple visual embodiments and tighten protection around a flagship product’s aesthetic.
For Dyson, whose premium personal care appliance business depends substantially on distinctive product aesthetics, design patent protection is a front-line commercial asset. The hair styling device category — including products such as the Airwrap and Supersonic — is a high-volume, high-margin segment that attracts significant counterfeiting and design copying activity on online marketplaces. Asserting two design patents simultaneously raises the bar for defendants seeking to invalidate or design around both, and the § 289 total-profit remedy makes infringement of even a single design patent financially material for infringing sellers.
Should your product team run an FTO against USD0852415S and USD0853642S?
Any company developing, sourcing, or listing hair styling or hair care appliances — particularly devices with visual similarity to Dyson’s Airwrap or Supersonic product lines — should conduct a freedom-to-operate analysis against Dyson’s design patent portfolio before commercialisation. The risk is not limited to identical copies: U.S. design patent infringement is assessed under the ‘ordinary observer’ test, meaning products that create a substantially similar overall visual impression can infringe even without direct copying. Marketplace sellers listing third-party branded or unbranded hair styling devices are particularly exposed given Dyson’s demonstrated Schedule A enforcement posture.
PatSnap Eureka’s FTO Search Agent enables IP teams and product managers to rapidly map Dyson’s full design patent portfolio, identify the visual claim scope of USD0852415S and USD0853642S, and benchmark proposed product designs against the ordinary observer standard. Eureka can also surface related Dyson design applications in other jurisdictions — relevant for brands selling cross-border — and flag continuation or divisional applications that may extend protection beyond these two granted patents. Running an FTO before product launch or marketplace listing can avoid account suspension, asset freezes, and profit disgorgement exposure.
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
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What this case signals for the personal care appliance IP landscape
Dyson’s Schedule A action demonstrates how design patents and platform asset-freeze mechanisms combine into a rapid, scalable enforcement tool.
Design patents under § 289 carry outsized monetary risk for online sellers
Unlike utility patent cases where damages are tied to reasonable royalty or lost profits, design patent infringement exposes defendants to their total article profits under § 289. For high-volume marketplace sellers of personal care devices, this arithmetic can produce large awards even at modest per-unit margins. Any seller sourcing visually similar hair styling devices should prioritise design clearance before listing.
Platform-level asset freezes make default judgment enforcement near-instantaneous
The court’s order compels Amazon and PayPal to freeze and transfer funds within seven days of notice. This operational enforcement model — independent of defendant cooperation — substantially reduces the usual post-judgment collection problem. IP teams at consumer electronics brands should note this mechanism is replicable wherever defendants rely on major marketplace payment infrastructure.
Limited v Partnerships — key questions answered
Dyson’s damages were awarded under 35 U.S.C. § 289, which permits a design patent holder to recover the total profits earned by an infringer from the sale of any article to which the patented design has been applied. This is distinct from utility patent remedies and can result in awards equal to the defendant’s entire revenue from the infringing product rather than a reasonable royalty.
A default judgment was entered because the defendant sellers failed to appear or respond. The court accepted Dyson’s allegations as true and granted all requested relief without a merits hearing. Defendants are now subject to a permanent injunction, asset seizure via Amazon and PayPal, and a profit disgorgement obligation. They may seek to vacate the judgment under Rule 60(b) but must act promptly.
Dyson asserted two design patents: USD0852415S (application US29/627707) and USD0853642S (application US29/627749), both covering the ornamental design of Dyson’s hair styling and hair care apparatus. The dual-patent filing strategy narrows design-around options and strengthens enforcement coverage over the product’s visual appearance.
In Schedule A cases, courts can order third-party platforms such as Amazon and PayPal to freeze financial accounts linked to defendant seller aliases as part of a TRO, then convert those frozen funds into a permanent damages award upon default judgment. Platforms must comply within seven calendar days of receiving the court order, making monetary enforcement immediate and independent of defendant cooperation.
Yes. The court order grants Dyson ongoing authority to serve the judgment on third-party providers if new financial accounts controlled by defaulting defendants are identified. It also explicitly covers new entities or seller aliases formed to circumvent the injunction, allowing Dyson to pursue supplemental proceedings without filing a new lawsuit for the same defendants.
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