Dyson Technology v. Schedule A Defendants: Design Patent Infringement Action Dismissed
Dyson Technology Limited brought a design patent infringement claim in the Northern District of Illinois against anonymous online sellers, asserting two design patents covering hair styling and hair care apparatus. The case closed just 58 days after filing, with Dyson voluntarily dismissing without prejudice — leaving the door open for future enforcement action.
Dyson’s Schedule A design patent sweep targets hair styling copycats
On August 26, 2025, Dyson Technology Limited filed suit in the Northern District of Illinois (Case No. 1:25-cv-10207) against an unnamed group of defendants identified on Schedule A — a common enforcement posture used against networks of anonymous online sellers. Dyson asserted two U.S. design patents, USD852415S and USD853642S, both derived from application series US29/627707 and US29/627749 respectively, covering the ornamental design of hair styling and hair care apparatus.
The case ended on October 23, 2025, 58 days after it was filed. On October 9, 2025, Dyson filed a notice of voluntary dismissal under Federal Rule of Civil Procedure 41(a)(1) as to the specific defendant entity identified as Shop1102191027 Store. The public record does not specify whether a settlement was reached; the dismissal is without prejudice, meaning Dyson retains the legal right to refile claims against this defendant in the future.
A 58-day lifecycle is consistent with the typical arc of Schedule A actions, which often resolve quickly — either through private settlement, default, or targeted dismissal of specific defendants following injunctive relief or payment. The absence of defendant counsel on record and the dismissal of a single named store suggests this may have been one resolution within a broader multi-defendant campaign. The full commercial terms, if any, remain undisclosed.
Filing to Voluntary dismissal in 58 days
58 days — notably swift closure, consistent with a targeted Schedule A enforcement action
Voluntarily dismissed: what Rule 41(a)(1) means for both parties
Rule 41(a)(1) voluntary dismissal — no court order required
A Rule 41(a)(1) dismissal is filed unilaterally by the plaintiff before the defendant serves an answer or summary judgment motion. It requires no judicial approval and takes effect immediately upon filing. Critically, the public record here is silent on whether the dismissal was with or without prejudice — the verdict text specifies ‘without prejudice,’ meaning Dyson explicitly preserved its right to refile.
Without prejudice — refiling permittedWithout prejudice vs. with prejudice: the public record speaks
Unlike many Schedule A dismissals where the prejudice qualifier is unstated, Dyson’s filing here explicitly states dismissal without prejudice. This means the claims are not extinguished — Dyson could refile against Shop1102191027 Store or pursue related defendants in a new action. A ‘with prejudice’ dismissal would have permanently barred the same claims, typically signalling a negotiated resolution. The explicit ‘without prejudice’ language here leaves enforcement options open.
Claims survive — enforcement preservedShop1102191027 Store: dismissed, but not cleared
The named defendant, Shop1102191027 Store, exits this specific proceeding without a merits ruling against it. No liability finding, no injunction, and no damages were recorded. However, ‘without prejudice’ means this is not a clean bill of health — Dyson may refile the same design patent claims at any time within the applicable statute of limitations. The defendant’s legal exposure to Dyson’s IP rights remains unresolved.
No merits ruling — exposure unresolvedSchedule A tactics signal ongoing design patent enforcement
Dyson’s use of Schedule A procedure against anonymous online sellers reflects a well-established enforcement strategy in the Northern District of Illinois targeting marketplace counterfeiters and design infringers. The rapid closure of this action — 58 days — is consistent with targeted settlements or strategic dismissals in multi-defendant campaigns. Sellers of competing hair styling apparatus should note that Dyson’s two design patents remain fully active and enforceable.
Design patents remain activeFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dyson Technology Limited | Individual | Consumer electronics and personal care company — holder of USD852415S and USD853642SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online sellers identified on Schedule A, including Shop1102191027 StoreSearch 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 Sara L. Ellis | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i), the self-executing voluntary dismissal mechanism available before a defendant has answered or moved for summary judgment. The explicit ‘without prejudice’ designation is legally significant: Dyson’s infringement claims under USD852415S and USD853642S are not extinguished and may be reasserted. No court merits analysis was conducted, meaning neither patent validity nor infringement scope was adjudicated. The phrasing ‘the above captioned case may be terminated’ is standard housekeeping language confirming administrative closure.
USD852415S & USD853642S — Dyson hair styling apparatus design patents
USD852415S (application US29/627707) and USD853642S (application US29/627749) are U.S. design patents protecting the ornamental appearance of Dyson’s hair styling and hair care apparatus. Design patents protect the way a product looks — not how it functions — making them particularly powerful tools against marketplace sellers reproducing the visual identity of a branded product. Both patents share overlapping application series, suggesting they cover related design variants or viewing perspectives within the same product family.
For Dyson, design patents in the personal care space serve as a frontline IP weapon against low-cost online counterfeiters who replicate the distinctive aesthetic of products like the Airwrap or Supersonic. A design patent infringement finding requires only that an ordinary observer would be deceived into thinking the accused product is the same as the patented design — a relatively accessible threshold in fast-moving e-commerce enforcement. Competitors designing hair tools for the U.S. market must ensure their product aesthetics do not substantially replicate the ornamental features covered by these two active Dyson patents.
Should your hair styling product be cleared against USD852415S and USD853642S?
Any company manufacturing, importing, or selling hair styling or hair care apparatus into the U.S. market — including curling tools, hair dryers, and multi-function stylers — should consider an FTO assessment against Dyson’s active design patent portfolio. This is particularly urgent for brands selling through Amazon, Shopify, or other online marketplaces where Schedule A enforcement actions can result in rapid account freezes and injunctive orders before a defendant has any opportunity to respond.
PatSnap Eureka’s FTO Search Agent enables product and IP teams to run structured freedom-to-operate assessments against active U.S. design patents, including USD852415S and USD853642S. Upload product images or CAD renders to compare ornamental features against Dyson’s claimed designs, identify design-around opportunities, and generate an audit trail that supports a clearance opinion — all before your product reaches market.
Run a freedom-to-operate analysis on USD852415S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in the Northern District of Illinois
Explore related design patent infringement actions against anonymous Schedule A defendants in the Northern District of Illinois, particularly in consumer electronics and personal care.
What this case signals for the hair styling apparatus IP landscape
Dyson’s Schedule A enforcement pattern in the N.D. Illinois reflects a systematic approach to design IP protection in the personal care sector.
Schedule A actions in N.D. Illinois move fast — prepare accordingly
This case closed in 58 days. Schedule A design patent actions in the Northern District of Illinois are engineered for speed — TROs, asset freezes, and early settlements are the norm. Sellers of hair styling products on online marketplaces should audit their product designs against Dyson’s active design patent portfolio before listings go live, not after a complaint is filed.
Without prejudice dismissal is not an acquittal — monitor for refiling
Dyson’s explicit ‘without prejudice’ language signals that this dismissal is tactical, not conclusive. Companies and marketplace sellers should monitor Dyson’s enforcement filings in N.D. Illinois for refiled actions or new Schedule A campaigns. A dismissal without prejudice in a Schedule A case often precedes a renewed or expanded action, particularly where the defendant failed to respond.
Limited v Partnerships — key questions answered
Dyson Technology Limited filed a design patent infringement action in the Northern District of Illinois on August 26, 2025, asserting USD852415S and USD853642S against anonymous online sellers. Dyson voluntarily dismissed the case without prejudice under Rule 41(a)(1) on October 9, 2025, specifically as to Shop1102191027 Store. The case closed on October 23, 2025 — 58 days after filing. No merits ruling was issued.
USD852415S (application US29/627707) and USD853642S (application US29/627749) are U.S. design patents owned by Dyson Technology Limited. They protect the ornamental design of hair styling and hair care apparatus. Design patents cover the visual appearance of a product, not its functional features. Both stem from closely related application numbers, suggesting they protect design variants within the same Dyson product family.
A without-prejudice dismissal under Rule 41(a)(1) means the plaintiff’s claims are not permanently extinguished. The defendant — here, Shop1102191027 Store — exits the proceeding without a liability finding, injunction, or damages award. However, Dyson retains the right to refile the same design patent infringement claims in the future. It does not constitute a legal clearance or ruling in the defendant’s favour.
The Northern District of Illinois is a favoured venue for Schedule A enforcement actions because local practice allows plaintiffs to file against groups of anonymous online sellers, obtain temporary restraining orders that freeze marketplace accounts, and serve defendants via electronic means. This approach is particularly effective against counterfeiters and design infringers operating through platforms like Amazon and AliExpress, where seller identities may be concealed.
Yes. Because the dismissal was explicitly without prejudice, Dyson is legally entitled to refile infringement claims based on USD852415S and USD853642S against Shop1102191027 Store or related entities, provided any applicable statute of limitations has not elapsed. A voluntary without-prejudice dismissal under Rule 41(a)(1) leaves all claims intact — it is a procedural exit, not a substantive resolution of the IP dispute.
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