Book a demo

Cut patent&paper research from weeks to hours with PatSnap Eureka AI!

Try now
Dyson v. Schedule A Defendants — Design Patent Infringement Hair Stylers | PatSnap
Explore in Eureka
Case ID1:25-cv-10969
FiledSep 2025
ClosedDec 2025
Patent Litigation

Dyson Technology v. Schedule A Defendants: Default Judgment in 85 Days

Dyson Technology Limited secured a default judgment and permanent injunction against a network of anonymous e-commerce sellers on Amazon and Walmart accused of copying its patented hair styler designs. The court awarded infringer profits under 35 U.S.C. § 289 and ordered fund freezes across third-party payment processors — all resolved within 85 days of filing.

Resolution time
85days
85 days — faster than the typical Schedule A enforcement timeline of 6–12 months
Patents asserted
2
USD852,415 and USD853,642 — ornamental hair styling product designs, two design patents asserted
Outcome
Default Judgment
Plaintiff win — defendants failed to appear; allegations deemed admitted by the court
Cost ruling
Profits Awarded
Disgorgement of infringer profits under 35 U.S.C. § 289; funds released from frozen accounts
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Dyson’s design patent blitz against anonymous online counterfeiters

Dyson Technology Limited filed this action on September 11, 2025 in the U.S. District Court for the Northern District of Illinois before Judge Thomas M. Durkin. The defendants — identified only as ‘Partnerships and Unincorporated Associations on Schedule A’ — operated anonymous e-commerce storefronts on Amazon and Walmart, selling hair styling products alleged to copy the ornamental designs protected by Dyson’s U.S. Design Patent Nos. USD852,415 and USD853,642.

The case closed on December 5, 2025 via default judgment, the court having found that none of the defendants answered or appeared. Judge Durkin entered a permanent injunction barring the defendants from selling, offering for sale, or importing the infringing products. Under 35 U.S.C. § 289, Dyson was awarded the defendants’ entire profits from infringing sales, with third-party platforms — including Amazon, Walmart, and PayPal — ordered to freeze and release funds to Dyson within seven to fourteen days of the order.

The 85-day resolution is consistent with the compressed timelines Dyson and similar brand owners achieve in Schedule A default proceedings, where defendants typically do not surface to contest the claims. What remains unknown from the public record is the total monetary recovery: individual per-defendant profit amounts are listed in a schedule attached to the judgment rather than a single aggregate figure. The use of a $2,000 surety bond and electronic service via email and publication reflects the standard procedural toolkit for these cross-border, anonymous-defendant cases.

Case at a glance
Case no.1:25-cv-10969
CourtIllinois Northern
JudgeThomas M. Durkin
FiledSeptember 11, 2025
ClosedDecember 5, 2025
Duration85 days
OutcomeDefault Judgment
Verdict causeInfringement Action
BasisDefault Judgment
Prior Art Intelligence
See what prior art exists on this patent.
Eureka scans millions of patents and papers to surface prior art that may have invalidated these claims before costly litigation begins.
Check Prior Art
Case data sourced from PACER / Illinois Northern District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to Default Judgment in 85 days

85 days — faster than the typical Schedule A enforcement timeline of 6–12 months

Case timeline: Complaint filed SEP 11 2025, OCT–NOV — 85 days total Horizontal timeline showing the three key events in Dyson Technology Limited v The Partnerships and Unincorporated Associations Identified on Schedule A from filing to resolution. Source: PACER, Illinois Northern District Court. SEP 11 2025 Complaint filed Pre-trial proceedings DEC 5 2025 Default Judgment 85 DAYS TOTAL
Default judgment

Default judgment granted: what the ruling means for both parties

Legal mechanism

Default judgment: allegations become admitted facts

When defendants fail to appear or respond, the court may enter default judgment under Fed. R. Civ. P. 55. Here, Judge Durkin found service properly effected via email and electronic publication — a method routinely accepted in Schedule A cases. All allegations in Dyson’s complaint were deemed admitted, removing any requirement for Dyson to prove infringement at trial. The court then assessed the appropriate remedy based on uncontested evidence.

Fed. R. Civ. P. 55 default
Plaintiff outcome

Permanent injunction and full profit disgorgement secured

Dyson obtained a permanent injunction, disgorgement of infringer profits under 35 U.S.C. § 289, and direct release of frozen funds held by Amazon, Walmart, and PayPal. The § 289 remedy is powerful for design patent holders: it captures the defendant’s total profits attributable to the infringing article — not just a reasonable royalty. Dyson also retains authority to commence supplemental collection proceedings if full recovery is not achieved from frozen accounts.

§ 289 total profit disgorgement
Defendant outcome

Online stores shuttered, accounts frozen, no recourse remaining

The defaulting defendants face permanent account suspension across Amazon and Walmart, advertising takedowns, and asset freezes. Because judgment was entered without appearance, defendants forfeited the opportunity to contest validity, claim independent design, or negotiate settlement. Any funds held in associated PayPal, Amazon, or Walmart accounts up to the awarded damages are released directly to Dyson. Defendants can theoretically seek to vacate the default, but the procedural bar is high.

Permanent platform ban
Commercial implications

Design patents as a fast enforcement tool in e-commerce markets

This outcome reinforces the commercial utility of design patents for consumer product brands targeting grey-market and counterfeit sellers on large online platforms. The combination of a preliminary injunction, TRO-style account freezing, and § 289 profit disgorgement creates significant deterrence. Competing hair styling brands and platform sellers should note that Dyson’s design portfolio is actively and rapidly enforced — ornamental similarity to USD852,415 or USD853,642 carries real litigation risk.

Design patent enforcement risk
Legal analysis based on PACER docket records for case 1:25-cv-10969 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffDyson Technology LimitedIndividualConsumer electronics and personal care brand — holder of USD852,415 and USD853,642Search in Eureka ↗
DefendantThe Partnerships and Unincorporated Associations Identified on Schedule AIndividualAnonymous e-commerce sellers operating on Amazon and Walmart under undisclosed seller aliasesSearch in Eureka ↗
Plaintiff counselAndrew Daniel BurnhamAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselJustin R. GaudioAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselJustin Tyler JosephAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselLawrence J. CrainAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselLuana Faria De SouzaAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselLucas Allen PetersonAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselThomas Joseph JuettnerAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff law firmGreer, Burns & Crain, Ltd.Law FirmRepresenting Dyson Technology LimitedSearch in Eureka ↗
Plaintiff law firmHusch Blackwell LLPLaw FirmRepresenting Dyson Technology LimitedSearch in Eureka ↗
Presiding judgeJudge Thomas M. DurkinJudgeIllinois Northern District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“This action having been commenced by Plaintiff Dyson Technology Limited (“Plaintiff” or “Dyson”) against the defendants identified on Schedule A, and using the Online Marketplace Accounts identified on Schedule A (collectively, the “Defendant Internet Stores”), and Plaintiff having moved for entry of Default and Default Judgment against the defendants identified on Schedule A attached hereto which have not yet been dismissed from this case (collectively, “Defaulting Defendants”); This Court having entered a preliminary injunction; Plaintiff having properly completed service of process on Defaulting Defendants, the combination of providing notice via electronic publication and e-mail, along with any notice that Defaulting Defendants received from payment processors, being notice reasonably calculated under all circumstances to apprise Defaulting Defendants of the pendency of the action and affording them the opportunity to answer and present their objections; and None of the Defaulting Defendants having answered or appeared in any way, and the time for answering having expired, so that the allegations of the Complaint are uncontroverted and are deemed admitted;This Court finds that it has personal jurisdiction over Defaulting Defendants because Defaulting Defendants directly target their business activities toward consumers in the United States, including Illinois. Specifically, Plaintiff has provided a basis to conclude that Defaulting Defendants have targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more seller aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars and/or funds from U.S. bank accounts, and have sold the same product shown in Exhibit 1 to the Complaint [3] (the “Infringing Product”), that infringes Plaintiff’s U.S. Patent No. D853,642 and U.S. Patent No. D852,415, namely hair styling products that copy the ornamental designs shown in the below chart, to residents of Illinois. In this case, Plaintiff has presented screenshot evidence that each Defendant e-commerce store is reaching out to do business with Illinois residents by operating one or more commercial, interactive internet stores through which Illinois residents can and do purchase the Infringing Products. See Docket No. [19], which includes screenshot evidence confirming that each Defendant e-commerce store does stand ready, willing and able to ship the Infringing Products to customers in Illinois. Plaintiff’s U.S. Patent No. D853,642 and U.S. Patent No. D852,415 (the “Dyson Designs”) are shown in the below chart.Accordingly, this Court orders that Plaintiff’s Motion for Entry of Default and Default Judgment is GRANTED as follows, that Defaulting Defendants are deemed in default, and that this Default Judgment is entered against Defaulting Defendants. This Court further orders that: 1. Defaulting Defendants, their officers, agents, servants, employees, attorneys, and all persons acting for, with, by, through, under, or in active concert with them be permanently enjoined and restrained from: a. offering for sale, selling, and importing Infringing Product; b. aiding, abetting, contributing to, or otherwise assisting anyone in offering for sale, selling, and importing the Infringing Product; and c. effecting assignments or transfers, forming new entities or associations or utilizing any other device for the purpose of circumventing or otherwise avoiding the prohibitions set forth in Subparagraphs (a) and (b). 2. Pursuant to 35 U.S.C. § 289, Plaintiff is awarded profits from each of the Defaulting Defendants for the sale of the Infringing Product sold through at least the Defaulting Defendants’ Seller Aliases according to the below chart: Defaulting Defendants and any third party with actual notice of this Order who is providing services for any of the Defaulting Defendants, or in connection with any of the Defaulting Defendants’ Online Marketplaces, including, without limitation, any online marketplace platforms such as Amazon.com, Inc. (“Amazon”) and Walmart, Inc. (“Walmart”) (collectively, the “Third Party Providers”), shall within seven (7) calendar days of receipt of this Order cease:a. using, linking to, transferring, selling, exercising control over, or otherwise owning the Online Marketplace Accounts, or any other online marketplace account that is being used to sell or is the means by which Defaulting Defendants could continue to sell Infringing Products; and b. operating and/or hosting websites that are involved with the distribution, marketing, advertising, offering for sale, or sale of the Infringing Products. 4. Upon Plaintiff’s request, those with notice of this Order, including the Third Party Providers as defined in Paragraph 3, shall within seven (7) calendar days after receipt of such notice, disable and cease displaying any advertisements used by or associated with Defaulting Defendants in connection with the sale of Infringing Products. 5. Any Third Party Providers holding funds for Defaulting Defendants, including PayPal, Amazon and Walmart, shall, within seven (7) calendar days of receipt of this Order, permanently restrain and enjoin any accounts connected to Defaulting Defendants or the Defendant Internet Stores from transferring or disposing of any funds (up to the damages awarded in Paragraph 2 above) or other of Defaulting Defendants’ assets. 6. All monies (up to the amount of the damages awarded in Paragraph 2 above) currently restrained in Defaulting Defendants’ financial accounts, including monies held by Third Party Providers such as PayPal, Amazon and Walmart, are hereby released to Plaintiff as partial payment of the above-identified damages, and Third Party Providers are ordered to release to Plaintiff the amounts from Defaulting Defendants’ financial accounts within fourteen (14) calendar days of receipt of this Order.Until Plaintiff has recovered full payment of monies owed to it by any Defaulting Defendant, Plaintiff shall have the ongoing authority to commence supplemental proceedings under Federal Rule of Civil Procedure 69. 8. In the event that Plaintiff identifies any additional online marketplace accounts or financial accounts owned by Defaulting Defendants, Plaintiff may send notice of any supplemental proceeding, including a citation to discover assets, to Defaulting Defendants by e-mail at the e-mail addresses identified in Exhibits to the Declaration of Giles Samuel Lane and any e-mail addresses provided for Defaulting Defendants by third parties. 9. The two thousand dollar ($2,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel.”
Source: PACER Docket, Case 1:25-cv-10969, Illinois Northern District Court

The default judgment is comprehensive in scope: the court did not merely enter liability but simultaneously imposed a permanent injunction, profit disgorgement, and operational directives binding third-party platforms. The invocation of 35 U.S.C. § 289 is particularly significant — this statute entitles the design patent holder to the infringer’s total profits from the infringing article, without the apportionment analysis required in utility patent cases. Because no defendant appeared, the factual record is entirely Dyson’s, meaning the damages schedule reflects plaintiff-submitted profit evidence that went unchallenged.

PACER case 1:25-cv-10969 · Public docket record Explore in Eureka ↗
Patent at issue

USD852,415 & USD853,642 — Dyson ornamental hair styling product designs

Publication No.USD0852415S
Application No.US29/627707
Patent details
ProductOrnamental design for a hair styling appliance (USD852,415)
Cited in actionSeptember 11, 2025

Publication No.USD0853642S
Application No.US29/627749
Patent details
ProductOrnamental design for a hair styling appliance (USD853,642)
Cited in actionSeptember 11, 2025

U.S. Design Patent Nos. USD852,415 and USD853,642, filed as application Nos. 29/627707 and 29/627749, protect the ornamental appearance of Dyson’s hair styling products. Design patents under 35 U.S.C. § 171 cover the visual, non-functional characteristics of a manufactured article. The sequential application numbers suggest these two patents were filed within the same prosecution campaign, likely tied to a single product generation — consistent with Dyson’s practice of filing multiple design applications capturing different angles or variants of a single product.

For Dyson, design patents on hair styling tools are a front-line commercial asset. The Dyson Airwrap and Supersonic product lines command significant retail premiums, making their distinctive silhouettes high-value IP targets. Registering ornamental features prevents copycat sellers from trading on Dyson’s visual identity in e-commerce search results. The aggressive enforcement record here — with permanent injunctions obtained in under 90 days — suggests Dyson treats these design registrations as an active market exclusion tool, not merely a defensive portfolio element.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should you run an FTO against USD852,415 and USD853,642?

Any company designing, manufacturing, or distributing hair styling appliances — particularly cordless stylers, air-wrap devices, or hair dryers with distinctive cylindrical or wrap-around barrel designs — should conduct a design patent freedom-to-operate analysis against Dyson’s U.S. design portfolio. Ornamental similarity is assessed from the perspective of an ordinary observer, meaning even non-identical products can infringe if the overall visual impression is substantially similar. E-commerce sellers on Amazon or Walmart face elevated risk given Dyson’s demonstrated willingness to pursue rapid default judgments.

PatSnap Eureka’s FTO Search Agent allows product teams to map their device’s visual design against registered design patents in the personal care appliance space. By uploading product renders or images, R&D and IP teams can identify potentially conflicting Dyson design registrations — including continuations and related family members not yet surfaced in standard patent searches — before committing to a product launch or marketplace listing.

PatSnap Eureka FTO Search

Run a freedom-to-operate analysis on USD0852415S to assess your product’s exposure

Run FTO in Eureka →
Related litigation

Similar design patent enforcement cases: hair care appliances

Explore related Schedule A design patent cases in the personal care appliance sector litigated in the Northern District of Illinois.

🔍
Access 40+ similar cases in PatSnap Eureka
Dyson Technology Limited patent enforcement history, Illinois Northern case history, Dyson Technology Limited’s full IP portfolio, and comparable case analysis
Shark Beauty design casesSchedule A hair tool actions§ 289 profit awards N.D. Ill.Amazon seller injunctions
Unlock similar cases in Eureka →
Strategic implications

What this case signals for the consumer electronics IP landscape

Dyson’s 85-day enforcement cycle demonstrates how design patents can function as rapid takedown instruments against e-commerce infringers.

Design patents under § 289 deliver stronger remedies than utility patents

Unlike utility patent damages, which require apportionment, § 289 awards the infringer’s entire profits on the infringing article. For consumer product brands, this makes design patents a commercially superior enforcement tool when counterfeit physical products are at issue — particularly against defendants with no incentive to appear and contest damages.

Schedule A filings compress timelines through procedural design

The Northern District of Illinois’s familiarity with Schedule A cases — combined with electronic service, preliminary asset freezes, and platform cooperation from Amazon and Walmart — allows brand owners to achieve binding outcomes in under 90 days. Companies monitoring competitive markets should treat these proceedings as near-automated enforcement events rather than traditional litigation.

🔒
Full strategic analysis in PatSnap Eureka
Unlock deeper analysis of Dyson’s design patent enforcement strategy in consumer electronics at the district court level.
Dyson design filing strategy§ 289 damages benchmarksPlatform freeze order risk
Unlock full analysis →
Analysis powered by PatSnap Eureka Litigation Intelligence Explore in Eureka ↗
Frequently asked questions

Limited v Partnerships — key questions answered

Still have questions? PatSnap Eureka can answer them instantly from patent and litigation data. Ask Eureka ↗
PatSnap Eureka

Protect your hair care product designs before the next Dyson filing

Run a design patent FTO against Dyson’s personal care appliance portfolio before your next product launch. PatSnap Eureka tracks new filings, enforcement actions, and platform injunctions across the hair styling appliance sector in real time.

Ask anything about this case.
PatSnap Eureka searches patents and litigation data to answer instantly.
Powered by PatSnap Eureka
Link copied to clipboard

Related Litigation Cases

Help us improve this page

Found incorrect or outdated information? Let us know and we'll get it fixed.