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Dyson v. Schedule A Defendants — Hair Styler Design Patent Infringement | PatSnap
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Case ID1:25-cv-01833
FiledFeb 2025
ClosedJun 2025
Patent Litigation

Dyson Technology v. Schedule A Defendants — Design Patent Consent Judgment (116 Days)

Dyson Technology Limited pursued design patent infringement claims against an anonymous e-commerce seller in the Northern District of Illinois, asserting two design patents covering its iconic hair styler and hair dryer aesthetics. The case resolved via consent judgment after 116 days, securing a permanent injunction and $4,000 in damages — a swift enforcement win consistent with Dyson’s broader Schedule A anti-counterfeiting strategy.

Resolution time
116days
116 days — resolved well within the median Schedule A case timeline in N.D. Illinois
Patents asserted
2
USD0852415S and USD0853642S — Dyson hair styler and hair dryer ornamental designs
Outcome
Consent Judgment
Settled by agreement; defendant permanently enjoined and ordered to pay $4,000 in damages
Cost ruling
Each Side Bears Own Costs
No attorney fee award; parties agreed each bears its own fees and costs under settlement terms
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Dyson’s Schedule A design patent sweep nets injunction and $4K damages

Dyson Technology Limited filed this action on February 21, 2025, in the U.S. District Court for the Northern District of Illinois against an anonymous defendant (Def. No. 44 operating under seller alias gjnfMMF) identified on a Schedule A, asserting infringement of two U.S. design patents — D852,415 and D853,642 — covering the ornamental designs of its hair stylers and hair dryers. The defendant operated e-commerce stores targeting U.S. consumers, accepted payments in U.S. dollars, and shipped infringing products to Illinois residents.

The case closed on June 17, 2025, through a consent judgment entered by Judge Elaine E. Bucklo. The court found personal jurisdiction, held the defendant liable for patent infringement under 35 U.S.C. § 271, issued a permanent injunction, and ordered Walmart to transfer $4,000 from the defendant’s frozen accounts to Dyson. The case is technically dismissed with leave to reinstate within 180 days, automatically converting to dismissal with prejudice absent a reinstatement motion — a mechanism that preserves Dyson’s enforcement leverage during any payment transition period.

The 116-day resolution reflects the efficiency of Dyson’s enforcement playbook: TRO-based account freezes applied immediately upon filing, placing financial pressure on marketplace sellers to settle early. The $4,000 settlement amount is modest relative to litigation costs but represents a component of a broader multi-defendant campaign — the pattern of Schedule A enforcement is cumulative. What remains undisclosed is the full roster of co-defendants in this action and the aggregate recovery across the campaign.

Case at a glance
Case no.1:25-cv-01833
CourtIllinois Northern
JudgeElaine E. Bucklo
FiledFebruary 21, 2025
ClosedJune 17, 2025
Duration116 days
OutcomeConsent Judgment
Verdict causeInfringement Action
BasisConsent Judgment
Prior Art Intelligence
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Case data sourced from PACER / Illinois Northern District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to Consent Judgment in 116 days

116 days — resolved well within the median Schedule A case timeline in N.D. Illinois

Case timeline: Complaint filed FEB 21 2025, APR–MAY — 116 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. FEB 21 2025 Complaint filed Pre-trial proceedings JUN 17 2025 Consent Judgment 116 DAYS TOTAL
Dismissal terms

Consent judgment secured: permanent injunction plus $4,000 damages from Walmart account

Legal mechanism

Consent judgment: court-enforceable resolution by agreement

A consent judgment is a court order that formalises the parties’ negotiated settlement, carrying the same enforceability as a contested judgment. Here, the court made express findings of personal jurisdiction and patent infringement liability before entering the order — giving Dyson a judicially confirmed infringement finding, not merely a private settlement. This matters: the finding under 35 U.S.C. § 271 is on the public record.

Court-entered, fully enforceable
Plaintiff outcome

Dyson secures injunction and account freeze-backed payment

Dyson obtained a permanent injunction barring the defendant from selling, offering, or importing the infringing product and from forming new entities to evade the order. Critically, the court directed Walmart to transfer $4,000 directly from the defendant’s frozen account — a mechanism that ensures payment without relying on voluntary defendant compliance. Dyson bears its own legal costs but achieves market exclusion, the primary objective.

Permanent injunction granted
Defendant outcome

Seller faces permanent ban and account seizure via Walmart

Defendant gjnfMMF (Def. No. 44) agreed to pay $4,000 in damages and accept a permanent injunction. The consent judgment expressly bars creating successor entities to circumvent the order. The case is technically dismissed with leave to reinstate for 180 days — meaning Dyson retains the right to return to court if the defendant re-emerges or fails to comply. Walmart account restraints lift only upon confirmed payment transfer.

Enjoined; account restrained
Commercial implications

Schedule A enforcement: cumulative pressure on marketplace counterfeiters

This case is one data point in Dyson’s broader Schedule A enforcement campaign targeting e-commerce design infringers across major U.S. marketplaces. The TRO-plus-account-freeze model is engineered for leverage: sellers face operational disruption from day one, making early settlement economically rational. Competitors and marketplace sellers in the personal care appliance space should note that Dyson actively monitors and enforces its design patent portfolio with speed and consistency.

Active design patent enforcement
Legal analysis based on PACER docket records for case 1:25-cv-01833 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffDyson Technology LimitedIndividualGlobal consumer electronics brand — holder of U.S. Design Patents D852,415 and D853,642Search in Eureka ↗
DefendantThe Partnerships and Unincorporated Associations Identified on Schedule AIndividualAnonymous e-commerce seller (gjnfMMF, Def. No. 44) operating on Walmart marketplaceSearch 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 law firmGreer, Burns & Crain, Ltd.Law FirmRepresenting Dyson Technology LimitedSearch in Eureka ↗
Presiding judgeJudge Elaine E. BuckloJudgeIllinois Northern District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“This action having been commenced by Plaintiff Dyson Technology Limited (“Plaintiff”) against Defendant gjnfMMF (Def. No. 44). Plaintiff and Defendant have resolved all claims arising from the allegations in the Complaint. THIS COURT HEREBY FINDS that it has personal jurisdiction over Defendant since Defendant directly targets its business activities toward consumers in the United States, including Illinois. “In the context of cases like this one, that means a plaintiff must show that each defendant is actually operating an interactive website that is accessible in Illinois and that each defendant has aimed such site at Illinois by standing ready, willing and able to ship its [infringing] goods to customers in Illinois in particular (or otherwise has some sufficient voluntary contacts with the state).” Am. Bridal & Prom Indus. Ass’n v. P’ships & Unincorporated Ass’ns Identified on Schedule A, 192 F. Supp. 3d 924, 934 (N.D. Ill. 2016). Specifically, Defendant has targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more Seller Aliases, offered shipping to the United States, including Illinois, accepted payment in U.S. dollars and/or funds from U.S. bank accounts, and has sold products (the “Infringing Product”) featuring Plaintiff’s patented designs U.S. Patent Nos. D853,642 and Case: 1:25-cv-01833 Document #: 63 Filed: 06/17/25 Page 1 of 6 PageID #:868 2 D852,415 (the “Dyson Designs”) to residents of Illinois. The Dyson Designs are shown in the below chart. Patent Number Claim Issue Date D853,642 July 9, 2019 Case: 1:25-cv-01833 Document #: 63 Filed: 06/17/25 Page 2 of 6 PageID #:869 3 Patent Number Claim Issue Date Case: 1:25-cv-01833 Document #: 63 Filed: 06/17/25 Page 3 of 6 PageID #:870 4 Patent Number Claim Issue Date D852,415 June 25, 2019 Case: 1:25-cv-01833 Document #: 63 Filed: 06/17/25 Page 4 of 6 PageID #:871 5 Patent Number Claim Issue Date THIS COURT FURTHER FINDS that Defendant is liable for patent infringement (35 U.S.C. § 271). IT IS HEREBY ORDERED that: 1. Defendant, its officers, agents, servants, employees, attorneys, and all persons acting for, Case: 1:25-cv-01833 Document #: 63 Filed: 06/17/25 Page 5 of 6 PageID #:872 6 with, by, through, under, or in active concert with it be permanently enjoined and restrained from: a. offering for sale, selling, and importing the 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 the parties’ settlement agreement, Defendant shall pay Plaintiff in total $4,000 (four thousand dollars) in damages (the “Damages Amount”). 3. Walmart Inc. (“Walmart”) is ordered to transfer the Damages Amount from Defendant’s accounts to Plaintiff within seven (7) calendar days of receipt of this Order. 4. Upon Walmart’s transfer of Damages Amount to Plaintiff pursuant to paragraph 2, Walmart shall remove any restraints that were placed on Defendant’s e-commerce store and financial account pursuant to the Temporary Restraining Order [24]. 5. This case is dismissed with leave to reinstate within one hundred and eighty (180) days, at such time, absent a motion to reinstate, shall automatically convert to a dismissal with prejudice. 6. Each party shall bear its own attorney’s fees and costs.”
Source: PACER Docket, Case 1:25-cv-01833, Illinois Northern District Court

The consent judgment is notable for its explicit judicial findings prior to the agreed order — the court affirmatively found personal jurisdiction and infringement liability under 35 U.S.C. § 271 rather than simply endorsing a private settlement. This distinction means the infringement finding carries judicial authority. The permanent injunction’s anti-circumvention language, expressly barring successor entities, reflects N.D. Illinois practice in Schedule A cases and extends Dyson’s enforcement reach beyond the named defendant alias.

PACER case 1:25-cv-01833 · Public docket record Explore in Eureka ↗
Patent at issue

USD0852415S & USD0853642S — Dyson hair appliance ornamental designs

Publication No.USD0852415S
Application No.US29/627707
Patent details
ProductOrnamental design of a Dyson hair styler appliance
Cited in actionFebruary 21, 2025

Publication No.USD0853642S
Application No.US29/627749
Patent details
ProductOrnamental design of a Dyson hair dryer appliance
Cited in actionFebruary 21, 2025

U.S. Design Patents D852,415 (issued June 25, 2019) and D853,642 (issued July 9, 2019) protect the ornamental visual appearance of Dyson’s hair styling and drying appliances — not their functional mechanics. Both filed under application numbers US29/627707 and US29/627749 respectively, these design patents cover the specific aesthetic elements that give Dyson products their distinctive commercial identity. Design patents grant 15-year terms from grant date under U.S. law, placing both patents within their active enforcement window through 2034.

For Dyson, design patents serve a dual function: brand protection and competitive moat. The distinctive visual language of Dyson hair appliances commands premium retail positioning, and lookalike products on e-commerce platforms directly threaten that brand equity. Because the ordinary observer test — rather than a claim-by-claim technical comparison — governs design patent infringement, enforcement is faster and the infringement standard more intuitive to courts. This makes design patents particularly effective enforcement instruments against marketplace counterfeiters and copycat OEM products entering U.S. channels.

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

Should you run an FTO against USD0852415S and USD0853642S?

Any company developing or sourcing hair appliances — dryers, stylers, straighteners, or multi-function tools — that will be sold on U.S. e-commerce platforms (Amazon, Walmart, Temu, Shein) should conduct a design patent freedom-to-operate analysis against Dyson’s active design patent portfolio. This case confirms Dyson actively monitors marketplace listings and moves swiftly: TROs were secured and account freezes applied before the seller could respond. The risk is not hypothetical — it is operational and immediate.

PatSnap Eureka’s FTO Search Agent can map your product’s visual design against Dyson’s design patent claims, identify the closest prior art, and flag design-around opportunities before your product reaches U.S. customs or marketplace listing. Eureka surfaces the full Dyson design patent family, prosecution history, and related enforcement actions — giving your IP and product teams the intelligence to make a launch decision with confidence rather than exposure.

PatSnap Eureka FTO Search

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

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Related litigation

Similar design patent Schedule A cases in N.D. Illinois — hair and consumer appliances

Cases matching Dyson’s Schedule A design patent enforcement pattern in the Northern District of Illinois against e-commerce defendants in the consumer appliance and personal care sector.

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Dyson Technology Limited patent enforcement history, Illinois Northern case history, Dyson Technology Limited’s full IP portfolio, and comparable case analysis
Dyson prior Schedule A filingsN.D. Ill. design patent TRO grantsHair appliance IP enforcement mapComparable damages awards
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Strategic implications

What this case signals for the consumer electronics IP enforcement landscape

Dyson’s Schedule A strategy demonstrates how design patents function as rapid-deployment enforcement tools against e-commerce infringers.

TRO-based account freezes are the real enforcement lever in Schedule A cases

Dyson’s ability to freeze defendant Walmart accounts at the TRO stage — before any merits ruling — is what drives early settlement. The $4,000 damages figure reflects the leverage of operational disruption, not the full value of infringing sales. Marketplace sellers should treat TRO risk as an existential prompt to audit their product listings against active design patent portfolios.

Consent judgment preserves an infringement finding — stronger than a settlement alone

By obtaining a court-entered finding of infringement under 35 U.S.C. § 271, Dyson builds a public enforcement record. This matters in future actions: a pattern of consent judgments can support enhanced damages arguments and signals to other potential infringers that Dyson litigates to enforceable conclusions, not just private releases.

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Unlock design patent FTO risk analysis and Dyson’s Schedule A campaign strategy in N.D. Illinois district court enforcement data.
Design claim scope analysisReinstatement risk indicatorsCampaign-level damages aggregation
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Frequently asked questions

Limited v Partnerships — key questions answered

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Monitor Dyson’s design patent campaign before it targets your product

Dyson actively enforces D852,415 and D853,642 across U.S. marketplaces with rapid TRO filings that freeze accounts within days of filing. PatSnap Eureka gives your IP team real-time enforcement monitoring and FTO analysis to stay ahead of design patent risk in the personal care appliance space.

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