Dyson v. Schedule A Defendants: Default Judgment in Hair Styling Design Patent Case
Dyson Technology Limited secured a default judgment in the Northern District of Illinois against anonymous online marketplace sellers accused of infringing two design patents covering hair styling and hair care apparatus. The court granted a permanent injunction and asset freeze within 96 days of filing — a notably swift resolution consistent with Dyson’s aggressive anti-counterfeiting enforcement strategy.
Dyson’s Schedule A enforcement playbook wins default in 96 days
Dyson Technology Limited filed suit on 22 August 2025 in the Northern District of Illinois before Judge Sunil R. Harjani, asserting infringement of two US design patents — USD0852415S and USD0853642S — covering hair styling and hair care apparatus. The defendant was identified only as ‘The Partnerships and Unincorporated Associations Identified on Schedule A’, a procedural device commonly used in brand-protection actions targeting multiple anonymous online marketplace sellers simultaneously.
The case closed on 26 November 2025 via default judgment — the court found the defaulting defendant had failed to appear or contest the claims, and granted Dyson’s motion in full. The order permanently enjoined the defendant from offering, selling, or importing infringing products, directed third-party platforms including PayPal and Alibaba to freeze associated accounts and disable advertisements within seven days, and authorised supplemental enforcement proceedings under Federal Rule of Civil Procedure 69 to pursue any further assets.
A 96-day lifecycle from filing to final judgment is consistent with the accelerated timelines that characterise Schedule A design-patent cases in the Northern District of Illinois, where default outcomes are common when defendants — typically offshore e-commerce sellers — fail to engage. The public record does not disclose the quantum of damages awarded, the number of seller accounts targeted on Schedule A, or whether any defendants subsequently sought to vacate the default. The swift resolution suggests Dyson experienced no meaningful opposition.
Filing to Default Judgment in 96 days
96-day resolution — well below the typical district court median of 2+ years for patent cases
Default judgment entered: permanent injunction and asset freeze against infringing sellers
Default judgment: defendant failed to appear or defend
A default judgment under Federal Rule of Civil Procedure 55 is entered when a defendant fails to plead or otherwise defend against a complaint. Here, the defaulting defendant did not appear, allowing the court to treat the well-pleaded allegations as admitted. The result is a final judgment on the merits in Dyson’s favour without a trial, carrying full injunctive and monetary relief.
FRCP 55 defaultDyson obtains permanent injunction and platform-level asset freeze
Dyson secured a permanent injunction barring the defaulting defendant from selling or importing infringing hair styling products. Critically, the order binds third-party platforms — including PayPal and Alibaba — requiring them to freeze funds and disable seller accounts within seven days. This platform-level enforcement is a core commercial objective of Schedule A litigation, enabling Dyson to disrupt infringing supply chains without chasing individual sellers.
Injunction + asset freezeNon-appearing sellers face permanent sales ban and frozen funds
The defaulting defendant is permanently restrained from selling or importing the infringing products and is subject to asset restraint up to the damages amount awarded. Online marketplace accounts and financial accounts linked to the defendant are frozen. The judgment also authorises Dyson to pursue supplemental discovery to identify any additional accounts, making it difficult for sellers to shift assets or re-register under new identities.
Permanent injunction enteredDesign patent enforcement through default is a proven Dyson tactic
This outcome is consistent with a broader industry pattern in which brand owners like Dyson use the Northern District of Illinois as a venue for rapid enforcement against online counterfeiters. Default judgments in Schedule A cases typically resolve within months and produce injunctions and asset freezes before defendants can dissipate funds. Competitors and IP teams should note that Dyson’s design patent portfolio for hair care apparatus is being actively enforced at scale.
Anti-counterfeiting enforcementFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dyson Technology Limited | Individual | Global consumer technology company — holder of USD0852415S and USD0853642SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online marketplace sellers identified collectively on Schedule ASearch 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 counsel | Lucas Allen Peterson | 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 Sunil R. Harjani | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order is comprehensive and self-executing in its enforcement reach. By naming PayPal and Alibaba directly as third-party providers subject to the seven-day compliance window, the court has created a mechanism that operates at the platform infrastructure level rather than requiring Dyson to pursue individual sellers separately. The supplemental proceedings authority under FRCP 69 preserves Dyson’s ability to pursue asset discovery against the defaulting defendant indefinitely until damages are fully recovered.
USD0852415S & USD0853642S — hair styling apparatus design patents
USD0852415S (application US29/627707) and USD0853642S (application US29/627749) are US design patents protecting the ornamental appearance of hair styling and hair care apparatus. Design patents cover the visual, non-functional aspects of a product — meaning any product that looks substantially similar to the patented design as perceived by an ordinary observer may constitute infringement, regardless of whether it copies the underlying technology. The closely numbered application series suggests these two patents were filed as part of a coordinated design-protection strategy, likely capturing different views or variants of Dyson’s hair care product line.
For competitors and manufacturers in the hair care appliance sector, these design patents carry significant commercial weight. Dyson’s product line — including its widely recognised hair dryers and styling tools — commands premium brand equity that is partly protected through design IP. Active enforcement of these patents against online marketplace sellers signals that Dyson is monitoring third-party platforms systematically. Any company designing, manufacturing, or distributing hair styling appliances with a visual profile similar to Dyson’s registered designs faces meaningful infringement exposure, particularly if selling through AliExpress, Alibaba, or similar channels.
Should you run an FTO analysis against USD0852415S and USD0853642S?
Any R&D team, ODM manufacturer, or product company developing hair styling or hair care appliances should treat these two Dyson design patents as active enforcement risks. This case confirms that Dyson is not merely holding the patents — it is using them aggressively against online sellers. If your product’s visual profile shares features with Dyson’s registered ornamental designs, an FTO analysis is not optional. The ordinary observer standard used in design patent infringement is broad, and similarity of overall impression — not just identical copying — can trigger liability.
PatSnap Eureka’s FTO Search Agent can map the full landscape of Dyson’s design patent portfolio across hair care and personal appliance categories, identify the specific claims and drawings in USD0852415S and USD0853642S, and flag visual similarity risks across your product pipeline. Eureka can also surface related design applications and continuations that may not yet have been asserted, giving your team early warning of emerging enforcement vectors before litigation is filed.
Run a freedom-to-operate analysis on USD0852415S to assess your product’s exposure
Run FTO in Eureka →Similar hair care design patent cases in N.D. Illinois Schedule A litigation
Explore related design patent enforcement actions in the Northern District of Illinois involving hair styling and personal care appliances against Schedule A online marketplace defendants.
What this case signals for the hair care appliance IP landscape
Dyson’s rapid default judgment signals that its design patent portfolio for hair styling apparatus is under active, systematic enforcement.
Schedule A default judgments move fast — respond or lose everything
The 96-day resolution is a warning to any seller operating in the hair styling appliance space on platforms like AliExpress or Alibaba. Dyson’s use of FRCP 55 default means that failure to appear results in a binding injunction and frozen accounts. Companies selling or manufacturing products in this space should conduct immediate FTO analysis against Dyson’s design patent portfolio.
Platform-level enforcement extends Dyson’s reach beyond individual sellers
By binding PayPal and Alibaba directly in the judgment, Dyson has created enforcement leverage that operates independently of whether it can locate individual sellers. This approach — increasingly common in N.D. Illinois Schedule A cases — means that even sellers who believe they are anonymous face real commercial risk through account suspension and fund freezing.
Limited v Partnerships — key questions answered
Dyson asserted two US design patents: USD0852415S (application US29/627707) and USD0853642S (application US29/627749), both covering the ornamental design of hair styling and hair care apparatus. The case was filed in the Northern District of Illinois on 22 August 2025.
A Schedule A defendant refers to a group of named defendants listed on a separate schedule attached to the complaint rather than in the caption itself. This procedural device is widely used in the Northern District of Illinois to pursue multiple anonymous online marketplace sellers — typically operating on platforms like AliExpress or Alibaba — in a single consolidated action, reducing filing costs and enabling rapid injunctive relief.
The order permanently enjoined the defaulting defendant from selling or importing infringing hair styling products, required third-party platforms including PayPal and Alibaba to freeze associated accounts and disable advertisements within seven days, and authorised Dyson to commence supplemental proceedings under FRCP 69 to pursue full recovery of awarded damages.
The case resolved in 96 days from filing (22 August 2025) to the default judgment order (26 November 2025). This timeline is consistent with Schedule A design patent enforcement actions in the Northern District of Illinois, where default judgments are common when offshore e-commerce sellers fail to appear and defend.
US design patent infringement is assessed under the ‘ordinary observer’ test established in Egyptian Goddess, Inc. v. Swisa, Inc. (Fed. Cir. 2008). A design infringes if an ordinary observer, familiar with the prior art, would be deceived into thinking the accused product is the same as the patented design. This is a visual similarity standard focused on overall ornamental impression, not functional features.
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