Dyson Technology Limited v. Schedule A Defendants (Case No. 1:25-cv-00630)
Dyson Technology Limited filed a design patent infringement action in the Northern District of Illinois asserting two design patents covering its hair styling and hair care apparatus against marketplace seller huayueecomme. The case closed just 24 days after filing, following a voluntary dismissal without prejudice under Rule 41(a)(1).
Dyson’s 24-day Schedule A design patent campaign: a swift voluntary exit
On January 17, 2025, Dyson Technology Limited filed suit in the U.S. District Court for the Northern District of Illinois against a defendant identified as part of a Schedule A group — a common enforcement tactic targeting online marketplace sellers allegedly offering counterfeit or infringing products. The asserted patents, USD0852415S and USD0853642S, protect ornamental design elements of Dyson’s hair styling and hair care apparatus. The specific defendant named in the dismissal is huayueecomme.
On February 7, 2025, Dyson filed a Rule 41(a)(1) voluntary notice of dismissal without prejudice as to defendant huayueecomme, and the case was formally closed on February 10, 2025. A dismissal without prejudice means Dyson has not relinquished its claims — it retains the legal right to refile against the same defendant at a future date. No judgment on the merits was entered, and no damages, injunctions, or fee awards were issued.
A 24-day lifecycle is consistent with Schedule A enforcement patterns where plaintiffs often secure a temporary restraining order to freeze marketplace accounts and assets before reaching a private resolution with the defendant. The public record does not disclose whether a settlement, payment, or takedown agreement was reached prior to the dismissal. The absence of defendant counsel on record further suggests the defendant may not have formally appeared before the matter concluded.
Filing to Voluntary dismissal in 24 days
24 days — resolved significantly faster than the median U.S. patent case lifespan
Voluntarily dismissed: what the Rule 41 exit means for both parties
Rule 41(a)(1): a unilateral exit with no merits ruling
Under Federal Rule of Civil Procedure 41(a)(1), a plaintiff may voluntarily dismiss an action without a court order before the defendant serves an answer or motion for summary judgment. Here, with no defendant counsel on record, Dyson could exit unilaterally. Crucially, no court decided whether the patents were infringed, valid, or enforceable — the slate is legally clean for both sides.
No merits adjudicationWithout prejudice vs. with prejudice: the public record is silent on terms
The dismissal was expressly filed without prejudice, meaning Dyson can refile the same claims against huayueecomme in the future. A ‘with prejudice’ dismissal would have permanently barred refiling. The public docket does not disclose whether the parties reached a private settlement, licensing arrangement, or takedown agreement prior to dismissal — only that Dyson chose to exit on these terms.
Refiling rights preservedNo judgment entered — but exposure remains open
Huayueecomme faces no court-ordered damages, injunction, or fee award as a result of this dismissal. However, because the dismissal is without prejudice, the threat of renewed litigation persists. If marketplace account freezes or asset restraints were obtained via TRO during the 24-day window, those orders would have dissolved upon dismissal, but the underlying IP risk has not been formally resolved.
No judgment — exposure not closedSchedule A tactics: fast resolution as a feature, not a bug
Dyson’s Schedule A enforcement programme targets online sellers at scale. A rapid voluntary dismissal after a brief window is consistent with a strategy designed to disrupt infringing listings, secure private agreements, or test enforcement against specific sellers. For other marketplace sellers of Dyson-design products, this case signals active monitoring and a willingness to file and resolve quickly — pattern litigation at pace.
Active enforcement signalFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dyson Technology Limited | Individual | Consumer electronics and home appliance IP licensor — holder of USD0852415S and USD0853642SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Online marketplace seller huayueecomme, identified under Schedule A defendant groupingSearch in Eureka ↗ |
| Plaintiff counsel | Andrew Daniel Burnham | Attorney | Counsel for Dyson Technology LimitedSearch in Eureka ↗ |
| Plaintiff counsel | Jennifer Van Nacht | 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 Jeremy C. Daniel | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1) and specifies ‘without prejudice’ — precise language that preserves Dyson’s ability to refile against huayueecomme. No merits determination was made. The phrasing ‘the above-captioned case can be terminated’ suggests the dismissal was self-executing, requiring no judicial order, consistent with Rule 41(a)(1)(A)(i) where no responsive pleading had been filed by the defendant.
USD0852415S & USD0853642S — Dyson hair styling apparatus design patents
USD0852415S (application no. US29/627707) and USD0853642S (application no. US29/627749) are U.S. design patents protecting the ornamental appearance of Dyson’s hair styling and hair care apparatus. Design patents under 35 U.S.C. § 171 protect how a product looks, not how it functions. The scope of protection is determined by the visual appearance shown in the patent drawings, making visual similarity the central infringement test under the ‘ordinary observer’ standard established in Egyptian Goddess v. Swisa.
For Dyson, these design patents form part of a broader IP strategy to protect the distinctive aesthetic of its premium hair care product line — products that command significant price premiums based in part on visual identity. Competitors and marketplace sellers offering products that are visually similar to the designs claimed in these patents face meaningful infringement exposure, even if the underlying technology is independently developed. The patents signal that Dyson treats product appearance as a core protectable asset in the hair care category.
Should you run an FTO against USD0852415S and USD0853642S?
Any company manufacturing, importing, or selling hair styling or hair care devices that bear aesthetic resemblance to Dyson’s product lines should conduct a freedom-to-operate assessment against these two design patents. This is particularly relevant for brands sourcing from third-party manufacturers in Asia, private-label sellers on Amazon or similar platforms, and any product team launching a new hair dryer, styler, or treatment device in the U.S. market. The ordinary observer test means even non-identical products can infringe if the overall visual impression is similar.
PatSnap Eureka’s FTO Search Agent can map USD0852415S and USD0853642S against your product’s visual design, identify design-around opportunities, and surface related Dyson design patent filings that may extend protection to adjacent product forms. Given Dyson’s demonstrated willingness to file Schedule A actions rapidly, an FTO review before product launch or marketplace listing is a practical risk-management step — not just a legal formality.
Run a freedom-to-operate analysis on USD0852415S to assess your product’s exposure
Run FTO in Eureka →Similar design patent infringement cases in hair care and personal devices
Cases involving design patent assertions over hair styling and personal care apparatus in U.S. district courts, particularly Schedule A enforcement actions in the Northern District of Illinois.
What this case signals for the hair care and consumer electronics IP landscape
Dyson’s Schedule A campaign over hair styling design patents reveals a fast, high-volume enforcement posture that carries real risks for online sellers.
Schedule A filings are enforcement tools, not just lawsuits
Dyson’s 24-day lifecycle is consistent with a TRO-driven enforcement model: file, freeze assets, resolve privately, dismiss. For marketplace sellers in consumer electronics and hair care, being named in a Schedule A action — even briefly — can result in platform delisting and frozen funds before any court merits ruling.
Design patent risk in hair care is real and actively monitored
USD0852415S and USD0853642S protect the ornamental appearance of Dyson’s hair styling apparatus. Design patents can be powerful against visually similar products even where function differs. Any manufacturer or seller sourcing hair care devices with visual similarity to Dyson’s products should treat these patents as live enforcement risk.
Limited v Partnerships — key questions answered
Dyson Technology Limited filed a design patent infringement action on January 17, 2025 in the Northern District of Illinois against online seller huayueecomme, asserting patents USD0852415S and USD0853642S covering Dyson hair styling apparatus. The case was voluntarily dismissed without prejudice on February 7, 2025 under Rule 41(a)(1), closing 24 days after filing. No merits ruling was issued.
USD0852415S (US29/627707) and USD0853642S (US29/627749) are U.S. design patents that protect the ornamental appearance of Dyson’s hair styling and hair care apparatus. Design patents cover how a product looks rather than how it functions. Infringement is assessed under the ‘ordinary observer’ standard — whether an ordinary consumer would find the accused product substantially similar in appearance to the patented design.
A voluntary dismissal without prejudice under Rule 41(a)(1) means Dyson chose to end this specific action against huayueecomme without a court ruling on the merits. Critically, Dyson retains the right to refile the same claims against the same defendant in the future. The defendant receives no judgment in its favour, and the patents remain valid and enforceable against all third parties.
Schedule A lawsuits are a common enforcement technique where a brand names multiple online sellers as a group of defendants identified on an attached schedule. This allows plaintiffs to file a single action against numerous marketplace sellers at once, often seeking a temporary restraining order to freeze seller accounts and funds. The strategy is designed to disrupt infringing listings at scale and is frequently used in the Northern District of Illinois against e-commerce sellers.
Yes. Because the dismissal was expressly without prejudice, Dyson is not barred from refiling infringement claims against huayueecomme based on USD0852415S and USD0853642S. Under the Federal Rules, a second voluntary dismissal of the same claims against the same defendant would operate as a dismissal with prejudice, but the first without-prejudice dismissal leaves Dyson’s options fully open.
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