Dyson Technology Ltd v. Schedule A Defendants — Voluntary Dismissal in 3 Days
Dyson Technology Limited filed suit in the Northern District of Illinois asserting two design patents covering hair styling and hair care apparatus against an anonymous group of online defendants. The case was voluntarily dismissed just three days after filing, with the plaintiff citing a ruling in a related parallel proceeding.
Dyson’s 3-day Schedule A action dismissed, citing related ruling
On October 13, 2025, Dyson Technology Limited filed Case No. 1:25-cv-12496 in the U.S. District Court for the Northern District of Illinois before Judge John J. Tharp Jr. Dyson asserted two design patents — USD0852415S and USD0853642S, filed under application numbers US29/627707 and US29/627749 — against a group of unnamed defendants collectively referred to as ‘The Partnerships and Unincorporated Associations Identified on Schedule A,’ a common plaintiff-side device in e-commerce IP enforcement actions.
The case closed on October 16, 2025 — just three days after filing — via voluntary dismissal under Federal Rule of Civil Procedure 41(a)(1). The dismissal notice expressly references a ruling issued in the related case 24-cv-12434 (Docket No. 25) in the same court as the operative reason for terminating this action. The public record does not specify whether the dismissal was with or without prejudice, a distinction with material consequences for Dyson’s ability to re-file against the same defendants.
The three-day lifespan of this case is consistent with a coordinated multi-wave enforcement strategy often used by brand owners targeting counterfeit or infringing online sellers. The reference to a parallel ruling in 24-cv-12434 suggests this filing may have been mooted or superseded by developments in that companion proceeding. What remains unknown from the public record is whether Dyson obtained any relief in the related case, whether the Schedule A defendants were identified, and the precise terms and scope of the referenced ruling.
Filing to Voluntary dismissal in 3 days
Closed in 3 days — exceptionally fast, consistent with a tactical or coordinated multi-case filing strategy
Voluntarily dismissed: what the termination means for both parties
Rule 41(a)(1) voluntary dismissal — no merits adjudication
Under Federal Rule of Civil Procedure 41(a)(1), a plaintiff may dismiss an action without a court order before the defendant serves an answer or a motion for summary judgment. Here, Dyson exercised this right within three days of filing. Because no merits ruling was issued, the case ended procedurally rather than on the substance of the design patent infringement claims.
Procedural exit — no liability findingWith or without prejudice? The public record is silent
A voluntary dismissal ‘with prejudice’ bars Dyson from re-filing the same claims against the same defendants; ‘without prejudice’ preserves that right. The dismissal notice in this case does not specify which applies. Under Rule 41(a)(1)(B), a dismissal is presumed without prejudice unless the notice states otherwise — but practitioners should verify this directly from the docket before drawing conclusions.
Re-filing risk: unresolved from public recordSchedule A defendants face no judgment — but exposure may continue
The unnamed Schedule A defendants were not served with an answer or required to mount a defense in this specific proceeding. They face no adverse finding here. However, Dyson’s reference to a ruling in the companion case 24-cv-12434 suggests the underlying enforcement effort remains active. Defendants identified in the broader Schedule A may still be subject to enforcement actions, injunctions, or asset freezes in related proceedings.
No judgment — parallel risk persistsMulti-case e-commerce enforcement: a coordinated IP playbook
Filing and rapidly dismissing Schedule A actions is a recognised tactic in brand-owner enforcement against online counterfeiters. Courts in the Northern District of Illinois have significant experience with this approach. The referencing of case 24-cv-12434 suggests this action was one wave in a broader Dyson enforcement campaign. IP teams and platforms hosting third-party sellers in the hair styling category should monitor Dyson’s parallel docket activity closely.
Part of broader Dyson enforcement waveFull 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 sellers identified collectively on Schedule A filingSearch 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 John J. Tharp, Jr. | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1) — a plaintiff-initiated procedural exit requiring no court consent at this early stage — and expressly ties the decision to ‘this Court’s ruling in 24-cv-12434 (Docket No. 25).’ This phrasing suggests the companion proceeding had already addressed the relief Dyson sought, rendering this parallel action redundant rather than abandoned on the merits. No infringement finding, validity ruling, or damages determination was made. The dismissal resolves this specific docket only; it carries no precedential weight on the design patent claims themselves.
USD0852415S & USD0853642S — Hair Styling Apparatus Design Patents
USD0852415S (application US29/627707) and USD0853642S (application US29/627749) are U.S. design patents held by Dyson Technology Limited. Design patents protect the ornamental appearance of a product — in this case, the visual design of hair styling and hair care apparatus. Unlike utility patents, design patents confer rights over how a product looks rather than how it functions, making them particularly potent in consumer electronics where product aesthetics drive purchasing decisions.
Dyson’s design patent portfolio in the hair styling category is strategically significant given the commercial success of its Airwrap and Supersonic product lines. Competitors and white-label manufacturers producing visually similar hair styling devices face heightened infringement risk. The simultaneous assertion of two design patents in a Schedule A filing suggests Dyson is building a layered visual IP perimeter around its product family — a tactic that raises the bar for any new market entrant seeking to capture the premium hair care segment.
Should you run an FTO against USD0852415S and USD0853642S?
Any company designing, manufacturing, importing, or selling hair styling or hair care apparatus — particularly cordless stylers, air-driven tools, or multi-attachment devices — should treat these two Dyson design patents as active clearance priorities. The N.D. Illinois Schedule A enforcement pattern shows Dyson is willing to move quickly and simultaneously against multiple sellers. A proactive FTO assessment reduces the risk of being named in a future wave of Schedule A filings.
PatSnap Eureka’s FTO Search Agent can map USD0852415S and USD0853642S against your product designs, identify design-around opportunities, and surface the full Dyson design patent family for comprehensive clearance. Eureka’s citation analysis and visual similarity tools are specifically suited to design patent landscapes — giving your R&D and product teams actionable guidance before a product reaches market or a marketplace listing goes live.
Run a freedom-to-operate analysis on USD0852415S to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A design patent cases in N.D. Illinois hair styling
Related Schedule A design patent enforcement actions filed in the Northern District of Illinois involving hair styling and consumer electronics apparatus by brand-owner plaintiffs.
What this case signals for the hair styling device IP landscape
Dyson’s rapid-fire Schedule A filing pattern signals sustained design patent enforcement pressure on e-commerce sellers in the hair care category.
Dyson is running a coordinated multi-case design patent enforcement campaign
The three-day lifespan and explicit cross-reference to companion case 24-cv-12434 are consistent with a coordinated, multi-wave enforcement strategy. Brand owners in the hair styling sector should expect Dyson to continue leveraging design patents USD0852415S and USD0853642S — and potentially others — against online marketplace sellers.
Schedule A tactics create systemic risk for e-commerce platform sellers
Online sellers of hair styling and hair care apparatus operating on platforms such as Amazon or Shopify should treat this filing as a signal that Dyson is actively monitoring and enforcing its design patent portfolio. Even a voluntary dismissal in one case does not eliminate re-filing risk, particularly where prejudice terms are unspecified in the public record.
Limited v Partnerships — key questions answered
Dyson’s dismissal notice cites a ruling in the companion case 24-cv-12434 (Docket No. 25) as the operative reason. This suggests the relief sought — such as a temporary restraining order or asset freeze — was obtained or resolved in the parallel proceeding, making this separate action redundant. The three-day timeline is consistent with coordinated multi-case e-commerce enforcement tactics commonly used in N.D. Illinois Schedule A matters.
Dyson asserted two design patents: USD0852415S (application US29/627707) and USD0853642S (application US29/627749), both covering the ornamental design of hair styling and hair care apparatus. Design patents protect visual appearance rather than functionality, making them a powerful tool against copycat products in the consumer electronics space.
A Rule 41(a)(1) voluntary dismissal means the plaintiff ended the case without a court order and before any substantive proceedings occurred. No liability, infringement, or validity ruling was made. Under Rule 41(a)(1)(B), such dismissals are presumed to be without prejudice unless stated otherwise, meaning Dyson could potentially re-file against the same defendants — though the public record here does not specify the prejudice terms.
In U.S. e-commerce IP enforcement, plaintiffs often file against large numbers of anonymous online sellers whose identities are listed in a sealed Schedule A exhibit rather than in the public complaint. This allows brand owners like Dyson to pursue dozens or hundreds of marketplace sellers simultaneously while initially concealing their identities. N.D. Illinois is a particularly active venue for Schedule A design patent cases.
Yes. The filing of this action alongside the parallel case 24-cv-12434 suggests Dyson is running an active, multi-case enforcement campaign targeting online sellers of hair styling apparatus. Even though this specific case was voluntarily dismissed, the companion proceeding remains relevant. Sellers — particularly those on third-party marketplaces — should conduct FTO analysis against USD0852415S and USD0853642S and monitor Dyson’s N.D. Illinois docket activity.
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