Dyson Technology Limited v. Schedule A Defendants — Voluntary Dismissal After 103 Days
Dyson Technology Limited filed a design patent infringement action in the Northern District of Illinois against anonymised Schedule A defendants, asserting two design patents covering hair styling and hair care apparatus. The case closed after 103 days via voluntary dismissal under Rule 41(a)(1), with no merits adjudication on record.
Dyson’s design patent strike against anonymous e-commerce sellers
Dyson Technology Limited initiated this infringement action on 15 January 2025 in the Northern District of Illinois before Judge LaShonda A. Hunt. The suit targeted a group of defendants identified only as ‘The Partnerships and Unincorporated Associations Identified on Schedule A’ — a procedural device commonly used to pursue multiple anonymous online sellers simultaneously. Two design patents were asserted: USD0852415S and USD0853642S, both covering hair styling and hair care apparatus.
The case closed on 28 April 2025, 103 days after filing, when Dyson filed a voluntary notice of dismissal under Rule 41(a)(1) of the Federal Rules of Civil Procedure as to defendant ‘liusoreg’. The public record identifies this as a voluntary dismissal but does not specify whether it was with or without prejudice, leaving the precise legal effect on any future action against this defendant ambiguous from the available record.
A resolution within 103 days — before any substantive court ruling — is consistent with the rapid lifecycle typical of Schedule A design patent enforcement campaigns, where plaintiffs often obtain ex parte temporary restraining orders, freeze defendant assets, and subsequently negotiate swift resolutions. What drove the specific outcome here, and whether any monetary terms were involved, is not disclosed in the public record.
Filing to Voluntary dismissal in 103 days
103 days — faster than the median district court patent case, suggesting early resolution pressure or settlement
Voluntarily dismissed: what the Rule 41(a)(1) filing means for both parties
Rule 41(a)(1) voluntary dismissal — no court merits ruling
A Rule 41(a)(1) voluntary dismissal allows a plaintiff to end an action without a court order, typically before the defendant has served an answer or a motion for summary judgment. It is the most common exit mechanism in Schedule A enforcement campaigns. Crucially, it produces no judicial ruling on infringement, validity, or claim scope — the court makes no finding for or against either party.
No merits adjudicationPublic record is silent on prejudice designation
A dismissal ‘with prejudice’ bars Dyson from refiling against the same defendant on the same claims permanently. A dismissal ‘without prejudice’ preserves Dyson’s right to refile. Under Rule 41(a)(1), a first voluntary dismissal is without prejudice by default unless the notice states otherwise. However, the available public record for this case does not specify either designation, so the precise legal effect on future enforcement against ‘liusoreg’ cannot be confirmed from public filings alone.
Prejudice designation unconfirmedDefendant exits without a validity or infringement ruling
The named defendant ‘liusoreg’ faces no court-imposed finding of infringement, no damages award, and no injunction on the public record. However, the absence of a merits ruling does not confirm the defendant’s freedom to continue selling the accused products — Dyson retains its design patent rights and, depending on prejudice terms, may have preserved the option to refile or pursue other enforcement channels.
No finding for or against defendantSchedule A tactics remain a live enforcement tool for Dyson
This case is consistent with an established enforcement strategy used by premium consumer brand owners against anonymous e-commerce sellers. The speed of resolution — 103 days — suggests the filing itself may have achieved its commercial objective, whether through asset freezing, a private agreement, or the defendant’s cessation of sales. Competing sellers in the hair styling and hair care apparatus space should treat Dyson’s design patent portfolio as an active enforcement risk.
Active enforcement postureFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Dyson Technology Limited | Individual | Global consumer electronics and home appliances company — holder of USD0852415SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online sellers identified collectively on a Schedule A attachment to the complaintSearch 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 LaShonda A. Hunt | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal was filed by Dyson under Rule 41(a)(1)(A)(i), the self-executing voluntary dismissal mechanism that requires no court order and takes effect upon filing. The notice names ‘liusoreg’ specifically, suggesting Dyson may have resolved its claims against this defendant individually while potentially retaining actions against other Schedule A defendants. No infringement finding, validity ruling, or damages award attaches to this disposition — the case ends procedurally rather than on the merits.
USD0852415S & USD0853642S — Hair Styling and Hair Care Apparatus Designs
USD0852415S and USD0853642S are U.S. design patents, filed under application numbers US29/627707 and US29/627749 respectively. Design patents protect the ornamental appearance of a product rather than its functional features, making them particularly powerful against manufacturers of visually similar competing products. In the consumer hair care sector, where product aesthetics are central to brand differentiation, design patents provide a relatively low-cost, high-impact enforcement tool.
For a company with Dyson’s brand equity in premium hair styling devices — including its widely recognised Airwrap and Supersonic product lines — design patents serve as a critical perimeter defence against copycat products entering through e-commerce channels. The two patents asserted here suggest Dyson maintains a layered design patent strategy, protecting multiple aesthetic elements or product variants. Any competitor or OEM supplier developing hair styling apparatus with a visual profile similar to Dyson’s portfolio faces meaningful infringement exposure.
Should you run an FTO check against USD0852415S and USD0853642S?
Any manufacturer, importer, or online seller of hair styling or hair care apparatus — particularly cordless stylers, hair dryers, or multi-function grooming tools — should assess freedom to operate against Dyson’s active design patent portfolio. This case demonstrates that Dyson actively monitors e-commerce platforms and is willing to file multi-defendant Schedule A actions, potentially accompanied by ex parte asset freezes, against sellers it identifies as infringing.
PatSnap Eureka’s FTO Search Agent can map the full scope of Dyson’s design patent portfolio across jurisdictions, identify claims covering specific product silhouettes and ornamental features, and flag pending design applications that may mature into enforceable rights. For sourcing teams and product designers working on hair care appliances, an Eureka FTO analysis provides an evidence-based clearance report before products reach the marketplace.
Run a freedom-to-operate analysis on USD0852415S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in hair care and personal appliances
Cases filed in the Northern District of Illinois asserting design patents against Schedule A defendants in the hair styling and personal care appliance sector.
What this case signals for the hair styling device IP landscape
Dyson’s use of Schedule A filings and design patents signals a systematic approach to policing e-commerce infringement of its hair care apparatus designs.
Schedule A filings move fast — 103 days to close is the norm, not the exception
Design patent Schedule A cases in the Northern District of Illinois routinely resolve before any substantive briefing. The 103-day lifecycle here is consistent with that pattern. Businesses selling hair care or styling products on e-commerce platforms should assume that a filing of this type can result in asset freezes and marketplace delistings before they have a meaningful opportunity to respond on the merits.
Two design patents asserted signals a portfolio enforcement approach
Dyson asserted two design patents — USD0852415S and USD0853642S — in a single action, a tactic that increases the risk of infringement for sellers with even minor variations in product design. R&D and product teams sourcing hair styling apparatus should conduct design clearance searches against Dyson’s full design patent portfolio, not just the patents named in any individual complaint.
Limited v Partnerships — key questions answered
Dyson asserted two design patents: USD0852415S (application number US29/627707) and USD0853642S (application number US29/627749), both covering the ornamental design of hair styling and hair care apparatus.
Dyson filed a voluntary notice of dismissal under Rule 41(a)(1) of the Federal Rules of Civil Procedure as to defendant ‘liusoreg’. No court order was required. The public record does not specify whether the dismissal was with or without prejudice, so the precise legal effect on future actions is not confirmed from public filings.
Schedule A cases allow a plaintiff to sue multiple anonymous or pseudonymous online sellers in a single action, listing defendants on an attachment rather than naming them in the caption. This device is common in the Northern District of Illinois and is frequently used by consumer brand owners to pursue e-commerce marketplace sellers of counterfeit or infringing products efficiently, often alongside motions for ex parte temporary restraining orders.
No. A voluntary dismissal under Rule 41(a)(1) produces no merits ruling. The court made no finding on infringement, patent validity, or claim scope. The case ended procedurally, not on the substance of Dyson’s design patent claims.
The case was filed in the United States District Court for the Northern District of Illinois (case no. 1:25-cv-00429) and assigned to Judge LaShonda A. Hunt. Dyson was represented by Greer, Burns & Crain, Ltd.
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