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Dyson v. Schedule A Sellers: Design Patent Infringement — Hair Styling | PatSnap
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Case ID1:25-cv-12610
FiledOct 2025
ClosedDec 2025
Patent Litigation

Dyson v. Schedule A Sellers: Default Judgment for Hair Styling Design Patent Infringement

Dyson Technology Limited secured default judgment against 27 online marketplace sellers within 63 days of filing, asserting design patents D852,415 and D853,642 covering its iconic hair styling product designs. The court awarded damages under 35 U.S.C. § 289 and issued a permanent injunction, with third-party platforms including Amazon, PayPal, and Walmart ordered to freeze and release seller funds.

Resolution time
63days
63 days — faster than the typical Schedule A default cycle of 90–120 days
Patents asserted
2
USD852,415 and USD853,642 — hair styling apparatus ornamental designs, 2 design patents asserted
Outcome
Default Judgment
27 defaulting defendants; permanent injunction and § 289 profit disgorgement awarded
Cost ruling
§ 289 Damages
Total infringer profits disgorged; $250–$282.79 per seller; funds released from frozen accounts
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Dyson’s Design Patents Survive 27-Seller Counterfeiting Ring in 63 Days

On October 15, 2025, Dyson Technology Limited filed suit in the Northern District of Illinois against a group of anonymous e-commerce sellers identified only on Schedule A, alleging design patent infringement of U.S. Patent Nos. D852,415 and D853,642 — both covering ornamental designs for hair styling and hair care apparatus. The defendants operated across major online marketplaces including Amazon, eBay, and Walmart, selling copycat products that Dyson alleged replicated the protected visual designs of its hair styling devices.

The case closed on December 17, 2025 — just 63 days after filing — via default judgment entered by Judge Thomas M. Durkin. None of the 27 defaulting defendants appeared or answered, causing the complaint’s allegations to be deemed admitted. The court found personal jurisdiction over all defendants based on their deliberate targeting of Illinois consumers through active e-commerce storefronts, entered a permanent injunction, and awarded disgorgement of infringer profits under 35 U.S.C. § 289, ranging from $250.00 to $282.79 per seller.

The 63-day resolution is notably swift even by Schedule A standards, consistent with an aggressive TRO-to-default pipeline employed by Dyson’s counsel at Greer, Burns & Crain. The absence of any defense response suggests defendants were likely overseas operators with limited U.S. presence. What remains unknown from the public record is the total number of defendants originally named — the final judgment covers 27 sellers, and others appear to have been dismissed prior to the default judgment, suggesting earlier settlements or voluntary dismissals as to some parties.

Case at a glance
Case no.1:25-cv-12610
CourtIllinois Northern
JudgeThomas M. Durkin
FiledOctober 15, 2025
ClosedDecember 17, 2025
Duration63 days
OutcomeDefault Judgment
Verdict causeInfringement Action
BasisDefault 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 Default Judgment in 63 days

63 days — faster than the typical Schedule A default cycle of 90–120 days

Case timeline: Complaint filed OCT 15 2025, NOV–DEC — 63 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. OCT 15 2025 Complaint filed Pre-trial proceedings DEC 17 2025 Default Judgment 63 DAYS TOTAL
Default judgment

Default judgment entered: what the ruling means for Dyson and the defendants

Legal mechanism

Default judgment: allegations deemed admitted, no merits contest

A default judgment under Federal Rule of Civil Procedure 55 is entered when defendants fail to appear or respond. The court deems all well-pleaded complaint allegations admitted. Here, Judge Durkin found design patent infringement under 35 U.S.C. § 271 established by Dyson’s uncontroverted evidence. Defendants forfeited their right to challenge infringement, invalidity, or damages by non-appearance.

FRCP 55 — no contest on merits
Plaintiff outcome

Dyson secures permanent injunction and profit disgorgement

Dyson obtained a permanent injunction barring all 27 defendants from selling, importing, or aiding sale of infringing products. Under 35 U.S.C. § 289, Dyson is entitled to total infringer profits — not merely lost profits — from the sale of infringing articles. Third-party platforms were ordered to freeze and release funds within 14 days. The $17,000 surety bond posted by Dyson was also returned.

§ 289 total profits — permanent injunction
Defendant outcome

Sellers face account freezes, fund seizure, and permanent market ban

All 27 defaulting defendants are permanently restrained from selling infringing products. Their marketplace accounts and financial accounts held by PayPal, Amazon, and Walmart are frozen and funds released to Dyson. Defendants cannot transfer assets or create new entities to circumvent the order. The court reserved Dyson’s right to pursue supplemental enforcement proceedings to recover any shortfall.

Account freeze — funds transferred to Dyson
Commercial implications

Schedule A enforcement: a scalable anti-counterfeiting tool for design patents

This case exemplifies the Schedule A model: file, obtain a TRO, serve electronically, and pursue default against non-appearing offshore sellers. For premium consumer electronics brands, design patents covering product aesthetics are a critical enforcement lever against counterfeit and copycat e-commerce listings. The 63-day cycle demonstrates how effectively U.S. courts can disrupt online counterfeit networks targeting domestic consumers.

Design patent enforcement — e-commerce counterfeit risk
Legal analysis based on PACER docket records for case 1:25-cv-12610 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffDyson Technology LimitedIndividualGlobal consumer technology company — holder of design patents D852,415 and D853,642Search in Eureka ↗
DefendantThe Partnerships and Unincorporated Associations Identified on Schedule AIndividual27 anonymous online marketplace sellers targeting U.S. consumers with infringing hair styling productsSearch 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 counselLucas Allen PetersonAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff counselThomas Joseph JuettnerAttorneyCounsel for Dyson Technology LimitedSearch in Eureka ↗
Plaintiff law firmGreer, Burns & Crain, Ltd.Law FirmRepresenting Dyson Technology LimitedSearch in Eureka ↗
Plaintiff law firmHusch Blackwell LLPLaw FirmRepresenting Dyson Technology LimitedSearch in Eureka ↗
Presiding judgeJudge Thomas M. DurkinJudgeIllinois Northern District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“This action having been commenced by Plaintiff Dyson Technology Limited (“Plaintiff” or “Dyson”) against the defendants identified on Schedule A, and using the Online Marketplace Accounts identified on Schedule A (collectively, the “Defendant Internet Stores”), and Plaintiff having moved for entry of Default and Default Judgment against the defendants identified on Schedule A attached hereto which have not yet been dismissed from this case (collectively, “Defaulting Defendants”); This Court having entered a preliminary injunction against certain defendants; Plaintiff having properly completed service of process on Defaulting Defendants, the combination of providing notice via electronic publication and e-mail, along with any notice that Defaulting Defendants received from payment processors, being notice reasonably calculated under all circumstances to apprise Defaulting Defendants of the pendency of the action and affording them the opportunity to answer and present their objections; and None of the Defaulting Defendants having answered or appeared in any way, and the time for answering having expired, so that the allegations of the Complaint are uncontroverted and are deemed admitted; Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 1 of 11 PageID #:986 2 This Court finds that it has personal jurisdiction over Defaulting Defendants because Defaulting Defendants directly target their business activities toward consumers in the United States, including Illinois. Specifically, Plaintiff has provided a basis to conclude that Defaulting Defendants have targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more seller aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars and/or funds from U.S. bank accounts, and have sold the same product shown in Exhibit 1 to the Complaint [3], that infringes Plaintiff’s U.S. Patent No. D853,642 and U.S. Patent No. D852,415, namely hair styling products that copy the ornamental designs shown in the below chart, to residents of Illinois. In this case, Plaintiff has presented screenshot evidence that each Defendant ecommerce store is reaching out to do business with Illinois residents by operating one or more commercial, interactive internet stores through which Illinois residents can and do purchase the Infringing Products. See Docket No. [19], which includes screenshot evidence confirming that each Defendant e-commerce store does stand ready, willing and able to ship the Infringing Products to customers in Illinois. Plaintiff’s U.S. Patent No. D853,642 and U.S. Patent No. D852,415 (the “Dyson Designs”) are shown in the below chart. Patent Number Claim Issue Date D853,642 July 9, 2019 Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 2 of 11 PageID #:987 3 Patent Number Claim Issue Date Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 3 of 11 PageID #:988 4 Patent Number Claim Issue Date D852,415 June 25, 2019 Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 4 of 11 PageID #:989 5 Patent Number Claim Issue Date This Court further finds that Defaulting Defendants are liable for design patent infringement (35 U.S.C. § 271). Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 5 of 11 PageID #:990 6 Accordingly, this Court orders that Plaintiff’s Motion for Entry of Default and Default Judgment is GRANTED as follows, that Defaulting Defendants are deemed in default, and that this Default Judgment is entered against Defaulting Defendants. This Court further orders that: 1. Defaulting Defendants, their officers, agents, servants, employees, attorneys, and all persons acting for, with, by, through, under, or in active concert with them be permanently enjoined and restrained from: a. offering for sale, selling, and importing 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 35 U.S.C. § 289, Plaintiff is awarded profits from each of the Defaulting Defendants for the sale of the Infringing Product sold through at least the Defaulting Defendants’ Seller Aliases according to the below chart: No. Defendant/Seller Alias Award 1 bofangim $250.00 2 gai199 $250.00 3 JingErKangJiaZheng $250.00 9 TFXR-AUTO Store $250.00 11 All we have is now $250.00 12 Find your fire $250.00 13 FYun-Enterprise $250.00 14 GaoHeNine $250.00 15 HB-501 $250.00 17 Jin Yue III $250.00 18 Jin Yue Li $250.00 19 Jin Yue zhou $250.00 Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 6 of 11 PageID #:991 7 20 Light chaser $250.00 21 LuoS-Enterprise $250.00 22 MSY-Enterprise $250.00 25 Phoenix plus local $250.00 26 QI XIN II Ltd $250.00 27 QI XIN IV Ltd $250.00 30 Shine like the stars $282.79 31 shuoshangfuzhuangyouxiangongsi $250.00 32 Take the road less $250.00 33 Tang Shuang $250.00 34 VTOCC $250.00 35 YONGDE seven Ltd $250.00 36 YONGDE six Ltd $250.00 37 YY&MIS $250.00 38 Zhang Weijun $250.00 3. Defaulting Defendants and any third party with actual notice of this Order who is providing services for any of the Defaulting Defendants, or in connection with any of the Defaulting Defendants’ Online Marketplaces, including, without limitation, any online marketplace platforms such as PayPal, Inc. (“PayPal”), eBay, Inc. (“eBay”), Amazon.com, Inc. (“Amazon”) and Walmart, Inc. (“Walmart”) (collectively, the “Third Party Providers”), shall within seven (7) calendar days of receipt of this Order cease: a. using, linking to, transferring, selling, exercising control over, or otherwise owning the Online Marketplace Accounts, or any other online marketplace account that is being used to sell or is the means by which Defaulting Defendants could continue to sell Infringing Products; and b. operating and/or hosting websites that are involved with the distribution, marketing, advertising, offering for sale, or sale of the Infringing Products. 4. Upon Plaintiff’s request, those with notice of this Order, including the Third Party Providers as defined in Paragraph 3, shall within seven (7) calendar days after receipt of Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 7 of 11 PageID #:992 8 such notice, disable and cease displaying any advertisements used by or associated with Defaulting Defendants in connection with the sale of Infringing Products. 5. Any Third Party Providers holding funds for Defaulting Defendants, including PayPal, Amazon and Walmart, shall, within seven (7) calendar days of receipt of this Order, permanently restrain and enjoin any accounts connected to Defaulting Defendants or the Defendant Internet Stores from transferring or disposing of any funds (up to the damages awarded in Paragraph 2 above) or other of Defaulting Defendants’ assets. 6. All monies (up to the amount of the damages awarded in Paragraph 2 above) currently restrained in Defaulting Defendants’ financial accounts, including monies held by Third Party Providers such as PayPal, Amazon and Walmart, are hereby released to Plaintiff as partial payment of the above-identified damages, and Third Party Providers are ordered to release to Plaintiff the amounts from Defaulting Defendants’ financial accounts within fourteen (14) calendar days of receipt of this Order. 7. Until Plaintiff has recovered full payment of monies owed to it by any Defaulting Defendant, Plaintiff shall have the ongoing authority to commence supplemental proceedings under Federal Rule of Civil Procedure 69. 8. In the event that Plaintiff identifies any additional online marketplace accounts or financial accounts owned by Defaulting Defendants, Plaintiff may send notice of any supplemental proceeding, including a citation to discover assets, to Defaulting Defendants by e-mail at the e-mail addresses identified in Exhibits to the Declaration of Giles Samuel Lane and any e-mail addresses provided for Defaulting Defendants by third parties. 9. The seventeen thousand dollar ($17,000) ($1,000 per Defendant subject to the TRO) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Case: 1:25-cv-12610 Document #: 58 Filed: 12/17/25 Page 8 of 11 PageID #:993 9 Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. This is a Default Judgment.”
Source: PACER Docket, Case 1:25-cv-12610, Illinois Northern District Court

The default judgment finds design patent infringement established by Dyson’s uncontroverted evidence, with all complaint allegations deemed admitted. The court’s invocation of 35 U.S.C. § 289 — the total profits remedy specific to design patent infringement — is significant: unlike utility patent damages, § 289 awards the defendant’s entire profit on the infringing article, not apportioned to the patented feature. The permanent injunction and fund-transfer mechanism directed at major platforms reflect the court’s willingness to treat non-appearing defendants’ marketplace infrastructure as subject to immediate judicial control.

PACER case 1:25-cv-12610 · Public docket record Explore in Eureka ↗
Patent at issue

USD852,415 & USD853,642 — Dyson Hair Styling Apparatus Ornamental Designs

Publication No.USD0852415S
Application No.US29/627707
Patent details
Productornamental design of a hair styling and hair care apparatus
Cited in actionOctober 15, 2025

Publication No.USD0853642S
Application No.US29/627749
Patent details
Productornamental design of a hair styling and hair care apparatus
Cited in actionOctober 15, 2025

U.S. Design Patents D852,415 (issued June 25, 2019) and D853,642 (issued July 9, 2019) protect the ornamental appearance — not functional features — of Dyson’s hair styling and hair care apparatus. Both patents originate from applications filed as U.S. 29/627,707 and 29/627,749 respectively. Design patents under 35 U.S.C. § 171 protect the novel, ornamental characteristics of a manufactured article, and their scope is assessed under the ordinary observer test established in Egyptian Goddess v. Swisa.

Dyson’s hair styling devices — including its high-profile Airwrap and Supersonic lines — occupy a premium consumer segment where product aesthetics drive purchase decisions and brand equity. Design patents on these distinctive forms create a broad perimeter against visual imitation. For competitors and ODM manufacturers supplying hair styling products to the U.S. market, these two patents represent active enforcement risk: Dyson has demonstrated both the will and the infrastructure to pursue rapid default judgment actions against e-commerce sellers globally.

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

Should you run an FTO against D852,415 and D853,642?

Any business designing, manufacturing, or importing hair styling or hair care apparatus for sale in the U.S. market — including curling wands, air stylers, blow dryers, and multi-function styling tools — should assess freedom-to-operate against Dyson’s D852,415 and D853,642. These patents cover ornamental designs and Dyson has shown readiness to enforce them aggressively via Schedule A actions. Marketplace sellers, private label brands, and OEM suppliers are all within scope.

PatSnap Eureka’s FTO Search Agent can map the visual claim scope of both design patents against your product designs, surface prior art that may limit enforceability, and identify related Dyson design patent families in the same product category. Run a proactive FTO analysis before product launch or marketplace listing to quantify your exposure — particularly given Dyson’s use of § 289 total profits claims and platform-level account freezes.

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 Consumer Electronics

Cases involving design patent enforcement against anonymous e-commerce sellers in the Northern District of Illinois, covering consumer electronics and hair care apparatus.

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Strategic implications

What this case signals for the consumer electronics IP landscape

Dyson’s swift default judgment reinforces the Schedule A model as a primary weapon against e-commerce design patent counterfeiting.

Design patents are actionable enforcement tools against online counterfeiters

Dyson’s use of ornamental design patents to pursue 27 sellers simultaneously demonstrates that design patents — often undervalued — carry significant enforcement weight in Schedule A actions. The § 289 total profits remedy is particularly powerful: it bypasses complex damages calculations and allows immediate fund seizure via cooperating platforms.

Third-party platform cooperation is integral to injunctive relief strategy

The court’s orders directed at Amazon, PayPal, eBay, and Walmart to freeze accounts and transfer funds within 7–14 days illustrate how brand owners can monetise injunctions even against anonymous defendants. Companies enforcing design patents should build platform cooperation into their litigation strategy from the outset, not as an afterthought.

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Seller alias clusteringDesign-around risk map§ 289 damages benchmarks
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Frequently asked questions

Limited v Partnerships — key questions answered

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Monitor Dyson Design Patent Enforcement and Hair Care IP Risk

Track new Schedule A filings by Dyson and monitor design patent activity in the hair styling and consumer electronics sector. Run a freedom-to-operate analysis against D852,415 and D853,642 before entering the U.S. market.

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