Guizhou Xiaozhi v. Schedule A Defendants: Default Judgment on Solar Drip Irrigator Design Patent
Guizhou Xiaozhi Sheep Trading Co. Ltd secured a default judgment against dozens of e-commerce sellers accused of infringing U.S. Design Patent No. D1,008,412 S covering solar plant drip irrigator products. The Illinois Northern District Court awarded $10,000 in reasonable royalty damages per defaulting defendant, with platform-level asset freezes across Amazon, eBay, Temu, Alibaba, and other major marketplaces.
Design patent default judgment targets global e-commerce infringers
Filed on 10 June 2024 in the Illinois Northern District Court, this action was brought by Guizhou Xiaozhi Sheep Trading Co. Ltd — a Chinese company holding U.S. Design Patent No. D1,008,412 S covering the ornamental appearance of solar plant drip irrigator products — against an anonymous group of online sellers identified only as ‘Schedule A’ defendants. The defendants operated e-commerce storefronts across platforms including Amazon, eBay, AliExpress, Temu, Walmart, Etsy, and DHgate, targeting U.S. consumers with allegedly infringing versions of the patented design.
The case closed on 18 December 2025 when Judge Franklin U. Valderrama entered a Final Default Judgment. Because no defendant appeared or filed an answer, the court accepted the plaintiff’s unrebutted evidence — including screenshots demonstrating each store’s willingness to ship infringing goods to Illinois residents — as sufficient basis for both personal jurisdiction and liability. Under 35 U.S.C. § 284, the court awarded a reasonable royalty of $10,000 per defaulting defendant, with third-party payment processors and marketplace platforms ordered to freeze and remit corresponding account balances within seven calendar days.
The 556-day duration is consistent with Schedule A enforcement actions that include an initial temporary restraining order phase before default proceedings conclude. What remains unknown from the public record is the precise number of defendants named on Schedule A and the aggregate damages collected, as Schedule A itself is attached to the filed document rather than reproduced in the verdict text. The asset-freeze mechanism — extending to PayPal, Alipay, Ant Financial, and Amazon Pay — suggests a deliberate enforcement strategy designed to maximise recovery even where defendants cannot be personally served in conventional ways.
Filing to Default Judgment in 556 days
556-day duration from filing to default judgment — typical for Schedule A e-commerce enforcement actions
Default judgment entered: what the ruling means for both parties
Default judgment: liability found without contest
When defendants fail to appear or respond to a complaint, the court may enter a default judgment under Fed. R. Civ. P. 55. Here, none of the Schedule A defendants answered, allowing the court to accept all of plaintiff’s well-pleaded allegations as admitted. The court independently confirmed personal jurisdiction based on evidence that each storefront offered shipping to Illinois residents and accepted U.S. dollar payments — a standard jurisdictional threshold in Northern District of Illinois Schedule A cases.
Fed. R. Civ. P. 55 defaultPlaintiff wins damages and platform-level asset freeze
Guizhou Xiaozhi secured $10,000 per defendant in reasonable royalty damages under 35 U.S.C. § 284, a permanent injunction against further sales of infringing products, and an order requiring all major e-commerce platforms and payment processors to disable listings and release frozen funds within seven days. The ongoing authority to serve supplemental orders on payment processors strengthens the plaintiff’s ability to capture newly identified accounts.
Plaintiff win — full relief grantedNon-appearing sellers face frozen accounts and permanent injunction
Each defaulting defendant is subject to a permanent injunction barring further sale of the infringing solar drip irrigator design, plus a $10,000 damages liability. Critically, their marketplace and payment processor accounts have been frozen and funds released directly to the plaintiff. Defendants who did not appear retain no right to contest liability in this proceeding, though in limited circumstances a default judgment may be vacated if a defendant can demonstrate a meritorious defence and excusable neglect.
Account freeze — no appeal path evidentPlatform enforcement model signals risk for drop-ship sellers
This case exemplifies the Northern District of Illinois ‘Schedule A’ enforcement model increasingly used by IP holders against anonymous cross-border e-commerce sellers. The multi-platform asset freeze — spanning Amazon, eBay, Temu, Alibaba, Etsy, Walmart, and DHgate simultaneously — suggests that sellers operating identical or similar ornamental designs across multiple marketplaces face aggregate exposure well in excess of individual per-defendant awards. Design patent holders in consumer garden product categories should monitor this docket type for enforcement benchmarks.
Schedule A enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Guizhou Xiaozhi Sheep Trading Co. Ltd | Company | Chinese solar garden product company — holder of U.S. Design Patent D1,008,412 SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous e-commerce sellers across Amazon, eBay, Temu, AliExpress, DHgate, and Walmart storefrontsSearch in Eureka ↗ |
| Plaintiff counsel | Qin Li | Attorney | Counsel for Guizhou Xiaozhi Sheep Trading Co. LtdSearch in Eureka ↗ |
| Plaintiff counsel | Zhiwei Hua | Attorney | Counsel for Guizhou Xiaozhi Sheep Trading Co. LtdSearch in Eureka ↗ |
| Plaintiff law firm | Concord & Sage Pc | Law Firm | Representing Guizhou Xiaozhi Sheep Trading Co. LtdSearch in Eureka ↗ |
| Presiding judge | Judge Franklin U. Valderrama | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s default judgment order functions as a final merits determination — plaintiff’s allegations of infringement of Design Patent D1,008,412 S were accepted as admitted due to defendants’ non-appearance. The jurisdictional finding, grounded in screenshot evidence of Illinois-targeted e-commerce activity, follows the standard Northern District of Illinois personal jurisdiction analysis for Schedule A defendants. The $10,000 reasonable royalty award per defendant, rather than a profits-based calculation, suggests the court applied a conservative but enforceable damages floor consistent with the evidentiary record submitted.
USD1018709S — Solar Plant Drip Irrigator Ornamental Design
U.S. Design Patent No. D1,008,412 S (filed under application number US29/874825, published as USD1018709S) protects the ornamental appearance — not the functional mechanics — of a solar plant drip irrigator. Design patents in the U.S. grant a 15-year term from grant and are infringed when an ordinary observer, familiar with prior art designs, would believe the accused product is the same as the patented design. The solar drip irrigator category sits within the broader smart garden and outdoor watering accessories market, where low-cost manufacturing and drop-ship distribution have driven significant design copying on cross-border platforms.
Solar plant drip irrigators have become a high-volume, low-margin product category on Amazon, Temu, and AliExpress, making them a frequent target for design patent enforcement. Holding a U.S. design patent in this category provides a mechanism to seek platform takedowns and asset freezes rapidly, without proving consumer confusion (as would be required for trade dress claims). The breadth of the Schedule A defendant list — spanning multiple major platforms — suggests the asserted design had widespread uptake by anonymous sellers, which in turn indicates meaningful commercial appeal and replication risk for any company operating in the solar garden accessories space.
Should your product team run an FTO against USD1018709S?
Any company sourcing, importing, or selling solar-powered plant drip irrigators through U.S. e-commerce channels should consider a Freedom-to-Operate review against U.S. Design Patent D1,008,412 S. The ordinary observer test means even products with minor ornamental variations can be found infringing if the overall visual impression matches the patented design. With the patent now enforced via a default judgment — and platforms already on notice — the risk of a listing takedown or account freeze extends to re-sellers and fulfilment partners, not only original manufacturers.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of D1,008,412 S against your product designs, identify prior art that may narrow the patent’s effective reach, and surface related design patent filings by Guizhou Xiaozhi or competing rights holders in the solar garden accessories category. Running an FTO before launch or before expanding distribution to U.S. marketplaces significantly reduces the risk of becoming a Schedule A defendant in a subsequent enforcement action.
Run a freedom-to-operate analysis on USD1018709S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in the Northern District of Illinois
Browse related Schedule A design patent enforcement actions involving consumer garden and outdoor products filed in the Illinois Northern District Court.
What this case signals for the garden product design patent landscape
The ruling reinforces Schedule A litigation as an efficient route to multi-defendant design patent enforcement across global e-commerce platforms.
Platform-level asset freezes make enforcement viable against anonymous sellers
By ordering Amazon, eBay, Temu, DHgate, Alibaba, PayPal, and Ant Financial to freeze and remit funds simultaneously, the court enabled monetary recovery without requiring conventional service. Design patent holders in consumer product categories should assess whether their IP portfolio supports this enforcement model before infringement scales.
A $10,000 per-defendant royalty floor sets a working benchmark
The court’s reasonable royalty award of $10,000 per defaulting defendant under 35 U.S.C. § 284 is consistent with comparable Schedule A default judgments in the Northern District of Illinois. Companies monitoring competitors’ enforcement activity should treat this figure as a baseline when modelling litigation risk or licensing exposure for ornamental design patents.
Guizhou v Partnerships — key questions answered
The asserted patent is U.S. Design Patent No. D1,008,412 S (application number US29/874825, published as USD1018709S), covering the ornamental design of a solar plant drip irrigator. The court’s default judgment confirms infringement by all Schedule A defendants who failed to appear.
The court awarded $10,000 per defaulting defendant as a reasonable royalty under 35 U.S.C. § 284. In addition, the court ordered major payment processors and e-commerce platforms — including Amazon Pay, PayPal, Alipay, and Temu — to freeze and remit funds from defendants’ accounts within seven calendar days of receiving the order.
Judge Valderrama found personal jurisdiction based on plaintiff’s unrebutted screenshot evidence showing each defendant storefront offered shipping to Illinois residents, accepted U.S. dollar payments, and actively targeted U.S. consumers. This is the standard jurisdictional analysis applied to Schedule A defendants in the Northern District of Illinois.
Schedule A cases are a well-established enforcement mechanism in the Northern District of Illinois where a plaintiff sues a large group of anonymous e-commerce sellers listed in an attached schedule rather than naming each defendant individually. The process typically involves an ex parte temporary restraining order to freeze assets, followed by service via email and electronic publication, and often culminates in a default judgment when defendants do not respond.
In limited circumstances, a defendant may seek to vacate a default judgment under Fed. R. Civ. P. 60(b) by demonstrating excusable neglect and a meritorious defence. However, the Final Judgment designation and the asset-freeze and remittance orders already executed by payment processors make practical reversal difficult absent prompt action by an affected defendant.
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