Gulan Liao v. Entities: Default Judgment & Permanent Injunction Over Toy Aircraft Designs
Plaintiff Gulan Liao, holder of toy aircraft design patent USD891522S, secured a default judgment and permanent injunction against multiple Chinese e-commerce sellers in the Northern District of Illinois in just 117 days. The court awarded $20,000 in statutory damages per defaulting defendant and ordered domain transfers, account freezes, and fund releases across major online platforms including Amazon, AliExpress, and Wish.com.
Schedule A Infringement Action Ends in Full Default Judgment for Toy Aircraft Designer
Filed on 5 January 2024 in the Northern District of Illinois before Judge LaShonda A. Hunt, this action was brought by Gulan Liao against a network of Chinese online marketplace operators collectively identified on Schedule A. The asserted intellectual property centres on USPTO design application US29/730859 (published as USD891522S), protecting the ornamental appearance of a toy aircraft product. Defendants included entities such as GuangZhouJiaGeShangMao, Shanghai Hengdi Trading Co. Ltd., QIQI-USS, QXINSM, Jingbu department store, and guchengxianchangxinshangmaoshanghang, all alleged to have sold infringing products through online storefronts on platforms including Amazon, AliExpress, and Wish.com.
The case closed on 1 May 2024 — just 117 days after filing — when the court granted Plaintiff’s Motion for Entry of Default and Default Judgment. Because no defendant appeared or responded, the court entered judgment on default, awarding $20,000 in statutory damages per distinct defaulting defendant under 17 U.S.C. § 504 for willful infringement of three copyrighted works. The judgment further ordered a permanent injunction barring all future manufacture, sale, import, and distribution of products using Plaintiff’s protected designs, and directed third-party platforms and domain registrars to disable or transfer defendant domain names and freeze or release defendant financial accounts within seven days.
The 117-day resolution is consistent with the expedited pace typical of Schedule A cases in the Northern District of Illinois, where plaintiffs routinely obtain ex parte temporary restraining orders and proceed to default when offshore defendants fail to engage. The public record does not disclose the precise monetary amounts ultimately released from frozen accounts, nor the total number of distinct defendants against whom the $20,000 award applied. What remains unknown is whether any defendant subsequently moved to vacate the default, a procedural option that is available but rarely exercised in these actions. The case illustrates the continued utility of the Northern District of Illinois as a plaintiff-friendly venue for enforcing design rights against e-commerce infringers.
Filing to Injunction Granted in 117 days
117 days — resolved well under the district median for IP infringement actions
Default judgment entered: what the ruling means for plaintiff and defendants
Default judgment: court rules without a contested hearing
When defendants fail to appear or respond to a complaint, the court may enter default judgment under Fed. R. Civ. P. 55. Here, all named defendants failed to engage, allowing the court to accept Plaintiff’s well-pleaded allegations as admitted. The result is a binding judgment — including permanent injunction and damages — without any merits adjudication between opposing counsel. Defendants retain limited post-judgment options, chiefly a motion to vacate under Rule 60(b), but the bar is high.
Rule 55 default procedureFull relief granted: injunction, damages, and asset recovery
Gulan Liao obtained the maximum range of relief available in a Schedule A action: a permanent injunction covering all defendant storefronts and domains, $20,000 statutory damages per defendant for willful infringement of three copyrighted works, and an order directing third-party platforms — including Amazon, PayPal, Alibaba, and Wish.com — to freeze and release defendant funds within 14 days. Domain registrars were further ordered to transfer or disable defendant domain names within seven days.
Maximum statutory damages awardedPermanent injunction and frozen accounts — no defence entered
Each defaulting defendant is permanently enjoined from selling, importing, or distributing any product bearing Plaintiff’s protected designs or any colorable imitation. Their online marketplace accounts, associated funds (up to the awarded damages), and domain names are subject to immediate third-party enforcement. Defendants who wish to contest this outcome must move to vacate the default under Rule 60(b), demonstrating a meritorious defence and excusable neglect — a difficult standard to meet post-judgment.
Permanent injunction; accounts frozenEscalating enforcement risk for e-commerce design copycats
This case is one of many Schedule A actions litigated annually in the Northern District of Illinois against offshore e-commerce sellers. The combination of expedited default procedures, platform cooperation from Amazon and AliExpress, and PayPal/Ant Financial account freezes creates a highly effective enforcement mechanism. For any seller operating in the toy or novelty product space, the case signals that product listing inactivity following a complaint will not prevent adverse judgment — and that financial accounts on US-linked platforms remain directly reachable.
High enforcement risk for online resellersFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Gulan Liao | Individual | Toy aircraft design rights holder — owner of design patent USD891522S (US29/730859)Search in Eureka ↗ |
| Defendant | Entities | Individual | Network of Chinese online marketplace sellers trading infringing toy aircraft via Amazon, AliExpress, Wish.com and affiliated storefrontsSearch in Eureka ↗ |
| Co-Defendant | The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint | Individual | Search in Eureka ↗ |
| Co-Defendant | GuangZhouJiaGeShangMao | Individual | Search in Eureka ↗ |
| Co-Defendant | guchengxianchangxinshangmaoshanghang | Individual | Search in Eureka ↗ |
| Co-Defendant | Jingbu department store | Individual | Search in Eureka ↗ |
| Co-Defendant | QIQI-USS | Individual | Search in Eureka ↗ |
| Co-Defendant | QXINSM | Individual | Search in Eureka ↗ |
| Co-Defendant | Shanghai Hengdi Trading Co., Ltd | Company | Search in Eureka ↗ |
| Plaintiff counsel | Shengmao Mu | Attorney | Counsel for Gulan LiaoSearch in Eureka ↗ |
| Plaintiff law firm | Whitewood Law, PLLC | Law Firm | Representing Gulan LiaoSearch in Eureka ↗ |
| Presiding judge | Judge LaShonda A. Hunt | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order grants every form of relief sought: a permanent injunction, $20,000 statutory damages per defendant for willful infringement of three copyrighted works, domain transfer or disablement, and third-party financial account freezes. The willfulness finding — which supports the elevated statutory damages figure — follows from defendants’ default rather than from any evidentiary hearing, consistent with established Seventh Circuit practice in Schedule A cases. No claim construction or invalidity analysis was conducted. The breadth of the injunction, extending to ‘colorable imitations’ of the protected designs, gives Plaintiff strong leverage in any supplemental enforcement proceeding under Fed. R. Civ. P. 69.
USD891522S (US29/730859) — Toy Aircraft Ornamental Design
USD891522S, filed under application number US29/730859, is a US design patent protecting the ornamental appearance of a toy aircraft. Design patents in the United States cover the non-functional, aesthetic features of a manufactured article — in this case the visual appearance of the toy aircraft as depicted in the patent’s drawings. The patent was asserted here on the basis that defendants’ products constituted colorable imitations of the protected design, which is the operative standard for design patent and copyright infringement in the context of consumer product ornamental features. The copyright claims (three works) suggest that Plaintiff may also hold separate 2D artistic registrations covering graphics or surface ornamentation applied to the product.
Design rights in the toy and novelty product sector are commercially significant precisely because products in this category compete primarily on visual appeal rather than technical specification. USD891522S, enforced successfully in this action, establishes that Plaintiff has a registered right capable of triggering the expedited Schedule A enforcement mechanism in the Northern District of Illinois — one of the most active venues for this type of IP litigation. Competing manufacturers in the toy aircraft and novelty drone categories should treat this patent as a clearance risk, particularly when developing products with similar planform geometry, surface detail, or colour scheme to the registered design.
Should you run an FTO against USD891522S before launching a toy aircraft product?
Any product team developing or sourcing toy aircraft, novelty drones, or similar ornamental flight-themed consumer goods for the US market should consider a freedom-to-operate review against USD891522S and related design registrations held by Gulan Liao. The Northern District of Illinois default judgment demonstrates that this design right is actively enforced against online marketplace sellers — including those operating through Amazon, AliExpress, and Wish.com. The relevant question is not merely whether your product is technically distinct, but whether its overall ornamental appearance would be considered substantially similar by an ordinary observer applying the Egyptian Goddess standard.
PatSnap Eureka’s FTO Search Agent can map the ornamental claim scope of USD891522S against your product’s design renders, identify design-arounds, and surface any related design applications or continuation filings by the same applicant. The tool also flags co-pending Schedule A litigation involving comparable design assets, giving your legal and product teams a complete picture of enforcement exposure before committing to a product launch or import programme.
Run a freedom-to-operate analysis on USD0891522S to assess your product’s exposure
Run FTO in Eureka →Similar toy design patent Schedule A enforcement cases in N.D. Illinois
Browse comparable Schedule A default judgment actions involving toy and novelty product design patents litigated in the Northern District of Illinois.
What this case signals for toy and novelty product IP enforcement
Schedule A design enforcement is fast, platform-backed, and largely uncontested — making IP registration and monitoring essential for any market participant.
Register design rights early: USD891522S secured injunction and damages in 117 days
Gulan Liao’s ability to obtain a full default judgment — including permanent injunction and asset freeze — depended entirely on having a registered design right in force. Without the registered design (USD891522S), access to statutory damages under 17 U.S.C. § 504 and injunctive relief via the Schedule A mechanism would have been unavailable. Early registration is the prerequisite for this enforcement pathway.
Platform cooperation is now a central feature of US design enforcement
The court’s order directly engaged Amazon, AliExpress, Alibaba, Wish.com, PayPal, and Ant Financial — requiring account freezes and fund releases within seven days. This reflects a maturing enforcement ecosystem in which US courts routinely command platform compliance. Any seller or brand owner operating across these channels should understand that a default judgment in the Northern District of Illinois can reach global e-commerce accounts with minimal additional litigation.
Liao v Entities — key questions answered
The court entered default judgment in favour of plaintiff Gulan Liao on 1 May 2024. Defaulting defendants were awarded a permanent injunction prohibiting further sale or importation of infringing toy aircraft products, and Plaintiff received $20,000 in statutory damages per defaulting defendant for willful infringement of three copyrighted works.
USD891522S (application no. US29/730859) is a US design patent protecting the ornamental appearance of a toy aircraft. US design patents cover the non-functional aesthetic features of a product as depicted in the patent drawings. The case also involved three separate copyright registrations covering related surface or graphic ornamentation applied to the product.
The $20,000 per defendant figure reflects statutory damages under 17 U.S.C. § 504 for willful copyright infringement. Because all defendants defaulted without appearing, the court accepted Plaintiff’s characterisation of infringement as willful, which supports enhanced statutory damages. The award applied once per distinct defendant, even where a single defendant operated under multiple aliases.
Schedule A cases are a category of IP infringement action in which a US rights holder sues a large group of typically overseas e-commerce sellers, identified collectively on an attached schedule rather than individually in the complaint caption. The Northern District of Illinois has become a preferred venue due to its established procedures for granting ex parte TROs, freezing marketplace accounts, and entering default judgments efficiently against non-appearing defendants.
Yes, in principle. Defendants may file a motion to vacate the default judgment under Federal Rule of Civil Procedure 60(b), arguing excusable neglect, lack of notice, or a meritorious defence. However, courts apply a demanding standard, and the practical challenges of overseas defendants engaging US litigation counsel make successful vacatur uncommon in Schedule A actions. No public record of a vacatur motion in this case is apparent from the available data.
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