Guo v. Schedule A Defendants: Default Judgment on Storage Shelf Design Patent
Kundian Guo secured a default judgment against a class of unnamed e-commerce sellers accused of counterfeiting a storage shelf covered by design patent USD1019220S. The Illinois Northern District Court issued a permanent injunction and ordered platform-level asset freezes across Amazon, AliExpress, Wish, and PayPal — resolving the case in 266 days.
Schedule A e-commerce counterfeit sweep ends in swift default
Filed on April 24, 2024, in the U.S. District Court for the Northern District of Illinois, this case was brought by Kundian Guo against a group of anonymous online sellers collectively identified as ‘The Partnerships and Unincorporated Associations Identified in Schedule A.’ The action alleged infringement of design patent USD1019220S (application no. US29/910118), which protects the ornamental appearance of a storage shelf product sold under Guo’s brand.
Because none of the defendants entered an appearance or filed a response, Guo moved for entry of default and default judgment. The court granted the motion on January 15, 2025, issuing a comprehensive order that permanently enjoined defendants from manufacturing, distributing, advertising, or selling infringing products and directed domain registrars and major e-commerce platforms — including Amazon, AliExpress, Alibaba, Wish.com, and eBay — to disable accounts and freeze financial assets within seven days of notice.
The 266-day resolution is consistent with the accelerated timeline typical of Schedule A design patent cases, where defendants are often overseas sellers who do not engage with U.S. proceedings. The $250-per-defendant statutory damages award under 35 U.S.C. § 289 is relatively modest, suggesting the primary strategic value lay in the injunctive and asset-seizure relief rather than monetary recovery. The public record does not reveal how many defendants were ultimately named in Schedule A or the total damages collected.
Filing to Default Judgment in 266 days
266 days from filing to default judgment — faster than typical N.D. Illinois civil disposition
Default judgment granted: what the ruling means for both parties
Default judgment: court rules without defendant participation
When defendants fail to appear or respond, Federal Rule of Civil Procedure 55 permits the plaintiff to seek a default and then a default judgment. The court accepts well-pleaded allegations as true and determines appropriate relief. Here, the court found sufficient basis to grant Guo’s motion in full, including injunctive relief and statutory damages — with no adversarial merits adjudication.
FRCP 55 — no merits contestGuo wins full relief: injunction, asset freeze, domain transfer
The default judgment delivers Guo substantial practical remedies: a permanent injunction, domain name transfer or disablement, platform account shutdowns across Amazon, AliExpress, Wish, and eBay, and the release of frozen funds up to the statutory damages cap. The ongoing authority to commence supplemental proceedings under FRCP 69 gives Guo further enforcement leverage to pursue remaining unpaid damages.
Permanent injunction + asset seizureDefendants bound by permanent injunction without day in court
Any defendant who received notice of this action and chose not to appear is now subject to a permanent injunction and financial account restraints. Default judgments can, in some circumstances, be challenged under FRCP 60(b) for lack of proper service or other good cause, but the burden falls on the defendant. Without such a motion, the judgment stands and platforms are obligated to enforce its terms immediately.
FRCP 60(b) challenge possiblePlatform enforcement orders signal deterrence beyond named defendants
Orders binding Amazon, AliExpress, Alibaba, Wish, and PayPal have deterrence value that extends beyond the named defendants: third-party providers receiving notice must act within seven days. For other sellers of similar storage shelf products, this judgment creates a documented enforcement record that can be cited in future proceedings and may prompt preemptive account closures on the same platforms.
Third-party platform liabilityFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Kundian Guo | Individual | Individual product designer and brand owner — holder of design patent USD1019220SSearch in Eureka ↗ |
| Defendant | THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A | Individual | Anonymous e-commerce sellers operating online stores across multiple global marketplace platformsSearch in Eureka ↗ |
| Plaintiff counsel | Robert Michael Dewitty | Attorney | Counsel for Kundian GuoSearch in Eureka ↗ |
| Plaintiff law firm | Dewitty And Associates, Chtd. | Law Firm | Representing Kundian GuoSearch in Eureka ↗ |
| Presiding judge | Judge LaShonda A. Hunt | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order is notably comprehensive in scope: rather than granting narrow damages, the court extended relief to domain registrars, payment processors, and e-commerce platforms by name. The $250 statutory damages figure per defendant under 35 U.S.C. § 289 reflects a willful-infringement finding by default rather than proven actual damages. The supplemental proceedings clause under FRCP 69 preserves Guo’s ability to pursue additional collection once further defendant assets are identified, suggesting the judgment is designed as both an injunctive instrument and an ongoing enforcement framework.
USD1019220S — ornamental design for a storage shelf
USD1019220S (filed under application number US29/910118) is a U.S. design patent protecting the ornamental appearance of a storage shelf. Design patents under 35 U.S.C. § 171 cover the visual, non-functional aspects of a product — meaning the claim scope is defined entirely by the drawings filed with the USPTO. The ‘D’ prefix designation and the application number suggest a relatively recent filing consistent with the 2024 litigation timeline.
Storage shelf design patents occupy a contested space: the product category is highly commoditised, with thousands of near-identical SKUs sold across global e-commerce platforms, making enforcement through Schedule A proceedings particularly common. For any seller, importer, or OEM sourcing storage products from overseas manufacturers, USD1019220S represents an active enforcement risk. The willingness of N.D. Illinois courts to grant comprehensive default judgments — including domain transfers and payment processor freezes — makes this a high-consequence IP right to overlook.
Should your storage shelf product be cleared against USD1019220S?
Any company listing, importing, or manufacturing storage shelf products for the U.S. market should assess whether their product’s ornamental appearance could be considered a colorable imitation of USD1019220S. This is especially relevant for Amazon and AliExpress sellers in home organisation categories, where the design features protected by this patent are widespread and where Schedule A plaintiffs actively monitor competitor listings for infringement.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD1019220S against your product drawings, identify design-around opportunities, and flag related active design patents in the storage and home organisation space. Running a freedom-to-operate analysis before a product launch or platform listing is significantly cheaper than responding to a Schedule A complaint and a motion for default judgment with asset freezes.
Run a freedom-to-operate analysis on USD1019220S to assess your product’s exposure
Run FTO in Eureka →Similar storage shelf design patent Schedule A cases in N.D. Illinois
Cases involving design patent enforcement against anonymous e-commerce sellers in N.D. Illinois follow a consistent pattern — explore comparable Schedule A judgments in the home goods and storage product space.
What this case signals for the e-commerce design patent IP landscape
Schedule A design patent cases are a growing enforcement tool — and this judgment illustrates both their power and their limits.
Schedule A filings are an effective rapid-response tool against counterfeiters
By grouping anonymous defendants under a single Schedule A complaint, plaintiffs like Guo can obtain sweeping injunctive relief across dozens of storefronts in a single proceeding. The 266-day timeline to default judgment — combined with platform-level asset freezes — demonstrates the practical enforcement speed this mechanism can achieve in N.D. Illinois.
§ 289 statutory damages: a floor, not a ceiling for strategic value
The $250-per-defendant award reflects the minimum available under 35 U.S.C. § 289, but the true commercial value of this outcome lies in the injunctions and frozen assets. Design patent holders facing mass e-commerce infringement should weigh statutory damages as a backstop while prioritising injunctive relief and platform cooperation as the primary remedies.
Guo v PARTNERSHIPS — key questions answered
The court entered a default judgment in favour of plaintiff Kundian Guo on January 15, 2025. Defendants failed to appear, and the court granted Guo’s motion in full — issuing a permanent injunction, ordering platform account shutdowns across Amazon, AliExpress, and Wish, directing domain transfers, and awarding $250 in statutory damages per defendant under 35 U.S.C. § 289.
The patent at issue is USD1019220S (application no. US29/910118), a U.S. design patent protecting the ornamental appearance of a storage shelf. Design patents protect visual, non-functional product features as defined by the patent drawings. Any product that appears substantially similar to the patented design to an ordinary observer may be deemed infringing.
A Schedule A complaint groups multiple anonymous online sellers into a single action. If a seller is named and fails to respond, the court may enter a default judgment that includes permanent injunctions, platform account freezes, domain disablement, and release of frozen financial assets. Sellers on Amazon, AliExpress, eBay, and Wish are particularly exposed given the platforms’ cooperation obligations under such orders.
The court awarded $250 per defaulting defendant in statutory damages under 35 U.S.C. § 289, which covers damages for unauthorised use of a patented design. This is a relatively modest award but applies to each distinct defendant individually. The order also provides for supplemental proceedings under FRCP 69 to recover any remaining unpaid amounts from identified assets.
Yes — a defendant bound by a default judgment may move to set it aside under Federal Rule of Civil Procedure 60(b), arguing grounds such as improper service, excusable neglect, or lack of jurisdiction. However, the burden falls on the defendant, timely motion is required, and the standard is not easily met. Once third-party providers such as PayPal or Amazon receive and comply with the order, practical reversal of asset transfers becomes more difficult.
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