Haoran Niu v. Schedule A Defendants: Default Judgment on Wrench Design Patent
Plaintiff Haoran Niu sued unnamed online marketplace sellers for infringing design patent D1,068,419, covering a wrench design. The Illinois Northern District Court entered a full default judgment — including a permanent injunction and statutory damages under 35 U.S.C. § 289 — after no defendant appeared, resolving the case in 241 days.
Schedule A design patent enforcement yields full default judgment
Haoran Niu filed suit on September 16, 2025 in the U.S. District Court for the Northern District of Illinois against an unspecified set of defendants identified on Schedule A — a common enforcement structure targeting anonymous online marketplace sellers. The asserted patent is design patent USD1,068,419 S (application no. US29/982873), which covers a wrench design. The defendants were alleged to be selling infringing products through domain names and online marketplace accounts identified on Schedule A, collectively described as the Defendant Internet Stores.
The case closed on May 15, 2026 via default judgment entered by Judge Mary M. Rowland. None of the defaulting defendants answered or appeared, and the time for answering expired, causing the complaint's allegations to be deemed admitted. The court granted the plaintiff's motion for entry of default and default judgment in its entirety, issuing a permanent injunction prohibiting further infringement across platforms including Amazon, eBay, Walmart, and Temu, and awarding statutory damages under 35 U.S.C. § 289. Third-party payment processors — including PayPal, Alipay, and Amazon Pay — were ordered to release restrained funds to the plaintiff within seven days.
The 241-day duration is consistent with Schedule A enforcement actions, which typically proceed swiftly when defendants fail to appear. The court found personal jurisdiction on the basis that defendants directly targeted U.S. consumers, including Illinois residents. The specific identity of defendants and the precise damages amounts per defendant are contained in Schedule A, which is not reproduced in the available public record.
See Complete Case & Patent Analysis →Filing to Default Judgment in 241 days
241 days from filing to default judgment — consistent with expedited Schedule A enforcement timelines
USD1,068,419 S — ornamental design for a wrench
Any company or individual selling wrench products — particularly through Amazon, eBay, Walmart, or Temu — should consider an FTO review against USD1,068,419 S. The permanent injunction entered in this case is broad and the order authorises supplemental enforcement proceedings against newly identified accounts. R&D and product teams developing or sourcing hand-tool designs for U.S. markets are exposed if their wrench products bear ornamental similarities to the patented design.
Official order — verbatim text
The default judgment order confirms the court's jurisdiction over anonymous marketplace defendants on the basis of targeted U.S. commerce, and enters relief under 35 U.S.C. § 289 without any merits contest. The operative mechanism is the defendants' failure to appear, which caused all infringement allegations to be deemed admitted. The order's multi-platform injunction and third-party fund-release provisions reflect standard Schedule A default judgment structure in the Northern District of Illinois.
Default judgment: what the court's order means for both parties
Default judgment entered after defendants failed to appear
A default judgment is entered when a defendant fails to respond or appear. The court treats the complaint's allegations as admitted and may award the relief requested. Here, Judge Rowland granted the full motion — permanent injunction plus statutory damages under 35 U.S.C. § 289. Defendants retain a 14-day window to oppose before the judgment is formally entered, per the order's terms.
No merits contestPermanent injunction and frozen funds released to plaintiff
Haoran Niu secured a permanent injunction restraining defendants and their affiliates from any further use of design patent USD1,068,419 S. Critically, third-party payment processors holding funds for defaulting defendants were ordered to release those amounts — up to the statutory damages award — to the plaintiff within seven days of the order, providing immediate monetary relief without a contested trial.
Injunction + damagesAccounts disabled, funds seized, listings enjoined across major platforms
Defaulting defendants face permanent injunctions across Amazon, eBay, Walmart, Temu, and other major platforms. Financial accounts connected to their seller aliases are permanently restrained up to the damages award. The order authorises the plaintiff to pursue supplemental proceedings if additional accounts are identified, creating ongoing enforcement risk for any defendant who continues operations under new aliases.
Platform-wide enforcementDesign patent enforcement via Schedule A: a growing e-commerce litigation model
Schedule A actions targeting anonymous marketplace sellers have become a prevalent enforcement mechanism for individual and small-entity design patent holders. This outcome demonstrates the coercive power of asset-freeze orders on payment processors combined with platform cooperation from Amazon, eBay, and Temu. Sellers operating across multiple marketplace accounts face simultaneous disruption, raising the risk profile for counterfeit and infringing product listings significantly.
E-commerce IP riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Haoran Niu | Individual | /Search in Eureka ↗ |
| Defendant | THE DEFENDANT IDENTIFIED ON SCHEDULE A | Individual | /Search in Eureka ↗ |
| Plaintiff counsel | Huicheng Zhou | Attorney | Counsel for Haoran NiuSearch in Eureka ↗ |
| Plaintiff counsel | Yifeng Hao | Attorney | Counsel for Haoran NiuSearch in Eureka ↗ |
| Plaintiff law firm | Alioth Law P.C. | Law Firm | Representing Haoran NiuSearch in Eureka ↗ |
| Presiding judge | Judge Mary M. Rowland | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
R&D signals in the hand-tool design patent space
Forward-looking patent intelligence derived from Haoran Niu v. Schedule A Defendants — covering wrench design IP, e-commerce enforcement trends, and competitive filing activity.
Haoran Niu's design patent filing activity in tool categories
Individual plaintiffs in Schedule A actions frequently hold multiple design patents across related product lines. Mapping Haoran Niu's USPTO filings can reveal whether additional wrench, hand-tool, or hardware accessory designs have been registered, signalling the breadth of potential future enforcement activity in this product category.
Portfolio mappingDesign patent filing trends for wrench and hand-tool ornamental designs
Design patent filings for hand tools — including wrenches, pliers, and screwdrivers — have increased alongside growth in e-commerce enforcement. Tracking filing trends in USPTO class D08 (hand tools) can identify emerging design thickets and high-risk ornamental features that product teams should differentiate from when developing new SKUs for U.S. marketplace distribution.
Filing trend analysisIP risk profile of anonymous Schedule A marketplace sellers
Defendants in Schedule A actions are typically overseas marketplace sellers with limited or no U.S. patent portfolios of their own. Their primary exposure is design patent infringement rather than counterassertion. Understanding which product categories attract Schedule A filings — and which platforms are most frequently cited — helps sourcing teams and marketplace operators calibrate vendor compliance requirements.
Seller IP riskAdjacent ornamental design space around wrench handle and jaw geometry
Design patent protection is limited to specific ornamental features. Adjacent design space — distinct handle profiles, jaw configurations, or surface texturing on wrenches — may remain clear of USD1,068,419 S's scope. An FTO and design-around analysis using visual patent search tools can identify differentiation pathways for tool manufacturers seeking to enter U.S. markets without infringement risk.
Design-around spaceSimilar design patent Schedule A cases in N.D. Illinois
Explore comparable Schedule A design patent enforcement actions in the Northern District of Illinois targeting online marketplace sellers of hand tools and hardware accessories.
What this case signals for the design patent enforcement landscape
This default judgment illustrates how design patent holders can achieve rapid, broad enforcement against anonymous e-commerce sellers without a contested merits hearing.
Payment processor freezes are the lever — monitor your seller accounts
The order compels PayPal, Amazon Pay, Alipay, and others to freeze and transfer funds within seven days. For marketplace sellers, this represents a near-instantaneous business disruption. Companies operating multi-storefront e-commerce strategies should assess their exposure to Schedule A-style design patent claims before a TRO is sought against them.
Design patent D1,068,419 S now carries a permanent injunction
Any seller currently listing a wrench product resembling the design covered by USD1,068,419 S faces the risk of being added to a supplemental Schedule A proceeding. The order explicitly authorises the plaintiff to pursue new accounts and domains. Conducting an FTO review against this patent is advisable for wrench and hand-tool manufacturers selling on U.S. marketplaces.
Niu v DEFENDANT — key questions answered
The Northern District of Illinois entered a default judgment in favour of plaintiff Haoran Niu on May 15, 2026. The court granted a permanent injunction against all defaulting defendants and awarded statutory damages under 35 U.S.C. § 289 for infringement of design patent USD1,068,419 S. No defendant appeared or answered the complaint.
The asserted patent is USD1,068,419 S (application no. US29/982873), a U.S. design patent covering the ornamental design of a wrench. Design patents protect the non-functional, visual appearance of an article of manufacture under 35 U.S.C. § 171.
The court awarded statutory damages under 35 U.S.C. § 289 from each defaulting defendant. The specific per-defendant amounts are set out in a schedule attached to the judgment. Third-party payment processors including PayPal, Amazon Pay, Alipay, and others were ordered to release restrained funds to the plaintiff within seven days of the order.
A Schedule A complaint names defendants by reference to a confidential schedule listing specific marketplace seller accounts, domain names, and associated financial accounts — rather than by individual name in the public caption. This structure is common in e-commerce design patent enforcement actions targeting multiple anonymous online sellers simultaneously, often accompanied by a TRO to freeze assets before defendants are notified.
Yes. The default judgment order directly instructs Amazon, eBay, Walmart, Temu, and other marketplace platforms to disable advertisements and listings for defaulting defendants. Payment processors are additionally ordered to freeze and transfer funds. The order also authorises the plaintiff to pursue supplemental proceedings against any new accounts identified as connected to the defaulting defendants.
This page is compiled from public court dockets and third-party patent and litigation data via PatSnap Eureka, and is provided for general informational purposes only. The information shown — including party names, patent and application numbers, dates, case status, outcomes, and any analysis — may be incomplete, may not reflect the most recent filings or legal status, and may contain errors or omissions. Verify all details against official court records (for example, PACER) and the relevant patent office before relying on them.
Nothing on this page constitutes legal advice or a legal opinion on the validity, infringement, enforceability, or scope of any patent or case, and no attorney‑client relationship is created by its use. Any description of an outcome (such as a dismissal, settlement, or consent judgment) is a general summary, not a legal determination. All patents, trademarks, and company or law‑firm names are the property of their respective owners. PatSnap makes no warranty as to the accuracy or completeness of this content and disclaims, to the fullest extent permitted by law, all liability for reliance on it. For advice on a specific matter, consult qualified legal counsel.
PatSnap Eureka searches patents and litigation data to answer instantly.