Jin Li v. Schedule A Defendants: Default Judgment Win on Lid Design Patent
Patent holder Jin Li sued anonymous online marketplace sellers for infringing USD972364S, a design patent covering a lid. The defendants never appeared, and Judge Tharp entered a default judgment within 73 days — granting a permanent injunction and ordering profits transferred from PayPal, Alibaba, Amazon Pay, and other platforms directly to Jin Li.
Fast default judgment in online marketplace lid design patent dispute
Jin Li filed suit on November 13, 2023 in the U.S. District Court for the Northern District of Illinois against a group of anonymous sellers — listed only as ‘The Partnership and Unincorporated Associations Identified on Schedule A’ — alleging infringement of design patent USD972364S (application no. 29/792,897), which protects the ornamental design of a lid. The defendants operated through online marketplace accounts on platforms including Amazon, eBay, AliExpress, Alibaba, Wish.com, and DHgate.
None of the named defendants answered or appeared. Chief Judge John J. Tharp entered a preliminary injunction early in the proceedings and, on January 25, 2024, granted Jin Li’s motion for default and default judgment. The court ordered a permanent injunction barring defendants from selling, importing, or aiding the sale of infringing lid products, and directed third-party payment processors — including PayPal, Alipay, Alibaba, Ant Financial, and Amazon Pay — to freeze and transfer restrained funds to Jin Li as partial satisfaction of damages.
The case closed in 73 days, consistent with the accelerated pace typical of Schedule A design patent enforcement actions where defendants are non-responsive. The public record does not disclose the aggregate damages figure, as individual awards are detailed on the non-public Schedule B. What drove the swift resolution was structural: service by electronic publication and email, combined with payment processor notices, was deemed sufficient, and the defendants’ silence meant all complaint allegations were deemed admitted.
Filing to settlement in 73 days
73 days — faster than most Schedule A default proceedings
Default judgment granted: permanent injunction and profit disgorgement ordered
What a default judgment means in this context
A default judgment is entered when a defendant fails to answer or appear. Here, the court deemed all of Jin Li’s allegations admitted by operation of law. This means infringement was not contested on the merits — the judgment reflects the defendants’ silence, not a judicial finding after contested litigation. The result is nonetheless legally binding and enforceable.
Default — no merits contestPermanent injunction covers platforms and future accounts
The injunction extends beyond the specific accounts named to any future online marketplace accounts used by the defendants to sell infringing goods. Third-party platforms including Amazon, eBay, AliExpress, and Wish.com were ordered to disable accounts and cease displaying associated advertisements within seven days of notice. This broad drafting is standard in Schedule A cases to prevent account-hopping.
Platform-wide enforcementFrozen funds released directly to plaintiff under 35 U.S.C. § 284
Rather than waiting for defendants to pay, the court ordered payment processors — PayPal, Alipay, Alibaba, Ant Financial, and Amazon Pay — to release already-restrained funds to Jin Li within 14 days. Individual damages figures are set out in the non-public Schedule B. Jin Li retains supplemental enforcement authority under FRCP 69 until damages are fully satisfied.
Profits disgorgement via processorsElectronic service deemed sufficient for anonymous defendants
The court accepted service by electronic publication and email as reasonably calculated to apprise defendants of the action — a well-established approach in Schedule A cases where defendants’ physical addresses are unknown or unverifiable. Payment processor notices served as a secondary notification channel. This approach is consistent with how Northern District of Illinois handles offshore e-commerce infringers.
E-service approvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | John Doe | Company | Design patent holder pursuing online marketplace infringers — holder of USD972364SSearch in Eureka ↗ |
| Defendant | The Partnership and Unincorporated Associations Identified On Schedule A | Company | Anonymous online marketplace sellers identified only on Schedule A filingSearch in Eureka ↗ |
| Plaintiff counsel | Pete Scott Wolfgram | Attorney | Counsel for John DoeSearch in Eureka ↗ |
| Plaintiff counsel | Xiyan Zhang | Attorney | Counsel for John DoeSearch in Eureka ↗ |
| Presiding judge | Judge John J. Tharp | Chief Judge | Illinois Northern District Court — Chief JudgeSearch in Eureka ↗ |
Stipulation of dismissal — official text
The default judgment was entered on the basis that defendants admitted all allegations by failing to appear — not following a contested hearing on infringement merits. The permanent injunction is drafted broadly, covering future accounts and downstream platforms. The damages award (per Schedule B) is structured as a disgorgement of profits under 35 U.S.C. § 284, enforced directly against payment processors. Jin Li retains FRCP 69 supplemental enforcement rights, meaning the judgment remains active until fully satisfied.
USD972364S — ornamental design for a lid
USD972364S (filed under application number 29/792,897) is a U.S. design patent protecting the ornamental appearance of a lid. Design patents protect how a product looks — its shape, configuration, and surface ornamentation — rather than its functional features. Infringement occurs when an ordinary observer would find the accused design substantially similar to the patented design. The patent was asserted against multiple online marketplace sellers in a single coordinated enforcement action.
In the consumer goods and kitchenware accessories market, lid designs are frequently replicated by offshore manufacturers selling through e-commerce platforms. A registered design patent gives the holder a structural enforcement advantage: it enables platform-level takedowns, payment processor freezes, and injunctive relief without requiring proof of intent. The USD972364S enforcement action suggests the patent holder views this design as commercially significant and is prepared to defend it systematically.
Should you run an FTO analysis against USD972364S?
Any company designing, sourcing, or selling lid products — particularly through Amazon, eBay, AliExpress, or similar platforms — should assess their exposure to USD972364S. The broad permanent injunction entered in this case, which explicitly covers future accounts and downstream platform actions, means that sellers who enter the market without an FTO analysis risk being swept into a supplemental enforcement proceeding even after initial judgment.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD972364S against your product designs, identify prior art that may limit enforcement reach, and flag related design patent families held by the same applicant. Claim monitoring alerts can notify your team if Jin Li or related entities file new design applications in adjacent product categories, giving you early warning before enforcement action is initiated.
Run a freedom-to-operate analysis on USD0972364S to assess your product’s exposure
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What this case signals for the online marketplace design patent space
Schedule A enforcement actions are a systematic tool for design patent holders targeting e-commerce infringers. This case illustrates the playbook.
Design patents are potent weapons against e-commerce counterfeiters
USD972364S shows how a single design patent, once registered, can anchor a multi-defendant enforcement action across major platforms simultaneously. The default judgment mechanism means that if defendants don’t appear — common with offshore sellers — the patent holder wins without a merits trial. Registration and readiness to file are the key investment.
Payment processor freezes make default judgments immediately enforceable
The order compelling PayPal, Alipay, Amazon Pay, and Ant Financial to release funds converts a judgment against unreachable defendants into actual recovery. Companies facing similar infringement should consider whether their design IP is registered and whether their counsel has the infrastructure to pursue Schedule A-style enforcement at speed.
John v The — key questions answered
Jin Li won a default judgment on January 25, 2024. Chief Judge John J. Tharp granted a permanent injunction against all non-dismissed defendants and ordered payment processors including PayPal, Alipay, Alibaba, and Amazon Pay to release restrained funds to Jin Li as damages under 35 U.S.C. § 284.
The asserted patent was USD972364S (application no. 29/792,897), a U.S. design patent protecting the ornamental design of a lid product. Design patents protect visual appearance, not function. Infringement is assessed using the ordinary observer test.
The court accepted service by electronic publication and email as sufficient for anonymous Schedule A defendants whose physical addresses were unavailable. Payment processor notifications provided a secondary channel. This approach is well-established in the Northern District of Illinois for offshore e-commerce infringement cases.
A Schedule A case is an enforcement strategy where a plaintiff sues multiple anonymous online marketplace defendants simultaneously, listing them on a confidential exhibit rather than in the caption. This structure is common for design patent enforcement against offshore e-commerce sellers. Courts in the Northern District of Illinois have developed streamlined procedures for these cases.
The permanent injunction named Amazon, eBay, AliExpress, Alibaba, Wish.com, and DHgate as platforms. Payment processors PayPal, Alipay, Alibaba, Ant Financial, and Amazon Pay were ordered to freeze and release funds. The injunction also extends to any future accounts opened by the defendants.
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