JJ Zhang v. Schedule A Defendants: Default Judgment on Fan Design Patent
JJ Zhang brought a design patent infringement action in the Northern District of Illinois against anonymous online marketplace sellers alleged to have copied a patented fan with light design. The court entered a default judgment — including a permanent injunction and disgorgement of profits under 35 U.S.C. § 289 — after defendants failed to appear, resolving the case in 161 days.
Online marketplace sellers defaulted on fan design patent infringement claim
On October 18, 2024, JJ Zhang filed suit in the U.S. District Court for the Northern District of Illinois against a group of unnamed partnerships and unincorporated associations — a filing structure commonly used in Schedule A counterfeit/infringement actions — alleging infringement of design patent USD1004815S, which covers the ornamental appearance of a fan with light (application number US29/857847). The defendants operated storefronts on online marketplaces including AliExpress, allegedly selling products bearing the protected design without authorisation.
Because the defendants never appeared or responded, Judge Sara L. Ellis granted Plaintiff’s Motion for Entry of Default and Default Judgment on March 28, 2025. The court issued a permanent injunction barring defendants from further use of the design patent in any product not authorised by Zhang, and awarded plaintiff the defendants’ profits under 35 U.S.C. § 289 — the design-patent-specific damages statute. Third-party providers, including AliExpress, were ordered to freeze and release restrained funds to plaintiff within fourteen calendar days.
The 161-day resolution is consistent with the accelerated trajectory typical of Schedule A default proceedings, where ex parte temporary restraining orders and asset freezes are sought early to prevent dissipation of funds. The public record does not disclose the aggregate damages figure beyond the per-defendant chart referenced in the order, nor whether full recovery was ultimately achieved from the restrained accounts. The use of § 289 profit disgorgement — rather than § 284 compensatory damages — is strategically significant and reflects the plaintiff’s election of the stronger design-patent remedy.
Filing to Default Judgment in 161 days
161-day resolution — faster than the typical N.D. Ill. IP default proceeding average
Default judgment entered: permanent injunction and § 289 profit disgorgement
Default judgment: what it means when defendants never appear
A default judgment under Fed. R. Civ. P. 55 is entered when a defendant fails to plead or otherwise defend. The court accepts the plaintiff’s well-pleaded allegations as true and fashions appropriate relief. Here, Judge Ellis granted both injunctive relief and monetary damages without a merits trial — a standard outcome in Schedule A infringement cases targeting unresponsive online sellers.
Fed. R. Civ. P. 55 — no merits contestZhang secures full injunction and disgorgement of infringer profits
JJ Zhang obtained a permanent injunction prohibiting any further sale, distribution, or advertisement of products bearing USD1004815S without authorisation. Critically, damages were awarded under 35 U.S.C. § 289, which entitles a design patent holder to the infringer’s total profits from the infringing article — a potentially higher recovery than lost profits or reasonable royalty under § 284. Restrained marketplace funds were ordered released directly to plaintiff.
§ 289 profit disgorgement — full article profitsDefendants face asset freezes, account shutdowns, and permanent ban
By failing to appear, defaulting defendants lost all opportunity to contest liability or limit damages. AliExpress and other third-party providers received direct court orders to freeze accounts, disable storefronts, and release funds within seven to fourteen days. Plaintiff retains ongoing authority to commence supplemental proceedings under Rule 69 to collect any shortfall, meaning enforcement exposure is not capped at the initial judgment.
Ongoing Rule 69 collection authoritySchedule A tactics create systemic risk for grey-market fan product sellers
This case illustrates how design patent holders can use Schedule A litigation in the Northern District of Illinois to obtain rapid asset freezes against anonymous online marketplace sellers. Any seller offering fan or lighting product designs on AliExpress, Amazon, or similar platforms without verifying design clearance faces a credible risk of account suspension and fund seizure before they can even respond. The § 289 total-profits measure amplifies financial exposure beyond typical royalty-based claims.
High asset-freeze risk for marketplace sellersFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | JJ Zhang | Individual | Design patent holder asserting ornamental rights in a fan with light product — USD1004815SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified on Schedule A | Individual | Anonymous online marketplace sellers on AliExpress and related platforms identified on Schedule ASearch in Eureka ↗ |
| Plaintiff counsel | Faye Yifei Deng | Attorney | Counsel for JJ ZhangSearch in Eureka ↗ |
| Plaintiff law firm | YK Law LLP | Law Firm | Representing JJ ZhangSearch in Eureka ↗ |
| Presiding judge | Judge Sara L. Ellis | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order is comprehensive in scope: it combines a permanent injunction, § 289 profit disgorgement, third-party platform obligations, and ongoing Rule 69 collection authority. Because the judgment was entered by default, no invalidity or non-infringement defences were adjudicated. The order’s direct reach to AliExpress as a third-party provider — compelling fund release within fourteen days — reflects the court’s willingness to treat marketplace operators as enforceable parties with actual notice, a recurring feature of N.D. Ill. Schedule A orders.
USD1004815S — Ornamental Design for a Fan with Light
USD1004815S is a U.S. design patent covering the ornamental appearance of a fan with light — a consumer product combining ceiling or portable fan functionality with an integrated lighting element. Filed under application number US29/857847, the patent protects the specific visual characteristics of the article, not its functional features. Design patents in this category are increasingly used to protect product aesthetics against low-cost overseas copycats selling through online marketplaces.
The commercial significance of USD1004815S lies in its applicability to a high-volume consumer goods category where visual differentiation is a key purchase driver. Fan-with-light products are widely manufactured in China and sold through cross-border e-commerce channels, making them a frequent target of both design copying and Schedule A enforcement campaigns. Competitors and OEM sourcing teams should treat this patent as a live enforcement risk, particularly given that the § 289 remedy exposes the entire article’s revenue — not just a royalty slice.
Should you run an FTO analysis against USD1004815S?
Any company designing, importing, or reselling fan products with integrated lighting should assess whether their product’s ornamental appearance falls within the scope of USD1004815S. This is especially urgent for sellers operating on AliExpress, Amazon, or similar platforms, which have already received direct court orders in this case. Even products that differ functionally may infringe if their visual design is substantially similar to the patented design under the ordinary observer test.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD1004815S against your product designs, surface prior art that may limit enforceability, and identify related design patent families filed by the same applicant. Eureka’s portfolio monitoring tools can also flag new Schedule A filings in N.D. Ill. that may target your product category — enabling proactive risk management before account freezes are sought.
Run a freedom-to-operate analysis on USD1004815S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois
Browse comparable Schedule A design patent enforcement actions filed in the Northern District of Illinois involving consumer product ornamental designs and online marketplace defendants.
What this case signals for the consumer fan and lighting design IP landscape
Schedule A default judgments are a fast-moving enforcement tool — understanding the pattern protects both IP holders and marketplace sellers.
Design patent holders can freeze marketplace funds before defendants respond
The Schedule A litigation model — filed under seal, paired with a TRO and asset freeze — allows plaintiffs to restrain online seller accounts within days of filing. Sellers and platform operators in the fan and consumer electronics space should monitor for sealed filings against Schedule A defendants in N.D. Ill. as an early warning signal.
§ 289 profit disgorgement makes design patents disproportionately powerful offensively
Unlike utility patent damages, 35 U.S.C. § 289 awards the infringer’s total profits from the entire infringing article — not an apportioned royalty. For low-cost, high-volume consumer goods like fans, this can represent the full sale price per unit. Any company sourcing or reselling fan or lighting products should conduct design patent clearance before launch.
Zhang v Partnerships — key questions answered
The Northern District of Illinois entered a default judgment in favour of plaintiff JJ Zhang on March 28, 2025. The court issued a permanent injunction against all defaulting defendants and awarded plaintiff the defendants’ profits under 35 U.S.C. § 289 for infringement of design patent USD1004815S covering a fan with light.
Section 289 entitles a design patent holder to the infringer’s total profits from the sale of any article to which the patented design has been applied. Unlike utility patent damages, § 289 does not require apportionment — the entire article’s profit is potentially recoverable. This makes design patent assertions against low-margin, high-volume consumer goods particularly potent.
Schedule A defendants are unnamed individuals or entities — typically online marketplace sellers — listed on an exhibit filed under seal at the outset of litigation. This approach is common in N.D. Ill. and allows plaintiffs to obtain TROs and asset freezes before defendants can dissipate funds or close their storefronts. Identities are later disclosed through third-party discovery from platforms like AliExpress or Amazon.
The case was filed in and decided by the U.S. District Court for the Northern District of Illinois. Judge Sara L. Ellis presided over the matter. Plaintiff was represented by attorney Faye Yifei Deng of YK Law LLP.
The patent at issue is USD1004815S, a U.S. design patent filed under application number US29/857847. It covers the ornamental design of a fan with light — a consumer product combining fan and integrated lighting functionality. Design patents protect visual appearance, not functional features, and are enforceable against products that appear substantially similar to the patented design under the ordinary observer standard.
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