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Junjie Peng v. Schedule A Defendants — Wireless Sports Headband Design Patent | PatSnap
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Case ID1:23-cv-06846
FiledSep 2023
ClosedFeb 2024
Patent Litigation

Junjie Peng v. Schedule A Defendants — Default Judgment on Wireless Sports Headband Design Patent

Individual inventor Junjie Peng sued ten e-commerce sellers across Amazon and other online marketplaces for infringing U.S. Design Patent D870,062, covering a wireless sports headband. None of the defaulting defendants responded, and Judge Bucklo entered default judgment in 153 days, awarding $8,393.52 in damages and a permanent injunction against all infringing stores.

Resolution time
153days
153 days from filing to default judgment — a swift resolution consistent with uncontested Schedule A enforcement actions
Patents asserted
1
USD0870062S — wireless sports headband ornamental design patent
Outcome
Default Judgment
Plaintiff won — five defaulting defendants permanently enjoined and ordered to pay $8,393.52
Cost ruling
Damages Awarded
$8,393.52 total — drawn from frozen marketplace and payment processor accounts
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Swift default judgment in Illinois e-commerce design patent enforcement

On September 1, 2023, individual inventor Junjie Peng filed suit in the Northern District of Illinois against a group of online sellers operating under the umbrella ‘Partnerships and Unincorporated Associations Identified on Schedule A.’ The complaint alleged that ten marketplace storefronts — including NIRUSAR-US, Yukaaa Direct, and Shenglan Rizhao — were selling wireless sports headbands that infringed U.S. Design Patent No. D870,062. The defendants operated primarily through Amazon seller accounts, with seller IDs documented in the judgment.

Five of the named defendants — shenglan rizhao, NIRUSAR-US, qianlinfeng, Yukaaa Direct, and jiaxuli1r — failed to answer or appear. Judge Elaine E. Bucklo granted Plaintiff’s motion for entry of default and default judgment on February 1, 2024, under 35 U.S.C. §§ 271, 284, and 289. The court awarded $8,393.52 in damages calculated from frozen gross revenues and admitted profits, and issued a permanent injunction barring the defaulting defendants from manufacturing, importing, selling, or distributing the infringing products.

The case resolved in 153 days — consistent with the accelerated timeline typical of Schedule A enforcement actions where defendants do not contest. The court’s jurisdiction finding rested on evidence that each defendant store offered shipping to Illinois residents and had made infringing sales there. Five defendants named on Schedule A are not referenced in the default judgment, suggesting their status may have been resolved separately through dismissal, settlement, or other means not reflected in the public default judgment order. That aspect of the record remains unclear from the publicly available docket.

Case at a glance
Case no.1:23-cv-06846
PlaintiffJunjie Peng
CourtIllinois Northern
JudgeElaine E. Bucklo
FiledSeptember 1, 2023
ClosedFebruary 1, 2024
Duration153 days
OutcomeDefault Judgment
Verdict causeInfringement Action
BasisDefault Judgment
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Case data sourced from PACER / Illinois Northern District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to settlement in 153 days

153 days from filing to default judgment — a swift resolution consistent with uncontested Schedule A enforcement actions

Case timeline: Complaint filed May 13 2025, NOV–DEC — 153 days total Horizontal timeline showing the three key events in Junjie Peng v Partnerships and Unincorporated Associations Identified on Schedule A from filing to voluntary dismissal. Source: PACER, Illinois Northern District Court. SEP 1 2023 Complaint filed NOV–DEC 2023 Pre-trial proceedings FEB 1 2024 Resolved consent judgment 153 DAYS TOTAL
Court ruling

Default Judgment: permanent injunction and $8,393.52 in design patent damages

Legal mechanism

What is a default judgment in patent litigation?

A default judgment is entered when a defendant fails to respond to a complaint within the required time. The court deems all well-pleaded allegations admitted and may grant the plaintiff’s requested relief. Here, five defendants never appeared, so Judge Bucklo treated Peng’s infringement allegations as uncontroverted and granted both damages and a permanent injunction without a trial on the merits.

No defense mounted
Damages basis

How were the $8,393.52 damages calculated?

Under 35 U.S.C. §§ 284 and 289, a design patent holder may recover the infringer’s total profit from the infringing article. The court used frozen gross revenues and admitted profits per store: NIRUSAR-US contributed the largest share ($4,165.64 from $20,828.19 gross), while shenglan rizhao’s award of $1,965.05 was based on admitted profits despite no gross revenue figure being documented. Frozen funds held by Amazon Pay and other processors were ordered released directly to Peng.

§ 289 total profits remedy
Injunction scope

Permanent injunction binds platforms, not just sellers

The injunction extends beyond the defendants themselves to any third-party service providers with notice — including Amazon, eBay, AliExpress, Alibaba, Wish.com, and Dhgate. These platforms were ordered to disable accounts and cease displaying infringing listings within seven calendar days. This platform-binding mechanism is a signature feature of Schedule A litigation and gives the injunction real practical reach even against sellers with no U.S. presence.

Platform takedown order
Schedule A litigation pattern

Why the N.D. Illinois is a hub for this enforcement model

The Northern District of Illinois has become a preferred venue for Schedule A design patent and trademark enforcement actions against overseas e-commerce sellers. Courts there have repeatedly accepted jurisdiction based on evidence that defendant storefronts offer shipping to Illinois. The model — mass filing, TRO to freeze assets, service by email, default judgment — allows individual rights-holders to enforce design patents at scale against non-appearing defendants with frozen funds funding the damage award.

Established enforcement model
Legal analysis based on PACER docket records for case 1:23-cv-06846 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffJunjie PengCompanyIndividual inventor and IP enforcer — holder of U.S. Design Patent D870,062Search in Eureka ↗
DefendantPartnerships and Unincorporated Associations Identified on Schedule ACompanyTen Amazon and online marketplace sellers of wireless sports headbands, operating under Schedule A aliasesSearch in Eureka ↗
Plaintiff counselDavid Randolph BennettAttorneyCounsel for Junjie PengSearch in Eureka ↗
Plaintiff counselSteven G. KalbergAttorneyCounsel for Junjie PengSearch in Eureka ↗
Plaintiff counselStevenson MooreAttorneyCounsel for Junjie PengSearch in Eureka ↗
Plaintiff counselTong JinAttorneyCounsel for Junjie PengSearch in Eureka ↗
Presiding judgeJudge Elaine E. BuckloChief JudgeIllinois Northern District Court — Chief JudgeSearch in Eureka ↗
Official verdict

Stipulation of dismissal — official text

“This action having been commenced by Plaintiff Junjie Peng (“Plaintiff”) against the Defendants identified on Schedule A, and using the Defendant Domain Names and Online Marketplace Accounts identified on Schedule A, and Plaintiff having moved for entry of Default and Default Judgment against Defendants shenglan rizhao, NIRUSAR-US, qianlinfeng, Yukaaa Direct, and jiaxuli1r (collectively, “Defaulting Defendants”); This Court having entered a preliminary injunction; Plaintiff having properly completed service of process on Defaulting Defendants, the combination of providing notice via electronic publication and e-mail, along with any notice that Defaulting Defendants received from domain name registrars and payment processors, being notice reasonably calculated under all circumstances to apprise Defaulting Defendants of the pendency of the action and affording them the opportunity to answer and present their objections; and None of the Defaulting Defendants having answered or appeared in any way, and the time for answering having expired, so that the allegations of the Complaint are uncontroverted and are deemed admitted; Case: 1:23-cv-06846 Document #: 37 Filed: 02/01/24 Page 1 of 5 PageID #:517 2 This Court finds that it has personal jurisdiction over Defaulting Defendants because Defaulting Defendants directly target their business activities toward consumers in the United States, including Illinois. Specifically, Plaintiff has provided a basis to conclude that Defaulting Defendants have targeted sales to Illinois residents by setting up and operating e- commerce stores that target United States consumers using one or more seller aliases, offer shipping to the United States, including Illinois, and have sold products that infringe Plaintiff’s patented design, U.S. Patent No. D870,062 (“D’062 Patent”) to residents of Illinois. In this case, Plaintiff has presented evidence that each Defendant e-commerce store is reaching out to do business with Illinois residents by operating one or more commercial, interactive internet stores through which Illinois residents can and do purchase products infringing the D’062 Patent. See Docket No. 4-2 (screenshot evidence confirming that each Defendant e-commerce store does stand ready, willing and able to ship its infringing goods to customers in Illinois). This Court further finds that Defaulting Defendants are liable for design patent infringement pursuant to 35 U.S.C. § 271. Accordingly, this Court orders that Plaintiff’s Motion for Entry of Default and Default Judgment is GRANTED as follows, that Defaulting Defendants are deemed in default, and that this Default Judgment is entered against Defaulting Defendants. This Court further orders that: 1. Defaulting Defendants, their officers, agents, servants, employees, attorneys, and all persons acting for, with, by, through, under, or in active concert with them be permanently enjoined and restrained from: a. manufacturing, importing, distributing, offering for sale, or selling any infringing products, i.e., the wireless sports headband as identified in the Complaint and any Case: 1:23-cv-06846 Document #: 37 Filed: 02/01/24 Page 2 of 5 PageID #:518 3 colorable variations thereof (“Infringing Products”); b. further infringing the D’062 Patent and damaging Plaintiff’s intellectual property rights; c. otherwise competing unfairly with Plaintiff in any manner; d. manufacturing, shipping, delivering, holding for sale, transferring or otherwise moving, storing, distributing, returning, or otherwise disposing of, in any manner, the Infringing Products; e. using, linking to, transferring, selling, exercising control over, or otherwise owning the Online Marketplace Accounts or any other online marketplace account that is being used to sell or is the means by which Defendants could continue to sell the Infringing Products; and f. operating and/or hosting any website or marketplace account for or on behalf of Defendants that are involved with the distribution, marketing, advertising, offering for sale, or sale of the Infringing Products. 2. Defaulting Defendants and any third parties with actual notice of this Order who are providing services for any of the Defaulting Defendants, or in connection with any of the Defaulting Defendants’ Online Marketplaces, including, without limitation, any online marketplace platforms such as eBay, Inc., AliExpress, Alibaba Group Holding Ltd. (“Alibaba”), Amazon.com, ContextLogic, Inc. d/b/a Wish.com and Dhgate (collectively, Third Party Providers”), shall within seven (7) calendar days of receipt of this Order cease: a. using, linking to, transferring, selling, exercising control over, or otherwise owning the Online Marketplace Accounts, or any other online marketplace account that is being used to sell or is the means by which Defaulting Defendants could continue to sell infringing goods; and Case: 1:23-cv-06846 Document #: 37 Filed: 02/01/24 Page 3 of 5 PageID #:519 4 b. operating and/or hosting websites that are involved with the distribution, marketing, advertising, offering for sale, or sale of any Infringing Products. 3. Upon Plaintiff’s request, those with notice of this Order, including the Third Party Providers as defined in Paragraph 4, shall within seven (7) calendar days after receipt of such notice, disable and cease displaying any advertisements used by or associated with Defaulting Defendants in connection with the sale of Infringing Products. 4. Pursuant to 35 U.S.C. §§ 284 and 289, Plaintiff is awarded damages from each of the Defaulting Defendants in the amount detailed below, totaling $8,393.52, for design patent infringement on products sold through at least the Defendant Internet Stores. This award shall apply to each distinct Defaulting Defendant only once, even if they are listed under multiple different aliases in the Complaint and Schedule A. Store Name ID Gross Revenue Frozen/Admitted Profits jiaxuli1r A2CT4J4LFDMSNJ $ 664.16 $ 203.11 NIRUSAR-US A3JAWF3IGECYXH $ 20,828.19 $ 4,165.64 qianlinfeng A3L05JFUP4YKMJ $ 4,675.39 $ 935.1 shenglan rizhao ATCBRF3MOO3D6 $ – $ 1965.05 Yukaaa Direct A32ECETV6EXB95 $ 851.09 $ 1,124.62 $ 27,018.83 $ 8,393.52 5. Any Third Party Providers holding funds for Defaulting Defendants, including PayPal, Inc. (“PayPal”), Alipay, Alibaba, Wish.com, Ant Financial Services Group (“Ant Financial”), and Amazon Pay, shall, within seven (7) calendar days of receipt of this Order, permanently restrain and enjoin any accounts connected to Defaulting Defendants or the Defendant Internet Stores from transferring or disposing of any funds (up to the damages awarded in Paragraph 4 above) or other of Defaulting Defendants’ assets. Case: 1:23-cv-06846 Document #: 37 Filed: 02/01/24 Page 4 of 5 PageID #:520 5 6. All monies (up to the amount of the damages awarded in Paragraph 4 above) currently restrained in Defaulting Defendants’ financial accounts, including monies held by Third Party Providers such as PayPal, Alipay, Alibaba, Wish.com, Ant Financial, and Amazon Pay, are hereby released to Plaintiff as partial payment of the above-identified damages, and Third Party Providers, including PayPal, Alipay, Alibaba, Wish.com, Ant Financial, and Amazon Pay, are ordered to release to Plaintiff the amounts from Defaulting Defendants’ financial accounts within fourteen (14) calendar days of receipt of this Order. 7. Until Plaintiff has recovered full payment of monies owed to it by any Defaulting Defendant, Plaintiff shall have the ongoing authority to commence supplemental proceedings under Federal Rule of Civil Procedure 69. 8. In the event that Plaintiff identifies any additional online marketplace accounts or financial accounts owned by Defaulting Defendants, Plaintiff may send notice of any supplemental proceeding, including a citation to discover assets, to Defaulting Defendants by e-mail at the e-mail addresses provided for Defaulting Defendants by third parties. 9. The clerk of the court is ordered to release the bond previously posted in this action to Plaintiff’s counsel, as this Default Judgement Order supersedes the Preliminary Injunction entered in this case. This is a Default Judgment.”
Source: PACER Docket, Case 1:23-cv-06846, Illinois Northern District Court · Filed February 1, 2024

The default judgment establishes liability without contest — the court’s finding of infringement under 35 U.S.C. § 271 is binding on the five named defaulting defendants but has no precedential weight as to claim scope or validity. The damage figure of $8,393.52, drawn from frozen account balances, reflects actual recovered profits rather than a litigated damages award. The permanent injunction’s extension to third-party platforms — with seven-day compliance windows — is the judgment’s most practically significant element, as it operationalises enforcement through Amazon and other marketplaces independent of any further defendant action.

PACER case 1:23-cv-06846 · Public docket record Explore in Eureka ↗
Patent at issue

USD0870062S — Wireless Sports Headband Ornamental Design

Publication No.USD0870062S
Application No.US29/697304
Patent details
AssigneeJunjie Peng
ProductU.S. Design Patent D870,062 — wireless sports headband ornamental design
Publication typeB2 — grant (with prior publication)
Cited in actionSeptember 1, 2023

U.S. Design Patent No. D870,062 (application No. 29/697,304) protects the ornamental design of a wireless sports headband as shown and described in the patent drawings. As a design patent, it covers the specific visual appearance of the product — shape, contour, and overall aesthetic — rather than any functional or technical attribute. Design patents typically grant for 15 years from issuance and are evaluated for infringement using the ‘ordinary observer’ test: would an ordinary purchaser mistake the accused product for the patented design?

In the fast-moving consumer wearables category, design patents over sports headbands and wireless audio accessories have become significant enforcement tools, particularly against overseas marketplace sellers who may copy product aesthetics without licensing. The D870,062 patent’s assertion against ten separate Amazon storefronts in a single action illustrates how a single design registration can generate broad enforcement reach when combined with the Schedule A litigation model. Any company sourcing or selling wireless headband products — especially through Amazon — should treat this patent as an active enforcement risk.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should your product team run an FTO against USD0870062S?

If your company designs, sources, or distributes wireless sports headbands or closely related wearable audio accessories through Amazon, eBay, AliExpress, or comparable platforms, U.S. Design Patent D870,062 represents a live enforcement risk. This case demonstrates that the patent holder is actively monitoring marketplace listings and prepared to seek asset freezes and default judgments. An FTO analysis should compare your product’s ornamental appearance against the D870,062 drawings using the ordinary observer standard — not a technical claim-by-claim analysis.

PatSnap Eureka’s FTO Search Agent allows product and IP teams to run rapid design patent clearance searches across U.S. design patent databases, flagging visually similar registered designs and active enforcement histories. Claim monitoring alerts can notify your team if new Schedule A actions are filed referencing D870,062 or related design patents, giving you lead time to adjust product aesthetics or seek counsel before account freezes are sought.

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Related litigation

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PatSnap Eureka tracks related litigation across truck body equipment, vehicle accessories, and comparable infringement actions in the Georgia district system.

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Strategic implications

What this case signals for the e-commerce design patent enforcement landscape

Schedule A default judgments are reshaping how individual inventors enforce design patents against overseas marketplace sellers.

Asset freezing before judgment is the enforcement model’s core lever

The court’s preliminary injunction froze marketplace accounts and payment processor balances before any judgment was entered. By the time default judgment issued, frozen funds were simply redirected to the plaintiff. Companies selling through Amazon or similar platforms should assess whether their products face design patent exposure before funds are frozen — post-freeze, the practical ability to defend is severely constrained.

Design patent D870,062 covers ornamental appearance, not function

U.S. Design Patent D870,062 protects the specific ornamental design of Peng’s wireless sports headband, not its underlying technology. Competitors can sell functionally similar headbands provided the visual appearance diverges sufficiently from the patented design. An FTO analysis focusing on ornamental similarity — not technical specifications — is the appropriate risk-screening tool for this product category.

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Frequently asked questions

Junjie v Partnerships — key questions answered

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PatSnap Eureka’s FTO Search Agent screens your product designs against active U.S. design patents including D870,062. Set up claim monitoring alerts to track new Schedule A filings before account freezes are sought against your storefronts.

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