Book a demo

Cut patent&paper research from weeks to hours with PatSnap Eureka AI!

Try now
Kids Squad v. Guangzhou Hui De — Bath Toy Patent Infringement | PatSnap
Explore in Eureka
Case ID1:23-cv-07764
FiledAug 2023
ClosedSep 2024
Patent Litigation

Kids Squad v. Guangzhou Hui De: Default Judgment for Willful Bath Toy Patent Infringement

Kids Squad LLC secured a default judgment in the Southern District of New York against four Chinese Amazon marketplace sellers accused of willfully infringing US Patent No. 11,684,863 covering a bath toy product. The court trebled damages to $62,720.67 and awarded $25,550 in attorneys’ fees after finding the infringement willful, egregious, and exceptional.

Resolution time
391days
391 days — faster than the SDNY median for patent default proceedings, suggesting efficient case management
Patents asserted
1
US11684863B1 — Bath Toy Product; novel children’s bath toy design and function
Outcome
Default Judgment
Plaintiff prevailed; defendants never appeared; willful infringement found warranting trebled damages
Cost ruling
Fees Awarded
$25,550 attorneys’ fees plus $402 costs; case deemed ‘exceptional’ under 35 U.S.C. § 285
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Amazon Storefront Enforcement: SDNY Default Judgment Targets Chinese Sellers

On August 31, 2023, Kids Squad, LLC filed suit in the U.S. District Court for the Southern District of New York against four Chinese e-commerce entities — Guangzhou Hui De E-Trade Co., Ltd., Guangzhou Yikong Electronic Commerce Co., Ltd., Shenzhen Hongquan International Co., Ltd., and Shenzhen Shi Yanwu Zhineng Jiaju Youxian Gongsi Ltd. — alleging patent infringement of U.S. Patent No. 11,684,863 through the sale of bath toy products via Amazon storefronts targeting U.S. consumers.

The case closed on September 25, 2024, with Judge Katherine Polk Failla granting a default judgment against two of the named defendants — Guangzhou Hui De and Guangzhou Yikong — after they failed to answer or appear. The court found willful, egregious infringement of at least Claim 1 of the ‘863 Patent, trebled the proven lost profits of $20,906.89 to $62,720.67 under 35 U.S.C. § 284, and imposed permanent injunctions against all infringing activity and Amazon account usage.

The 391-day duration reflects a relatively streamlined path to judgment, consistent with cases where defendants default rather than contest. The absence of any defendant appearance or counsel on record suggests the Chinese sellers either could not be meaningfully reached or chose not to engage U.S. litigation. The public record does not disclose whether any restrained Amazon funds were sufficient to satisfy the full judgment, nor the final disposition as to the two non-defaulting defendants.

Case at a glance
Case no.1:23-cv-07764
CourtNew York Southern
JudgeKatherine Polk Failla
FiledAugust 31, 2023
ClosedSeptember 25, 2024
Duration391 days
OutcomeDefault Judgment
Verdict causeInfringement Action
BasisDefault Judgment
Prior Art Intelligence
See what prior art exists on this patent.
Eureka scans millions of patents and papers to surface prior art that may have invalidated these claims before costly litigation begins.
Check Prior Art
Case data sourced from PACER / New York Southern District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to Default Judgment in 391 days

391 days — faster than the SDNY median for patent default proceedings, suggesting efficient case management

Case timeline: Complaint filed AUG 31 2023, MAR–APR — 391 days total Horizontal timeline showing the three key events in Kids Squad, LLC v Guangzhou Hui De E-Trade Co., Ltd. from filing to resolution. Source: PACER, New York Southern District Court. AUG 31 2023 Complaint filed Pre-trial proceedings SEP 25 2024 Default Judgment 391 DAYS TOTAL
Default judgment

Default judgment entered: what the ruling means for both parties

Legal mechanism

Default judgment: liability by non-appearance

A default judgment is entered when a defendant fails to respond or appear. Here, the court accepted the plaintiff’s well-pleaded allegations as true, found willful infringement of at least Claim 1 of US11684863, and granted all requested relief. This is not a merits adjudication following adversarial proceedings — but the permanent injunction and damages order carry full legal force against the defaulting defendants and those in privity with them, including Amazon.

Liability by non-appearance
Patent holder outcome

Kids Squad wins trebled damages and permanent injunction

Kids Squad obtained everything it sought: trebled damages of $62,720.67, $25,550 in attorneys’ fees, $402 in costs, 8.25% statutory interest, and a permanent injunction blocking all infringing sales, Amazon storefront operation, and advertising. Amazon and PayPal were ordered to freeze and release restrained funds within two business days. The ‘863 Patent’s enforceability is uncontested on the record — strengthening Kids Squad’s position in any future enforcement actions.

Full relief granted
Defendant outcome

Amazon accounts disabled; assets frozen and released to plaintiff

The defaulting defendants — Guangzhou Hui De and Guangzhou Yikong — face a permanent injunction, frozen financial accounts, and mandatory fund release to Kids Squad. Amazon was directed to disable associated storefronts and prevent links from appearing in search results within three business days. Because the defendants never appeared, they have limited grounds to challenge enforcement absent a successful motion to vacate the default, which requires showing good cause under Fed. R. Civ. P. 55(c).

Storefronts disabled
Commercial implications

Cross-border Amazon enforcement precedent for consumer product IP

This case illustrates the SDNY’s willingness to exercise jurisdiction over Chinese Amazon sellers based solely on U.S.-directed sales, authorize electronic service, and impose treble damages plus fee-shifting where defendants default. For patent holders in the children’s products and consumer goods space, it reinforces the viability of Amazon-targeted enforcement strategies. For sellers on U.S. marketplaces, it signals that non-appearance does not insulate against significant financial and operational consequences.

Amazon enforcement signal
Legal analysis based on PACER docket records for case 1:23-cv-07764 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffKids Squad, LLCCompanyChildren’s consumer products company — holder of US11684863B1 (bath toy)Search in Eureka ↗
DefendantGuangzhou Hui De E-Trade Co., Ltd.CompanyFour Chinese Amazon marketplace sellers of allegedly infringing bath toy productsSearch in Eureka ↗
Co-DefendantGuangzhou Yikong Electronic Commerce Co., Ltd.CompanySearch in Eureka ↗
Co-DefendantShenzhen Hongquan International Co., Ltd.CompanySearch in Eureka ↗
Co-DefendantShenzhen Shi Yanwu Zhineng Jiaju Youxian Gongsi, Ltd.CompanySearch in Eureka ↗
Plaintiff counselChristopher Jon FladgateAttorneyCounsel for Kids Squad, LLCSearch in Eureka ↗
Plaintiff counselMichael Myer SteinmetzAttorneyCounsel for Kids Squad, LLCSearch in Eureka ↗
Plaintiff law firmGarson Segal Steinmetz Fladgate LLPLaw FirmRepresenting Kids Squad, LLCSearch in Eureka ↗
Presiding judgeJudge Katherine Polk FaillaJudgeNew York Southern District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“THIS CASE having been commenced by Kids Squad LLC (“Plaintiff”) against Defendants Guangzhou Hui De E-Trade Co., Ltd., Guangzhou Yikong Electronic Commerce Co. Ltd., Shenzhen Shi Yanwu Zhineng Jiaju Youxian Gongsi Ltd., and Shenzhen Hongquan International Co., Ltd. (collectively, the “Defendants”) and using online Amazon accounts identified in Amazon’s production (the “Defaulting Defendant Amazon Storefronts”), and Plaintiff having moved for entry of Default and Default Judgment against Defendants Guangzhou Hui de E-Trade Co., Ltd. and Guangzhou Yikong Electronic Commerce Co., Ltd. (collectively, the “Defaulting Defendants”); Plaintiff having properly completed service of process on Defaulting Defendants pursuant to the methods authorized in the Court’s order of September 6, 2023, Dkt. No. 12, the combination of providing notice via electronic publication or email, along with any notice that Defaulting Defendants received from Amazon, 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 Case 1:23-cv-07764-KPF Document 53 Filed 09/25/24 Page 1 of 6 – 2 – None of the Defaulting Defendants having answered the Complaint or appeared in any way, and the time for answering the Complaint having expired; THIS COURT FURTHER FINDS that it has personal jurisdiction over the Defaulting Defendants because the Defaulting Defendants directly target their business activities toward consumers in the United States, including New York, offering to sell and ship products into this Judicial District. Specifically, Defaulting Defendants are reaching out to do business with New York residents by operating Defaulting Amazon Storefronts through which New York residents can purchase products (“Infringing Products”) that infringe at least Claim 1 of Plaintiff’s U.S. Patent No. 11,684,863 (the “‘863 Patent”) identified within Plaintiff’s Complaint. Dkt. No. 5. THIS COURT FURTHER FINDS that Defaulting Defendants are liable for willful federal Patent infringement. IT IS HEREBY ORDERED that Plaintiff’s Motion for Entry of Default and Default Judgment is GRANTED in its entirety, that Defaulting Defendants are deemed in default and that this Default Judgment is entered against Defaulting Defendants. Accordingly, this Court ORDERS that: 1. Defaulting Defendants, their parent companies, subsidiaries, agents, officers, employees, and attorneys, and other persons who are in active concert or participation with them be permanent enjoined from: a. Making, using, offering to sell, or selling within the United States, or importing into the United States, or actively inducing others to make, use, offer to sell, or sell within the United States or to import into the United States: (i) any Infringing Products identified in the Complaint [Dkt. No. 5], or (ii) any product that infringes the ‘863 Patent; Case 1:23-cv-07764-KPF Document 53 Filed 09/25/24 Page 2 of 6 – 3 – b. Using, linking to, transferring, selling, or otherwise exercising control over the Defaulting Amazon Storefronts, or any other domain name or online marketplace account that is being used to sell or is the means by which Defaulting Defendants could continue to sell Infringing Products; c. Shipping, delivering, holding for sale, transferring, or otherwise moving, storing, distributing, returning, or otherwise disposing of, in any manner, products or inventory not manufactured by or for Plaintiff, not authorized by Plaintiff to be sold or offered for sale, and which infringes the ‘863 Patent; and d. Operating and/or hosting websites and/or any other web presence registered or operated by Defaulting Defendants that are involved with the distribution, marketing, advertising, offering for sale, or sale of any product that infringes the ‘863 Patent. 2. Those in privity with Defaulting Defendants and with actual notice of this Order, including any online marketplaces such as Amazon, shall within three (3) business days of receipt of this Order: a. disable and cease providing services for any accounts through which Defaulting Defendants engage in the sale of Infringing Products. b. disable and cease displaying any advertisements used by or associated with Defaulting Defendants in connection with the sale of Infringing Products; and c. take all steps necessary to prevent links to the Defaulting Amazon Storefronts from displaying in search results, including, but not limited to, removing links to the Defaulting Amazon Storefronts from any search index. Case 1:23-cv-07764-KPF Document 53 Filed 09/25/24 Page 3 of 6 – 4 – 3. Those in privity with Defaulting Defendants and with actual notice of this Order, including third party platforms Amazon, PayPal, shall within two (2) business days search and provide resulting discovery for Defaulting Defendant Accounts based on identifying information provided by Plaintiff’s counsel, including but not limited to, account IDs, legal names, and associated email addresses. 4. Amazon.com (“Amazon”) and any related companies and affiliates shall, within two (2) business days of receipt of this Order, permanently restrain and enjoin any accounts connected to Defaulting Defendants from transferring or disposing of any money or other of Defaulting Defendants’ assets. 5. Pursuant to 35 U.S.C. § 284, Plaintiff has established $20,906.89 in the form of lost profits as a result of Defaulting Defendants’ patent infringement. The Court finds that Defaulting Defendants’ patent infringement as alleged and supported was willful, egregious and otherwise knowing and culpable warranting trebling of damages. Therefore, Defaulting Defendants shall pay Plaintiff $62,720.67 in damages. 6. The Court finds that this case is “exceptional” within the meaning of 35 U.S.C. § 285, and therefore, Plaintiff is entitled to an award of reasonable attorneys’ fees. The Court finds that Plaintiff has established that the time spent and hourly rates incurred in prosecuting this matter were reasonable, and therefore Defaulting Defendants shall pay Plaintiff $25,550 to reimburse Plaintiffs’ attorneys fees. 7. Pursuant to Fed. R. Civ. P. 54 and 28 U.S.C. § 1920, as the prevailing party, Plaintiff is entitled to recover taxable costs. In addition, under 35 U.S.C. §§ 284, 285, the Court has the discretion to award other, non-taxable costs and expenses. Exercising its discretion, the Case 1:23-cv-07764-KPF Document 53 Filed 09/25/24 Page 4 of 6 – 5 – Court awards Plaintiff $402 in reasonable litigation costs, which Defaulting Defendants are obligated to pay. 8. With respect to all awarded amounts, Plaintiff is entitled to statutory interest of 8.25% per annum upon entry of this judgment. 9. All monies currently restrained in Defaulting Defendants’ financial accounts, including monies held by Amazon are hereby released to Plaintiff as partial payment of the aboveidentified damages within ten (10) business days of receipt of this Order. 10. Until Plaintiff has recovered full payment of monies owed by any Defaulting Defendant, Plaintiff shall have the ongoing authority to serve this Order on any banks, savings and loan associations, or other financial institutions (collectively, the “Financial Service Providers”) in the event that any new financial accounts controlled or operated by Defaulting Defendants are identified. Upon receipt of this Order, the Financial Service Providers shall within two (2) business days: a. Locate all accounts and funds connected to Defaulting Defendants, or Defaulting Amazon Storefronts, including, but not limited to, any accounts; b. Restrain and enjoin such accounts or funds from transferring or disposing of any money or other of Defaulting Defendants’ assets; and c. Release all monies restrained in Defaulting Defendants’ accounts to Plaintiff as partial payment of the above-identified damages within ten (10) business days of receipt of this Order. 9. In the event that Plaintiff identifies any additional online marketplace accounts, domain names, or financial accounts owned by Defaulting Defendants, Plaintiff may send notice Case 1:23-cv-07764-KPF Document 53 Filed 09/25/24 Page 5 of 6 – 6 – of any supplemental proceeding to Defaulting Defendants by email at the email addresses identified by Plaintiff and any email addresses provided for Defaulting Defendants by third parties. 11. Plaintiff may serve this Order on third party providers including Amazon by e-mail delivery to the e-mail addresses Plaintiff used to serve the Temporary Restraining Order and Preliminary Injunction Order on third party providers. 12. The Court releases the Two Thousand U.S. Dollar ($2,000.00) security bond that Plaintiff submitted in connection with this action to counsel for Plaintiff, Garson Ségal Steinmetz Fladgate LLP, 164 West 25th Street, Suite 11R, New York, NY 10001; and 13. This Court shall retain jurisdiction over this matter and the parties in order to construe and enforce this Order. The Clerk of Court is otherwise directed to terminate all pending motions, adjourn all remaining dates, and close this case”
Source: PACER Docket, Case 1:23-cv-07764, New York Southern District Court

The verdict’s willfulness finding — described as ‘willful, egregious and otherwise knowing and culpable’ — carries significance beyond trebling: it supports the § 285 ‘exceptional case’ designation that justified full attorneys’ fee shifting. The permanent injunction extends to parties ‘in privity’ with the defendants, binding Amazon and PayPal operationally without naming them as defendants. The court’s retention of jurisdiction suggests Kids Squad retains ongoing enforcement authority, including against newly identified accounts.

PACER case 1:23-cv-07764 · Public docket record Explore in Eureka ↗
Patent at issue

US11684863B1 — Children’s Bath Toy Product Patent

Publication No.US11684863B1
Application No.US18/100718
Patent details
ProductChildren’s bath toy product design and functional features
Cited in actionAugust 31, 2023

U.S. Patent No. 11,684,863 (application number US18/100718) is a utility patent granted to Kids Squad, LLC covering a children’s bath toy product. The ‘863 Patent is the subject of at least Claim 1 as identified in the litigation, which the court found to be infringed by competing products sold through Amazon storefronts operated by Chinese e-commerce entities. The patent’s B1 designation indicates it issued without prior publication, suggesting a relatively streamlined prosecution history.

The enforcement of US11684863 against multiple Chinese Amazon sellers in a single action reflects a strategic portfolio approach common in the consumer products sector: identifying and consolidating infringing storefronts, then leveraging marketplace infrastructure to execute enforcement. For competitors in the children’s bath toy and aquatic toy segment, the patent’s active enforcement status and the SDNY’s willingness to grant broad injunctive relief make FTO analysis essential before launching or continuing U.S. marketplace listings.

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

Should you run an FTO analysis against US11684863?

Any company — domestic or international — selling children’s bath toy products on Amazon or other U.S. online marketplaces should evaluate its exposure to US11684863. The SDNY’s jurisdictional ruling confirms that directing sales at U.S. consumers through Amazon is sufficient for personal jurisdiction, even without a U.S. physical presence. Given Kids Squad’s demonstrated willingness to litigate to default judgment, a proactive FTO assessment is commercially prudent before listing or scaling bath toy products in the U.S. market.

PatSnap Eureka’s FTO Search Agent can map the full claim landscape of US11684863, identify design-around opportunities, and surface prior art that may affect claim validity — all in a fraction of the time required by traditional search. Eureka can also flag related applications and continuation risk, helping R&D and product teams make informed go/no-go decisions before products reach U.S. marketplaces.

PatSnap Eureka FTO Search

Run a freedom-to-operate analysis on US11684863B1 to assess your product’s exposure

Run FTO in Eureka →
Related litigation

Similar Amazon Patent Enforcement Cases: Children’s Products in SDNY

Explore comparable patent infringement default judgments against Chinese Amazon sellers in the children’s consumer products sector before SDNY courts.

🔍
Access 40+ similar cases in PatSnap Eureka
Kids Squad, LLC patent enforcement history, New York Southern case history, Kids Squad, LLC’s full IP portfolio, and comparable case analysis
Amazon default judgments 2023–24Children’s product patent suits SDNYChinese seller IP enforcement casesTreble damages consumer goods patents
Unlock similar cases in Eureka →
Strategic implications

What this case signals for the consumer products IP enforcement landscape

The SDNY default judgment in Kids Squad reveals a replicable enforcement template targeting Chinese marketplace sellers through Amazon’s own infrastructure.

Electronic service and Amazon production unlock cross-border enforcement

Judge Failla authorized service by electronic publication and email — combined with Amazon’s production of account data — establishing a low-friction pathway to jurisdiction over Chinese defendants who sell into the U.S. Patent holders in consumer goods should assess whether similar electronic service orders are available in their target jurisdictions.

Willfulness finding on default triggers automatic trebling risk for marketplace sellers

Where defendants default and the plaintiff pleads willful infringement, courts routinely accept trebling of damages under § 284. The $20,906.89 in proven lost profits became $62,720.67 through trebling alone. Marketplace sellers — and their platforms — should treat IP enforcement notices as litigation triggers, not nuisance correspondence.

🔒
Full strategic analysis in PatSnap Eureka
Unlock deeper analysis on US11684863 claim scope, Amazon marketplace enforcement risk, and SDNY consumer products litigation patterns.
Claim 1 scope analysisNon-defaulting defendant statusAmazon FTO risk map
Unlock full analysis →
Analysis powered by PatSnap Eureka Litigation Intelligence Explore in Eureka ↗
Frequently asked questions

Kids v Guangzhou — key questions answered

Still have questions? PatSnap Eureka can answer them instantly from patent and litigation data. Ask Eureka ↗
PatSnap Eureka

Protect your consumer product IP — or assess your exposure before entering the market

Whether you are a patent holder pursuing Amazon marketplace enforcement or a seller assessing FTO risk, PatSnap Eureka provides claim-level analysis, litigation monitoring, and prior art search for US11684863 and the broader children’s bath toy patent landscape.

Ask anything about this case.
PatSnap Eureka searches patents and litigation data to answer instantly.
Powered by PatSnap Eureka
Link copied to clipboard

Related Litigation Cases

Help us improve this page

Found incorrect or outdated information? Let us know and we'll get it fixed.