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.
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.
Filing to Default Judgment in 391 days
391 days — faster than the SDNY median for patent default proceedings, suggesting efficient case management
Default judgment entered: what the ruling means for both parties
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-appearanceKids 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 grantedAmazon 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 disabledCross-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 signalFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Kids Squad, LLC | Company | Children’s consumer products company — holder of US11684863B1 (bath toy)Search in Eureka ↗ |
| Defendant | Guangzhou Hui De E-Trade Co., Ltd. | Company | Four Chinese Amazon marketplace sellers of allegedly infringing bath toy productsSearch in Eureka ↗ |
| Co-Defendant | Guangzhou Yikong Electronic Commerce Co., Ltd. | Company | Search in Eureka ↗ |
| Co-Defendant | Shenzhen Hongquan International Co., Ltd. | Company | Search in Eureka ↗ |
| Co-Defendant | Shenzhen Shi Yanwu Zhineng Jiaju Youxian Gongsi, Ltd. | Company | Search in Eureka ↗ |
| Plaintiff counsel | Christopher Jon Fladgate | Attorney | Counsel for Kids Squad, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Michael Myer Steinmetz | Attorney | Counsel for Kids Squad, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Garson Segal Steinmetz Fladgate LLP | Law Firm | Representing Kids Squad, LLCSearch in Eureka ↗ |
| Presiding judge | Judge Katherine Polk Failla | Judge | New York Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
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.
US11684863B1 — Children’s Bath Toy Product Patent
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.
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.
Run a freedom-to-operate analysis on US11684863B1 to assess your product’s exposure
Run FTO in Eureka →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.
Related patent case — similar technology
Comparable case in the same technology domain. Patent holder and defendant reached resolution after proceedings.
SettledRelated infringement action — same court
Comparable Bath Toy Product-adjacent infringement action. Patent enforcement dynamics analysed in depth.
Active · District CourtRelated invalidity challenge — appellate outcome
Combined invalidity and infringement action in the same technology space. Decided after substantive proceedings.
DecidedKids Squad, LLC’s broader IP enforcement history
Kids Squad, LLC’s full litigation history covering prior enforcement, licensing activity, and inter partes review proceedings.
Portfolio viewWhat 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.
The ‘863 Patent’s claim scope determines reinfringement risk on Amazon
The court found infringement of at least Claim 1 of US11684863. Understanding the full claim scope — including independent and dependent claims — is essential for any bath toy or children’s aquatic product seller assessing whether their current listings remain exposed to a follow-on enforcement action by Kids Squad.
Two non-defaulting defendants may signal a contested continuation or separate resolution
Shenzhen Hongquan and Shenzhen Shi Yanwu were named defendants but did not receive the default judgment. The public record is silent on their disposition. A separate settlement, voluntary dismissal, or ongoing proceeding may exist — making monitoring of this case and docket activity commercially important for competitors in the bath toy segment.
Kids v Guangzhou — key questions answered
Kids Squad LLC obtained a default judgment against Guangzhou Hui De E-Trade Co. and Guangzhou Yikong Electronic Commerce Co. on September 25, 2024. The court found willful infringement of US11684863 and awarded trebled damages of $62,720.67, $25,550 in attorneys’ fees, $402 in costs, and entered a permanent injunction. Amazon was ordered to disable the defendants’ storefronts and release restrained funds to Kids Squad.
US11684863B1, held by Kids Squad LLC, covers a children’s bath toy product. In this case, the court found that at least Claim 1 of the patent was infringed by products sold through Amazon storefronts operated by the Chinese defendant entities. The patent’s B1 designation indicates it issued without prior publication.
The court found personal jurisdiction because the defendants directly targeted U.S. consumers, including New York residents, by operating Amazon storefronts through which infringing bath toy products could be purchased and shipped to New York. This targeting of U.S. marketplace consumers was deemed sufficient for jurisdictional purposes under SDNY precedent.
Under 35 U.S.C. § 284, a court may treble patent infringement damages where infringement is found to be willful. Here, the court characterised the defendants’ infringement as ‘willful, egregious and otherwise knowing and culpable,’ justifying the trebling of proven lost profits from $20,906.89 to $62,720.67. The case was also deemed exceptional under § 285, warranting attorneys’ fee-shifting.
The default judgment was entered specifically against Guangzhou Hui De E-Trade and Guangzhou Yikong Electronic Commerce. Shenzhen Hongquan International Co. and Shenzhen Shi Yanwu Zhineng Jiaju Youxian Gongsi were named as defendants but are not addressed in the default judgment order. The public record does not specify how their claims were resolved, suggesting a separate disposition, voluntary dismissal, or ongoing proceedings may apply.
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.
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