Liu v. Schedule A Defendants: Tablet Case Design Patent Ends in Consent Judgment
Patent holder Xiangxin Liu filed suit in the Northern District of Illinois against a broad cohort of e-commerce sellers alleging infringement of US Design Patent D672,353, covering a protective case for a tablet computer. The case resolved against defendant Merritfy within 328 days via consent judgment, yielding a permanent injunction and $1,750 in damages extracted directly from Merritfy’s Walmart seller account.
Design patent enforcement via Walmart account freeze yields injunction
Xiangxin Liu filed this action on January 4, 2024 in the Northern District of Illinois (Case No. 1:24-cv-00107), asserting that a large group of e-commerce sellers — identified collectively as Schedule A defendants — infringed US Design Patent D672,353, titled ‘Protective Case for a Tablet Computer.’ The defendants included numerous online storefronts operating under names such as Cayxenful, LRCXL DEALER, LXS Shop, YQMYXG, and others, consistent with the N.D. Illinois ‘Schedule A’ litigation strategy commonly used to target counterfeit or infringing goods sold through third-party marketplaces.
The case closed on November 27, 2024 against defendant Merritfy (Defendant No. 46) through a consent judgment, permanent injunction, and dismissal with prejudice. Under the terms, Merritfy expressly waived its right to appeal, agreed to a permanent injunction prohibiting manufacture, sale, importation, or promotion of the accused protective tablet covers, and consented to a $1,750 damages payment. Notably, Walmart was ordered to transfer the damages amount directly from Merritfy’s seller account within seven days, reflecting the asset-freeze mechanism commonly employed in Schedule A cases.
The 328-day duration and modest $1,750 damages figure are consistent with negotiated resolution patterns in N.D. Illinois Schedule A design patent cases, where plaintiffs often prioritise injunctive relief and platform-level enforcement over maximising monetary recovery. The public record does not disclose the resolution status of the remaining named defendants, and it is unclear whether separate consent judgments, defaults, or dismissals were entered as to those parties. The court retained jurisdiction specifically over Merritfy for enforcement purposes.
Filing to Consent Judgment in 328 days
328-day resolution — typical for Schedule A e-commerce enforcement actions in N.D. Illinois
Consent judgment against Merritfy: injunction, damages, and dismissal with prejudice
Consent judgment with prejudice forecloses future litigation
A consent judgment is a court-approved settlement that carries the force of a final court order. Because this judgment was entered with prejudice, Liu’s patent claims against Merritfy are fully resolved and cannot be re-litigated. Merritfy also expressly waived its appellate rights, meaning the injunction and damages are immediately final. The court retains jurisdiction solely for enforcement — not for re-opening the merits.
Dismissed with prejudiceLiu secures permanent injunction and Walmart account-level enforcement
Liu obtained a permanent injunction barring Merritfy from any further manufacture, sale, importation, advertising, or promotion of the accused tablet covers. The $1,750 damages were ordered transferred directly from Merritfy’s Walmart seller account — a platform-level enforcement mechanism that removes the need to independently collect from the defendant. Merritfy is also prohibited from challenging the validity or enforceability of D672,353.
Permanent injunction grantedMerritfy permanently barred and Walmart store restrictions lifted upon payment
Under the consent judgment, Merritfy is permanently enjoined and has waived all appeal rights. The $1,750 damages payment triggers Walmart’s release of any financial account restraints previously placed on the storefront — suggesting a pre-judgment asset freeze was in place. The with-prejudice dismissal means Merritfy faces no further monetary exposure from Liu on these specific claims, but the injunction binds the seller and all those acting in concert with it.
Injunction binding; appeal waivedMarketplace sellers face real account-freeze risk in Schedule A design patent actions
This case illustrates the coercive leverage available to design patent holders in Schedule A litigation: pre-judgment freezing of marketplace seller accounts creates strong incentives to settle quickly, often for modest sums. For e-commerce operators selling tablet accessories or consumer device cases, the risk is not just injunctive relief but immediate disruption of revenue streams. Sellers should conduct design patent clearance before listing third-party sourced accessories on major platforms.
E-commerce enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Xiangxin Liu | Individual | Consumer electronics IP holder — owner of design patent USD672,353 for a protective tablet caseSearch in Eureka ↗ |
| Defendant | The Partnerships And Unicorporated Associations Identified On Schedule A | Individual | Merritfy — e-commerce seller on Walmart marketplace, accused of selling infringing tablet coversSearch in Eureka ↗ |
| Co-Defendant | Cayxenful | Individual | Search in Eureka ↗ |
| Co-Defendant | LRCXL DEALER | Individual | Search in Eureka ↗ |
| Co-Defendant | LXS Shop | Individual | Search in Eureka ↗ |
| Co-Defendant | YQMYXG | Individual | Search in Eureka ↗ |
| Co-Defendant | Boxdljh | Individual | Search in Eureka ↗ |
| Co-Defendant | CenYouful | Individual | Search in Eureka ↗ |
| Co-Defendant | Hsxfl | Individual | Search in Eureka ↗ |
| Co-Defendant | LONGYIHANG | Individual | Search in Eureka ↗ |
| Co-Defendant | Others too numerous to list: Rayhee, Beebiz, LayYun, Newraturner, Xsltkby Dealer, RLINGX Dealer | Individual | Search in Eureka ↗ |
| Co-Defendant | Rouceyxin | Individual | Search in Eureka ↗ |
| Plaintiff counsel | David Randolph Bennett | Attorney | Counsel for Xiangxin LiuSearch in Eureka ↗ |
| Plaintiff counsel | Steven G. Kalberg | Attorney | Counsel for Xiangxin LiuSearch in Eureka ↗ |
| Plaintiff law firm | Direction IP law | Law Firm | Representing Xiangxin LiuSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The consent judgment is notable for its breadth: Merritfy is enjoined not only from selling the accused products but from challenging the validity, ownership, or enforceability of D672,353 in any forum. The explicit waiver of appeal rights and the direct Walmart account transfer mechanism reflect a carefully structured order designed to foreclose both commercial and legal re-engagement. The court’s retention of jurisdiction for enforcement purposes ensures Liu has an expedited path to contempt proceedings should Merritfy resume infringing activity — a standard but strategically important feature of consent judgments in Schedule A design patent cases.
USD672,353 — Protective Case for a Tablet Computer
US Design Patent D672,353 (application number 29/420,909) protects the ornamental design of a protective case for a tablet computer. Design patents cover the visual, non-functional appearance of a product — here, the specific aesthetic configuration of a tablet protective cover. Unlike utility patents, infringement is assessed under the ‘ordinary observer’ test: whether an ordinary purchaser would find the accused product substantially similar in overall visual impression to the patented design. Liu is identified in the consent judgment as the exclusive owner of all rights, title, and interest in the patent.
The protective tablet case market is highly competitive, with a large volume of low-cost products sourced from overseas manufacturers and resold through e-commerce platforms including Amazon, Walmart, and Walmart Marketplace. Design patents in this space are frequently asserted against Schedule A defendants — anonymous or pseudonymous online sellers — because the relatively low design complexity makes infringement comparisons straightforward and the marketplace account-freeze mechanism provides rapid leverage. D672,353 represents an asset that can be enforced repeatedly across multiple defendants, as this multi-defendant filing against over 40 parties demonstrates.
Should you run an FTO analysis against USD672,353?
Any company designing, importing, or reselling protective cases for tablet computers in the US market should assess freedom-to-operate against D672,353. Because design patent infringement turns on visual similarity rather than feature-by-feature claim mapping, even products that differ in material or function may infringe if their ornamental appearance is substantially similar to the patented design. Walmart and Amazon marketplace sellers are particularly exposed given the asset-freeze enforcement strategy demonstrated in this case.
PatSnap Eureka’s FTO Search Agent can map D672,353’s design claim drawings against your product’s visual profile, identify prior art that may narrow the patent’s effective scope, and surface related design patent families filed by Liu or related entities. For product teams sourcing tablet accessories from third-party manufacturers, running an FTO review before marketplace listing is a cost-effective way to avoid the account-freeze and injunction risk illustrated by this case.
Run a freedom-to-operate analysis on USD0672353S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in N.D. Illinois — tablet accessories
Cases involving design patent enforcement against Schedule A e-commerce defendants in N.D. Illinois, particularly in the tablet accessories and consumer electronics space.
What this case signals for the tablet accessories IP enforcement landscape
Schedule A design patent actions in N.D. Illinois are a proven, scalable enforcement model. This case confirms the playbook remains effective against marketplace sellers.
Asset freeze plus design patent is a powerful combination for IP holders
Liu’s team used N.D. Illinois’s Schedule A procedures to freeze Merritfy’s Walmart account prior to judgment. This pre-judgment remedy dramatically shifts settlement dynamics — defendants face immediate commercial harm regardless of the merits. IP holders enforcing design patents in consumer electronics should consider marketplace-specific enforcement strategies as a core litigation tool.
Small damages, big injunction: monetary recovery is not the primary objective
The $1,750 damages award is commercially modest for a design patent infringement case. The strategic value lies in the permanent injunction and the with-prejudice dismissal that prevents Merritfy from re-entering the market. This outcome pattern — low damages, high injunctive relief — is characteristic of Schedule A enforcement targeting volume resellers rather than manufacturers.
Liu v Partnerships — key questions answered
USD672,353 is a US design patent titled ‘Protective Case for a Tablet Computer,’ with application number 29/420,909. It protects the ornamental visual appearance of a tablet protective case. In this case, plaintiff Xiangxin Liu is identified as the exclusive owner of all rights, title, and interest in the patent.
A Schedule A filing allows a plaintiff to sue multiple anonymous or pseudonymous e-commerce sellers in a single action, naming them collectively and identifying specific sellers on a separately filed schedule. This approach is common in N.D. Illinois for IP enforcement against marketplace sellers on platforms like Amazon, Walmart, and eBay, where seller identities may initially be unknown.
The consent judgment required Merritfy to pay $1,750 in damages, with Walmart ordered to transfer the funds directly from Merritfy’s seller account. Merritfy was permanently enjoined from manufacturing, selling, importing, or advertising the accused tablet covers, and from challenging D672,353’s validity or enforceability. Merritfy waived all appellate rights, and the case was dismissed with prejudice.
Walmart was named as a third party in the damages transfer order because Merritfy operated an e-commerce store on the Walmart Marketplace. Pre-judgment asset restraints had been placed on Merritfy’s Walmart account, and the court directed Walmart to transfer the $1,750 damages amount to Liu’s counsel within seven days of the order, after which the account restraints would be lifted.
The dismissal with prejudice applies only to Merritfy (Defendant No. 46) under the consent judgment. It means Liu cannot re-sue Merritfy on the same D672,353 claims. The remaining named defendants — including Cayxenful, LRCXL DEALER, LXS Shop, and others — are not covered by this order, and their case status is not disclosed in the public record of Document 56.
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