Lovitedo LLC v. Schedule A Defendants: $141,219 Default Judgment for Toy Gun Patent
Lovitedo, LLC secured a default judgment of $141,219 and a permanent injunction against an anonymous Amazon marketplace seller for infringing US11644271B1, a patent covering a toy gun product. The case resolved in 225 days without the defendant appearing, with Amazon ordered to release restrained account funds directly to the plaintiff.
Amazon Seller Default Yields Full Patent Damages for Toy Gun IP
On October 8, 2024, Lovitedo, LLC filed a patent infringement action in the Northern District of Illinois against defendants identified only as ‘Partnerships and Unincorporated Associations Identified in Schedule A’ — a common anonymised pleading format used in Schedule A enforcement campaigns targeting online marketplace sellers. The asserted patent, US11644271B1, covers a toy gun product and was filed under application number US17/555529. The defendant operated an Amazon storefront under Seller ID A2AJK7IY3FRI8U.
The case closed on May 21, 2025, when Judge Jeremy C. Daniel granted Lovitedo’s motion for entry of default and default judgment in its entirety. The court awarded $141,219 in patent damages under 35 U.S.C. § 284 and issued a permanent injunction prohibiting the defaulting defendant from offering, selling, or importing any product covered by the ‘271 Patent without authorisation. Critically, the court ordered Amazon.com, Inc. to release all funds restrained in the defendant’s seller account — up to the $141,219 damages figure — directly to the plaintiff.
The 225-day resolution is notably fast for a patent case but is consistent with Schedule A actions where defendants fail to appear, allowing plaintiffs to obtain default judgments on an accelerated timeline. The absence of any defendant counsel or substantive opposition means no invalidity or non-infringement defences were tested on the merits. The public record does not disclose whether Lovitedo had previously sought to identify or serve other defendants listed in Schedule A, or whether the restrained Amazon funds fully covered the damages award.
Filing to Default Judgment in 225 days
225-day resolution — faster than average district court patent lifecycle of 2–3 years, driven by defendant default
Default judgment entered: what the order means for both parties
Default judgment: full relief granted without merits contest
A default judgment under Fed. R. Civ. P. 55 is entered when a defendant fails to appear or respond. The court treats the plaintiff’s well-pleaded allegations as admitted and may award full relief sought. Here, the court granted the motion ‘in its entirety,’ meaning no reduction was applied to damages or injunctive scope. Importantly, no validity or infringement analysis was conducted — the ‘271 Patent was never tested on the merits.
Defendant non-appearanceLovitedo secures maximum monetary and injunctive relief
Lovitedo received the full $141,219 damages award and a permanent injunction covering the defendant’s affiliates, agents, and confederates. The Amazon account freeze mechanism converted an intangible judgment into immediate liquidity — a strategically significant feature of Schedule A litigation. The injunction extends to any person acting in concert with the defendant, providing broad downstream coverage.
Full damages + permanent injunctionNon-appearance forfeits all defences and freezes seller revenue
By failing to appear, the defendant waived every potential defence — invalidity, non-infringement, damages apportionment. The court’s order to release restrained Amazon account funds means the financial consequence was immediate and collectable without further enforcement steps. The permanent injunction applies to the seller’s affiliates and agents, potentially disrupting related business operations beyond this single account.
All defences forfeitedSchedule A campaigns: effective patent enforcement on Amazon
This case illustrates the commercial efficacy of Schedule A patent enforcement: an IP holder can identify infringing Amazon sellers, obtain a TRO freezing marketplace funds, and convert that freeze into a damages award if the seller defaults. For toy and consumer product IP holders, this pathway is increasingly common. Sellers operating on Amazon without patent clearance in competitive product categories face asymmetric exposure if they ignore litigation notice.
Amazon IP enforcement modelFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Lovitedo, LLC | Company | Consumer toy product IP holder — asserting US11644271B1 covering a toy gunSearch in Eureka ↗ |
| Defendant | THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A | Individual | Anonymous Amazon marketplace seller; failed to appear or defend in proceedingsSearch in Eureka ↗ |
| Plaintiff counsel | Kevin John Keener | Attorney | Counsel for Lovitedo, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Keener & Associates PC | Law Firm | Representing Lovitedo, LLCSearch in Eureka ↗ |
| Presiding judge | Judge Jeremy C. Daniel | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The verdict’s operative language — ‘granted in its entirety’ — confirms the court accepted Lovitedo’s damages calculation under 35 U.S.C. § 284 without reduction, consistent with default judgment practice where well-pleaded damage allegations are deemed admitted. The permanent injunction’s reach to ‘affiliates, officers, agents, servants, employees, attorneys, confederates, and all persons acting in active concert’ is standard Schedule A injunction language and is intentionally broad. The Amazon fund release mechanism, capped at $141,219, demonstrates how pre-judgment asset restraints in these cases function as built-in collection vehicles.
US11644271B1 — Toy Gun Product Patent
US11644271B1 is a US utility patent granted to Lovitedo, LLC, filed under application number US17/555529. The patent covers a toy gun product — placing it within the consumer recreational products category. The B1 designation indicates the patent issued without any prior publication of the application, meaning the claims were not publicly disclosed before grant. The specific claim scope covering the toy gun is central to the infringement allegation, though the default judgment means no claim construction ruling was issued in this proceeding.
For competitors and sellers active in the toy gun and recreational shooting toy category on Amazon and other online marketplaces, US11644271B1 represents an enforced patent with a demonstrated willingness to litigate. Because no invalidity defence was raised or adjudicated here, the patent’s claims remain presumptively valid under 35 U.S.C. § 282. Sellers sourcing similar products from third-party manufacturers — particularly those supplied through channels common in the Schedule A defendant profile — should treat this patent as an active enforcement risk requiring FTO clearance.
Should you run an FTO analysis against US11644271B1?
Any company designing, manufacturing, importing, or selling toy gun products through Amazon or other online marketplaces should assess freedom-to-operate against US11644271B1. The patent has been actively enforced, and the Schedule A litigation model means multiple sellers in overlapping product categories may face simultaneous actions. Product teams sourcing from suppliers who have supplied infringing goods face potential contributory or induced infringement exposure even if they are not the primary seller.
PatSnap Eureka’s FTO Search Agent can map the claim scope of US11644271B1 against your product specifications, surface prior art that could support an IPR petition, and identify other patents in Lovitedo’s portfolio that may create adjacent risk. For Amazon-channel sellers in particular, understanding the full claim landscape before listing a product is significantly cheaper than contesting or defaulting on a Schedule A action after an account freeze.
Run a freedom-to-operate analysis on US11644271B1 to assess your product’s exposure
Run FTO in Eureka →Similar toy and consumer product patent cases in Illinois Northern District
Schedule A patent enforcement actions targeting Amazon sellers in toy and consumer product categories are concentrated in the Northern District of Illinois — explore comparable cases below.
What this case signals for the toy and consumer products IP landscape
Default judgments in Schedule A actions are reshaping how consumer product patent holders enforce IP against online marketplaces.
Amazon fund freezes make Schedule A judgments immediately collectable
Unlike traditional patent judgments requiring separate enforcement steps, this order directed Amazon to release restrained account funds within ten business days. For patent holders in consumer goods, this mechanism converts a default judgment into near-instant liquidity — a structural advantage unavailable in most other enforcement contexts.
No merits review means the patent’s validity remains untested
US11644271B1 was never subjected to an invalidity or claim construction analysis. Competitors who believe the patent is weak cannot rely on this outcome as precedent. Any party wishing to challenge the patent’s scope or validity would need to pursue IPR at the PTAB or raise invalidity in contested litigation.
Lovitedo v PARTNERSHIPS — key questions answered
The Northern District of Illinois entered a default judgment in favour of Lovitedo, LLC on May 21, 2025. The court awarded $141,219 in patent damages under 35 U.S.C. § 284 and issued a permanent injunction against the defaulting defendant for infringing US11644271B1. Amazon was ordered to release restrained seller account funds up to the damages amount directly to the plaintiff.
US11644271B1 is a US utility patent held by Lovitedo, LLC covering a toy gun product, filed under application US17/555529. Lovitedo alleged the anonymous Amazon marketplace defendant sold products that fell within the patent’s claims without authorisation. Because the defendant defaulted, no claim construction or invalidity analysis was conducted, leaving the patent’s full scope untested on the merits.
Schedule A litigation is a multi-defendant enforcement strategy where a plaintiff files a single action against numerous anonymous online sellers, identified only in a sealed ‘Schedule A’ exhibit. Courts in the Northern District of Illinois routinely grant temporary restraining orders that freeze defendants’ marketplace accounts. If defendants fail to appear, plaintiffs can obtain default judgments, with courts ordering platforms like Amazon to release frozen funds directly to the patent holder.
Yes. A default judgment in a patent case does not constitute a merits ruling on patent validity. No claim construction was performed and no invalidity defence was litigated. Any party who believes US11644271B1 is invalid could petition the USPTO for inter partes review (IPR) before the PTAB, or raise invalidity as a defence if sued in a future contested infringement action.
The damages award of $141,219 was entered under 35 U.S.C. § 284, which provides for damages adequate to compensate for infringement. Because the defendant failed to appear, the court accepted Lovitedo’s damages calculation without challenge or reduction. The public record does not disclose the specific methodology used — whether a reasonable royalty, lost profits, or another basis — as no adversarial hearing on damages quantum was held.
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