PG Ltd. v. Schedule A Defendants: Default Judgment in Hair Clipper Guide IP Case
PG Ltd. secured a default judgment against a class of anonymous online marketplace sellers accused of selling counterfeit versions of its hair clipper guide product. The Illinois Northern District Court granted a permanent injunction and $10,000 in statutory damages per defaulting defendant, with funds frozen across PayPal, Stripe, Payoneer, and LianLian accounts.
Schedule A counterfeit action yields swift default judgment for PG Ltd.
Filed on 7 April 2025 in the U.S. District Court for the Northern District of Illinois before Judge Manish S. Shah, this case pits PG Ltd. against an undisclosed number of online sellers identified only as ‘The Partnerships and Unincorporated Associations Identified in Schedule A.’ The action centres on USD0982233S, a design patent covering a guide for hair clippers, alongside associated copyrighted works. Defendants allegedly operated Internet storefronts — including on eBay and Walmart.com — selling counterfeit and infringing versions of PG Ltd.’s product.
The case closed on 5 August 2025 via default judgment after defendants failed to appear. Judge Shah granted PG Ltd.’s Motion for Entry of Default and Default Judgment in full: defendants are permanently enjoined from manufacturing, marketing, or selling infringing products, and statutory damages of $10,000 per defendant were awarded for willful copyright infringement under 17 U.S.C. § 504(c)(2). Third-party payment processors — including PayPal, Stripe, Payoneer, and LianLian — were ordered to freeze and release defendant funds within seven to fourteen calendar days.
At 120 days from filing to closure, this case resolved markedly faster than the median Schedule A infringement action, consistent with the default trajectory when anonymous defendants decline to contest. The speed and structure of the outcome — frozen payment accounts, platform-level injunctions, and a $127,000 surety bond returned to plaintiff’s counsel — suggests PG Ltd. and Flener IP & Business Law executed a well-prepared enforcement playbook. The total damages aggregate remains unknown from the public record, as the per-defendant figure applies individually and the Schedule A defendant count is sealed.
Filing to Default Judgment in 120 days
Resolved in 120 days — notably fast for a multi-defendant Schedule A infringement case
Default judgment granted: permanent injunction and damages against all defendants
Default judgment: what it means when defendants don’t appear
A default judgment is entered when a defendant fails to respond to a complaint. The court accepts the plaintiff’s well-pleaded allegations as true and grants the requested relief. Here, Judge Shah granted PG Ltd.’s motion in full, meaning all injunctive and monetary relief was awarded without a contested merits hearing. This is the standard outcome in Schedule A cases where anonymous overseas sellers elect not to engage.
No merits contestPG Ltd. secures permanent injunction and frozen funds
PG Ltd. obtained the full range of Schedule A enforcement remedies: a permanent injunction barring all infringing activity, platform-level takedown orders enforceable against eBay and Walmart.com, and mandatory fund releases from major payment processors within 14 days. The $127,000 surety bond posted at filing was returned in full. Statutory damages of $10,000 per defendant for willful infringement represent the maximum ceiling under 17 U.S.C. § 504(c)(2) for this damages category.
Full relief grantedDefaulting sellers face asset freezes and permanent market bar
Each defaulting defendant faces a $10,000 damages award, permanent injunction, and frozen financial accounts across LianLian, PayPal, Payoneer, and Stripe. Critically, the order grants PG Ltd. ongoing authority to pursue supplemental proceedings under FRCP 69 to collect any unpaid amounts, and to serve additional asset discovery by email. Defendants who chose not to appear are bound by all terms and have no automatic right to reopen the default.
Assets frozen; appeal path narrowMarketplace enforcement: a warning to counterfeit design product sellers
This judgment reinforces the effectiveness of the Schedule A litigation model for consumer product design patents and copyrights. Payment processor injunctions targeting LianLian — a platform frequently used by China-based marketplace sellers — signal that plaintiffs are increasingly targeting the financial infrastructure behind counterfeiting networks. For legitimate competitors in the hair clipper accessories space, the case confirms PG Ltd.’s active enforcement posture around USD0982233S.
Enforcement signal to marketplace sellersFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | PG Ltd., | Company | IP rights holder — holder of USD0982233S design patent for hair clipper guideSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified in Schedule A | Individual | Anonymous online marketplace sellers operating counterfeit storefronts on eBay and Walmart.comSearch in Eureka ↗ |
| Plaintiff counsel | James Edward Judge | Attorney | Counsel for PG Ltd.,Search in Eureka ↗ |
| Plaintiff counsel | Ying Chen | Attorney | Counsel for PG Ltd.,Search in Eureka ↗ |
| Plaintiff counsel | Zareefa Burki Flener | Attorney | Counsel for PG Ltd.,Search in Eureka ↗ |
| Plaintiff law firm | Flener IP & Business Law | Law Firm | Representing PG Ltd.,Search in Eureka ↗ |
| Presiding judge | Judge Manish S. Shah | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment is expansive in scope: it operates not only against named defendants but binds all persons ‘acting in active concert’ with them, and extends injunctive obligations to third-party platform and payment providers. The statutory damages figure of $10,000 per defendant reflects the willful infringement ceiling under 17 U.S.C. § 504(c)(2) rather than a negotiated or jury-assessed amount. Because no defendant appeared, there was no adversarial challenge to damages quantum or injunction breadth, meaning the order reflects PG Ltd.’s requested relief almost verbatim.
USD0982233S — Ornamental design for a guide for hair clippers
USD0982233S is a U.S. design patent protecting the ornamental appearance of a guide for hair clippers. Design patents under 35 U.S.C. § 171 cover the visual, non-functional characteristics of an article of manufacture as depicted in the patent drawings. Infringement is assessed under the ‘ordinary observer’ test: whether an ordinary purchaser, familiar with prior art, would be deceived into believing the accused design is the same as the patented design. The corrected application number US35/513233 places this filing in the standard design patent prosecution track.
Hair clipper accessories represent a high-volume, low-unit-price consumer product category that is particularly susceptible to counterfeiting via online marketplaces. Design patents in this space, while narrower than utility patents, are strategically valuable precisely because they enable Schedule A enforcement actions — targeting groups of anonymous sellers — without requiring proof of functional copying. PG Ltd.’s decision to assert USD0982233S alongside copyright claims maximises both injunctive leverage and statutory damages exposure for defaulting defendants.
Should your product team run an FTO against USD0982233S?
Any business designing, manufacturing, or distributing hair clipper guides — or accessories with a similar ornamental profile — sold through U.S. e-commerce channels should assess freedom-to-operate against USD0982233S. The ordinary observer test for design patents can capture products that are functionally distinct but visually similar, and the Northern District of Illinois has demonstrated willingness to issue ex parte TROs and default judgments rapidly in Schedule A cases. The risk is not limited to counterfeiters: legitimate competitors with similar-looking accessories could face enforcement action.
PatSnap Eureka’s FTO Search Agent allows product and IP teams to upload design images and map visual similarity against registered design patents including USD0982233S. Eureka can retrieve the original prosecution drawings, cited prior art, and related design family members to help counsel assess the claim boundary. For R&D teams developing new clipper guide profiles, Eureka’s design landscape view can identify white-space opportunities outside PG Ltd.’s registered visual claim.
Run a freedom-to-operate analysis on USD0982233S to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A design patent cases in the N.D. Illinois
Explore comparable Schedule A default judgment actions involving consumer product design patents and copyright infringement filed in the Northern District of Illinois.
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 Guide for hair clippers-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.
DecidedPG Ltd.,’s broader IP enforcement history
PG Ltd.,’s full litigation history covering prior enforcement, licensing activity, and inter partes review proceedings.
Portfolio viewWhat this case signals for the hair clipper accessories IP landscape
PG Ltd.’s swift default judgment illustrates how design patent holders are weaponising Schedule A actions to disrupt counterfeit supply chains at scale.
Schedule A default judgments move fast — 120 days is achievable
This case closed in 120 days, well below the average district court patent case. For IP holders in the consumer accessories space, this confirms that a well-prepared Schedule A complaint — with a pre-filed TRO, sealed Schedule, and payment processor injunction — can yield enforceable relief before counterfeiters can liquidate inventory or transfer funds.
Payment processor freezes are the real enforcement lever
The order targeting LianLian, PayPal, Payoneer, and Stripe within 7 days of service reflects a matured enforcement strategy. Funds frozen before defendants can transfer them abroad often exceed the face value of damages awarded. Companies monitoring counterfeit activity in consumer product categories should audit which payment rails their infringers use and name them explicitly in their complaints.
USD0982233S scope: which competing designs are at risk of capture
Design patents like USD0982233S protect ornamental appearance, not functional features. The claim scope turns entirely on the drawings. Competitors and FTO analysts should map the visual delta between their hair clipper guide designs and the registered drawings — even minor stylistic similarities have been held infringing under the ordinary observer test. PatSnap Eureka can surface the prosecution history and cited prior art to help calibrate that risk.
PG Ltd.’s enforcement pattern: a repeat plaintiff profile to monitor
Serial Schedule A plaintiffs — those filing multiple actions across different design and copyright portfolios — often signal a broader licensing or enforcement programme. If PG Ltd. files further actions in the N.D. Ill. involving consumer accessories, it suggests a systematic approach rather than a one-off enforcement event. IP teams in adjacent product categories should track plaintiff filing history via PatSnap Litigation to anticipate exposure.
PG v Partnerships — key questions answered
PG Ltd. won a permanent injunction barring all defendants from manufacturing, marketing, or selling infringing products, statutory damages of $10,000 per defaulting defendant for willful copyright infringement under 17 U.S.C. § 504(c)(2), mandatory fund releases from payment processors including PayPal, Stripe, Payoneer, and LianLian, and the return of its $127,000 surety bond.
USD0982233S is a U.S. design patent protecting the ornamental appearance of a guide for hair clippers. Design patents cover the visual, non-functional characteristics of a product as shown in the patent drawings. Infringement is assessed under the ordinary observer test, which asks whether an ordinary purchaser would be deceived into thinking the accused product is the same as the patented design.
A Schedule A case is a litigation strategy where a plaintiff files a single complaint against a large number of anonymous online sellers, identified on a sealed schedule rather than by name. It is commonly used in the Northern District of Illinois against overseas marketplace sellers of counterfeit goods. The approach allows plaintiffs to obtain ex parte TROs and asset freezes before defendants can move funds or inventory.
Default judgment was entered because the defendants failed to appear, answer the complaint, or otherwise respond to the litigation. Under Federal Rule of Civil Procedure 55, when a party fails to plead or defend, the court may enter a default judgment. In Schedule A cases, anonymous overseas defendants routinely decline to engage, resulting in default and full plaintiff relief without a contested merits hearing.
Defendants may move to vacate the default judgment under FRCP 60(b) if they can show good cause — typically by demonstrating excusable neglect, a meritorious defence, and lack of prejudice to the plaintiff. However, the bar is high and rarely met in Schedule A cases where defendants chose not to appear. The court also granted PG Ltd. ongoing authority to pursue supplemental collection proceedings under FRCP 69.
Monitor hair clipper design patent enforcement with PatSnap
PG Ltd.’s active enforcement of USD0982233S signals ongoing risk for sellers in the hair clipper accessories space. Use PatSnap Eureka to run an FTO analysis, track new Schedule A filings, and map the design patent landscape before launching your next product.
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