PP LLC v. Schedule A Defendants: $50,000 Default Judgment Over POOL PUNISHER Counterfeits
PP LLC, holder of design patent USD0981519S covering the POOL PUNISHER product line, sued a network of anonymous online sellers for selling counterfeit pool floats and sleds. The Illinois Northern District Court entered a final default judgment of $50,000 in statutory damages, with permanent injunctions and asset freezes across major e-commerce platforms, closing the case in 190 days.
Design Patent Enforcement Against a Counterfeit E-Commerce Network
PP LLC filed suit on May 30, 2024, in the U.S. District Court for the Northern District of Illinois against a group of anonymous defendants — identified as ‘The Partnerships and Unincorporated Associations Identified in Schedule A’ — a common enforcement tactic used to target coordinated networks of online counterfeit sellers. The asserted intellectual property includes design patent USD0981519S (application no. US29/783831) alongside trademark and copyright rights covering the POOL PUNISHER brand, which spans seasonal consumer products: pool floats in summer and sleds in winter.
The case concluded on December 6, 2024, via final default judgment after defendants failed to appear or respond. Judge Mary M. Rowland awarded $50,000 in statutory damages under the Lanham Act and Copyright Act, entered a permanent injunction barring defendants from any further use of PP LLC’s intellectual property, and ordered domain name registries and major third-party platforms — including Amazon, eBay, Temu, Shopify, PayPal, and Stripe — to disable accounts, freeze assets, and transfer funds to the plaintiff within specified timeframes.
The 190-day resolution is consistent with uncontested Schedule A default proceedings, which typically move quickly given defendants’ non-participation. The plaintiff’s use of a $10,000 surety bond, later returned, suggests a TRO or preliminary injunction was sought early in the case. What remains unknown from the public record is the actual amount of funds recovered from frozen accounts and whether any defendants were ultimately identified or held individually accountable beyond the default.
Filing to Default Judgment in 190 days
190 days — faster than typical contested IP cases in N.D. Illinois, reflecting unopposed default proceedings
Final default judgment: what the ruling means for both parties
Default judgment: plaintiff wins without merits contest
A default judgment is entered when defendants fail to appear or respond. The court accepts the plaintiff’s well-pleaded allegations as true and proceeds to relief. Here, Judge Rowland entered a final default judgment awarding statutory damages and permanent injunctive relief. No merits defence was argued, meaning the design patent, trademark, and copyright validity were never contested by the defendants.
Unopposed — defendants did not appearPP LLC secures permanent injunction and asset recovery
PP LLC obtained a permanent injunction against all defaulting defendants, domain name transfers or disablement, account freezes across major platforms, and a $50,000 statutory damages award. Critically, the order authorises ongoing supplemental proceedings under FRCP 69, giving PP LLC continuing authority to recover against defendants’ assets. The surety bond was also returned, recovering that cost.
Permanent injunction + $50K damagesCounterfeit sellers face account freezes and domain seizure
Defaulting defendants are permanently barred from selling, distributing, or advertising any product bearing PP LLC’s intellectual property. Their online marketplace accounts on platforms including Amazon, eBay, and Temu were ordered frozen, and domain names were subject to transfer or disablement. Third-party payment processors including PayPal and Stripe were ordered to release restrained funds to the plaintiff. Non-participation by defendants left them with no appellate posture on the merits.
Assets frozen, accounts disabledMulti-platform enforcement order sets broad precedent for brand protection
The order’s sweep — covering Alibaba, AliExpress, Amazon, DHgate, eBay, Temu, Shopify, Walmart, and multiple payment processors — is characteristic of aggressive Schedule A litigation strategy. For brand holders in seasonal consumer products, this case demonstrates that coordinated enforcement targeting anonymous online seller networks can yield rapid injunctive relief and asset recovery without contested litigation, provided the IP portfolio is properly secured.
Cross-platform enforcement modelFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | PP LLC | Company | Consumer products IP holder — holder of design patent USD0981519S for POOL PUNISHER productsSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified in Schedule A | Individual | Anonymous online marketplace sellers alleged to sell counterfeit POOL PUNISHER pool floats and sledsSearch in Eureka ↗ |
| Plaintiff counsel | James Edward Judge | Attorney | Counsel for PP LLCSearch in Eureka ↗ |
| Plaintiff counsel | Ying Chen | Attorney | Counsel for PP LLCSearch in Eureka ↗ |
| Plaintiff counsel | Zareefa Burki Flener | Attorney | Counsel for PP LLCSearch in Eureka ↗ |
| Plaintiff law firm | Flener IP & Business Law | Law Firm | Representing PP LLCSearch in Eureka ↗ |
| Presiding judge | Judge Mary M. Rowland | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The final default judgment is comprehensive in scope, addressing not only damages but operational shutdown of the entire infringing distribution chain. The $50,000 statutory damages award reflects willful infringement findings under both the Lanham Act and Copyright Act — the maximum per-work statutory tier for willful conduct. The verdict’s explicit application of the award ‘only once even if listed under multiple aliases’ is a standard safeguard against double recovery in Schedule A cases, suggesting the court’s familiarity with this enforcement format. The asset release mechanism — directing third-party platforms to transfer frozen funds directly to plaintiff — is particularly notable as it operationalises recovery without requiring individual defendant identification.
USD0981519S — POOL PUNISHER ornamental design for seasonal consumer products
USD0981519S is a U.S. design patent filed under application number US29/783831, protecting the ornamental appearance of the POOL PUNISHER product — a dual-season consumer item marketed as a pool float in summer and a sled in winter. Design patents protect the visual, non-functional characteristics of a product and, once granted, provide 15 years of protection from the grant date. The dual-use nature of the POOL PUNISHER design — spanning two distinct seasonal categories — is commercially notable, as it extends the product’s market window and the patent’s enforcement relevance across multiple retail cycles.
For competitors in the seasonal recreational products space, USD0981519S represents an active enforcement asset. PP LLC’s willingness to pursue litigation through the Schedule A mechanism — coordinating across domain registrars, major e-commerce platforms, and global payment processors — signals a sophisticated and aggressive enforcement posture. Any company designing or selling pool floats, inflatable toys, or recreational sleds with a visual similarity to the POOL PUNISHER design faces meaningful infringement risk. The combination of design patent, trademark, and copyright protection creates overlapping layers of IP coverage that are difficult to design around without a freedom-to-operate analysis.
Should you run an FTO analysis against USD0981519S?
If your company designs, sources, or sells recreational pool floats, inflatable summer products, or consumer sleds — particularly through online marketplaces including Amazon, eBay, Temu, or Shopify — USD0981519S and associated POOL PUNISHER trademark rights are directly relevant to your freedom-to-operate. This case demonstrates that PP LLC actively enforces these rights through coordinated multi-platform actions, including asset freezes and domain seizures, with minimal litigation delay. The risk is not theoretical: unnamed defendants in Schedule A cases can include small importers, dropshippers, and third-party marketplace sellers.
PatSnap Eureka’s FTO Search Agent can map the claim scope of USD0981519S against your product designs, identify the priority date and coverage window, and surface any related continuation or family applications that may extend the protection footprint. Eureka can also monitor for new design patent filings by PP LLC and alert your team to enforcement actions in related technology classes — giving R&D and sourcing teams the visibility they need before committing to product development or marketplace listings.
Run a freedom-to-operate analysis on USD0981519S to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A design patent enforcement cases — N.D. Illinois
Explore comparable Schedule A infringement actions involving design patents and seasonal consumer products filed in the Northern District of Illinois.
What this case signals for the consumer products IP enforcement landscape
This case exemplifies the Schedule A enforcement playbook — and illustrates both its power and its limitations for brand holders targeting e-commerce counterfeiting.
Schedule A litigation is a proven rapid-response tool for brand holders
By filing against anonymous seller networks under a single case number, PP LLC obtained a sweeping injunction and asset freeze across 10+ platforms in under 200 days. For brand owners with registered design patents and trademarks, this approach can deliver faster relief than individual defendant litigation — particularly where defendants operate across jurisdictions.
Multi-layer IP protection amplifies recovery in counterfeit cases
PP LLC asserted a design patent, trademark rights, and copyright simultaneously. This stacking strategy under 15 U.S.C. § 1117(c)(2) and 17 U.S.C. § 504(c)(2) enabled statutory damages without proving actual loss — a critical advantage when counterfeit seller revenues are opaque or untraceable across marketplace platforms.
PP v Partnerships — key questions answered
The case resulted in a final default judgment in favour of PP LLC entered on December 6, 2024. The court awarded $50,000 in statutory damages for willful infringement of PP LLC’s trademark and copyright rights, issued a permanent injunction against all defaulting defendants, and ordered major e-commerce platforms and payment processors to freeze and release defendants’ funds to the plaintiff.
The case involves design patent USD0981519S (application number US29/783831), which protects the ornamental design of the POOL PUNISHER product — a consumer item sold as a pool float in summer and a sled in winter. The plaintiff also asserted trademark and copyright rights in the POOL PUNISHER brand.
A Schedule A defendant refers to a group of anonymous or pseudonymous online sellers named collectively in a single complaint, identified only in a sealed or attached schedule. This tactic is common in N.D. Illinois and allows brand holders to pursue coordinated enforcement against counterfeit seller networks operating across multiple e-commerce platforms without filing separate suits against each seller.
The court awarded $50,000 in statutory damages under 15 U.S.C. § 1117(c)(2) for willful trademark counterfeiting and 17 U.S.C. § 504(c)(2) for willful copyright infringement. These provisions allow plaintiffs to elect statutory damages without proving actual loss — a critical tool when counterfeit seller revenues are difficult to verify. The award applied once per defendant, even if listed under multiple aliases.
The permanent injunction and asset freeze orders covered a broad range of platforms and payment processors, including Amazon, eBay, Temu, Shopify, Walmart, Alibaba, AliExpress, DHgate, Fruugo, Joybuy, CJDropshipping, PayPal, Stripe, Payoneer, and LianLian. Domain name registrars including GoDaddy, Namecheap, and Name.com were also ordered to transfer or disable defendant domain names.
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