Purkey Enterprises v. Schedule A Defendants: Default Judgment in Hair Device IP Case
Purkey Enterprises, LLC secured a final default judgment against anonymous online counterfeiters selling unauthorised copies of its patented hair lifting, retention, and styling device. The Northern District of Illinois awarded $100,000 in statutory damages per defaulting defendant, issued permanent injunctions, and ordered the seizure of funds held by major payment processors and marketplace platforms.
Anonymous counterfeit sellers routed in N.D. Ill. default judgment
On April 11, 2025, Purkey Enterprises, LLC filed suit in the U.S. District Court for the Northern District of Illinois against a class of anonymous defendants — identified only as partnerships and unincorporated associations listed in Schedule A — alleging trademark and copyright infringement in connection with the unauthorised sale of products mimicking its patented hair lifting, retention, and styling device (design patent application no. 29/534498, registered as USD0787124S). The defendants operated through online marketplace accounts and domain names, selling counterfeit goods to U.S. consumers via platforms including Amazon, eBay, Etsy, Shein, Temu, Walmart, AliExpress, and DHgate.
Because none of the defendants appeared or responded to the complaint, Judge Elaine E. Bucklo granted Purkey’s motion for entry of default and default judgment on October 10, 2025 — 182 days after filing. The court entered a final default judgment awarding $100,000 in statutory damages per defaulting defendant under 15 U.S.C. § 1117(c)(2) and 17 U.S.C. § 504(c)(2) for willful trademark and copyright infringement. The judgment further directed domain registrars and marketplace platforms to transfer or disable defendant domain names and online store accounts within seven days, and ordered payment processors — including PayPal, Stripe, Payoneer, and LianLian — to freeze and release defendant funds to Purkey as partial satisfaction of the damages award.
The 182-day resolution suggests the Schedule A enforcement mechanism operated efficiently here, consistent with the well-established N.D. Ill. practice of handling anonymous counterfeit seller cases at pace. The absence of any defendant appearance means the merits of the infringement allegations were never tested — the damage award reflects statutory maxima for willful infringement rather than proven actual harm. What remains unknown from the public record is the total number of defaulting defendants listed in Schedule A, making the aggregate damages figure and the ultimate recoverable amount from frozen marketplace accounts difficult to assess from the docket alone.
Filing to Default Judgment in 182 days
182 days from filing to final default judgment — faster than the median N.D. Ill. IP case
Default judgment entered: what the ruling means for both parties
Default judgment: liability without a merits contest
A default judgment under Fed. R. Civ. P. 55 is entered when a defendant fails to appear or respond. The court accepts the plaintiff’s well-pleaded allegations as true and determines appropriate relief. Here, Judge Bucklo granted both default entry and final default judgment in a single order — a standard Schedule A counterfeit-seller procedure in N.D. Ill. The infringement was treated as willful, triggering statutory damages maxima rather than actual damages.
No merits adjudicationPurkey secures injunctions, asset seizure, and $100K per defendant
Purkey Enterprises obtained a permanent injunction blocking all defendants from selling, marketing, or distributing infringing goods, plus domain transfer or disablement of defendant web properties. Critically, the court ordered payment processors and marketplace platforms to freeze and remit defendant funds within 14 days. Purkey retains ongoing authority under FRCP 69 to pursue supplemental enforcement proceedings until full satisfaction of the damages award — giving it a live tool to chase newly identified accounts.
Permanent injunction grantedDefaulting defendants face frozen accounts and permanent marketplace bans
Each defaulting defendant faces a $100,000 statutory damages judgment, permanent ejection from major e-commerce platforms, and domain seizure or disablement. Because the judgment is ‘final,’ defendants who failed to appear have very limited avenues to vacate it — they would need to show good cause, a meritorious defence, and lack of culpable conduct under FRCP 55(c) and 60(b), a high bar given the willfulness finding embedded in the award.
$100K per defendantSchedule A enforcement sends a deterrence signal to e-commerce counterfeiters
This outcome is consistent with a growing body of N.D. Ill. default judgments that use design patent and trademark rights to clear counterfeit listings from major platforms simultaneously. For legitimate competitors in the hair accessories and styling tools market, the ruling reinforces that design registrations covering even consumer accessories can support aggressive multi-platform enforcement actions with rapid asset-freezing relief. IP holders in adjacent product categories should note the speed and breadth of third-party platform compliance orders achieved here.
Multi-platform enforcementFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Purkey Enterprises, LLC | Company | Hair accessories IP owner — holder of design patent USD0787124S for a hair lifting and styling deviceSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations Identified in Schedule A | Individual | Anonymous online marketplace sellers alleged to have sold counterfeit hair styling devicesSearch in Eureka ↗ |
| Plaintiff counsel | James Edward Judge | Attorney | Counsel for Purkey Enterprises, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Ying Chen | Attorney | Counsel for Purkey Enterprises, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Zareefa Burki Flener | Attorney | Counsel for Purkey Enterprises, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Flener IP & Business Law | Law Firm | Representing Purkey Enterprises, LLCSearch in Eureka ↗ |
| Presiding judge | Judge Elaine E. Bucklo | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order is structured as a comprehensive final default judgment combining injunctive relief, statutory damages, and third-party platform compliance directives. The willfulness finding — supporting the $100,000 per-defendant maximum under 15 U.S.C. § 1117(c)(2) and 17 U.S.C. § 504(c)(2) — was reached by accepting Purkey’s pleaded allegations as true, as is standard on default. The breadth of the injunction, covering manufacturing, distribution, advertising, domain names, and payment accounts, reflects the court’s intent to extinguish the defendants’ entire online commercial infrastructure, not merely enjoin the specific infringing listings identified in the complaint.
USD0787124S — Ornamental design for a hair lifting and styling device
USD0787124S is a U.S. design patent (application no. 29/534498) protecting the ornamental appearance of a hair lifting, retention, and styling device. Design patents in the U.S. cover the novel, ornamental characteristics of a product — not its functional method of operation. As a design registration, it grants Purkey Enterprises the exclusive right to the specific visual appearance of the device, enabling enforcement against products that create the same overall visual impression in the eye of an ordinary observer.
In the hair accessories and styling tools market, design patents are commercially significant because consumers frequently select products based on visual appearance, and because the manufacturing economics of counterfeit accessories favour copying the appearance of market-leading products exactly. The asserted patent appears to cover a niche but commercially valuable segment of hair styling tools — the combination of lifting, retention, and styling functions in a single device — where design differentiation is a primary competitive lever. Competitors and OEM manufacturers producing similar hair tool categories should treat this patent as an active enforcement asset.
Should you run an FTO against USD0787124S?
Any company designing, manufacturing, or distributing hair lifting, retention, or styling devices — or any product with a similar ornamental profile — should consider whether their product’s visual appearance would strike an ordinary observer as substantially similar to USD0787124S. This is especially relevant for brands sourcing from contract manufacturers in Asia where design replication is common, OEM suppliers listing on Amazon, AliExpress, Etsy, or Temu, and new entrants to the consumer hair accessories market seeking to differentiate their product visually.
PatSnap Eureka’s FTO Search Agent can map the claim scope of USD0787124S against your product’s design, identify prior art that may limit the patent’s enforceability, and surface related design applications in Purkey’s portfolio that could represent additional risk. Given that this patent has already been asserted aggressively in a multi-defendant enforcement action, an early FTO review is a proportionate risk-management step for any manufacturer or distributor in the hair accessories category.
Run a freedom-to-operate analysis on USD0787124S to assess your product’s exposure
Run FTO in Eureka →Similar Schedule A design patent cases in N.D. Illinois
Cases involving Schedule A anonymous defendants, design patent enforcement, and multi-platform injunctions in the Northern District of Illinois federal court.
What this case signals for the hair accessories and e-commerce IP landscape
Purkey’s rapid default judgment illustrates how design IP paired with Schedule A tactics can neutralise entire counterfeit networks on major platforms simultaneously.
Design patents are potent weapons against e-commerce counterfeiting
USD0787124S — a design patent covering the ornamental appearance of a hair lifting and styling device — formed the backbone of a successful multi-platform enforcement action. Design patents are often underutilised by consumer product companies; this case illustrates their value in securing broad injunctions and statutory damages without needing to prove functionality.
Asset-freezing orders reach across global payment infrastructure
The court’s order captured funds held by PayPal, Stripe, Payoneer, LianLian, and marketplace escrow accounts on Amazon, Alibaba, and others — all within a 14-day compliance window. IP holders pursuing anonymous counterfeiters should ensure their complaints identify all major payment processors by name to maximise the reach of any asset-freezing relief.
Purkey v Partnerships — key questions answered
The Northern District of Illinois entered a final default judgment in favour of Purkey Enterprises, LLC on October 10, 2025. All named defendants were deemed in default. The court awarded $100,000 in statutory damages per defaulting defendant for willful trademark and copyright infringement, issued a permanent injunction, and ordered domain transfer and asset seizure across major e-commerce platforms and payment processors.
Purkey Enterprises asserted U.S. design patent USD0787124S (application no. 29/534498), which protects the ornamental design of a hair lifting, retention, and styling device. The case also involved trademark and copyright claims in connection with the same product, collectively referred to in the judgment as ‘Plaintiff’s Intellectual Property.’
The court awarded $100,000 per defaulting defendant under 15 U.S.C. § 1117(c)(2) (Lanham Act willful trademark infringement maximum) and 17 U.S.C. § 504(c)(2) (Copyright Act willful infringement maximum). The award applies once per defendant even if that defendant operated under multiple aliases in the complaint and Schedule A.
The judgment bound Amazon, eBay, Etsy, Alibaba/AliExpress, DHgate, Shein, Temu (PDD Holdings), and Walmart as third-party marketplace providers, and PayPal, Stripe, Payoneer, LianLian, and Alipay as payment processors. Each was ordered to freeze defendant accounts and remit funds to Purkey within seven to fourteen days of receipt of the order.
Yes, but the bar is high. A defaulting defendant may move to vacate under Fed. R. Civ. P. 55(c) and 60(b) by demonstrating good cause, a meritorious defence, and absence of culpable conduct. Given the willfulness finding embedded in the $100,000 per-defendant statutory award, successfully rebutting the willfulness characterisation would be a prerequisite to any meaningful damages reduction on vacatur.
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