Ring Holder Design Patent Yields $1.8M+ Default Judgment Against Global E-Commerce Infringers

In a sweeping default judgment entered September 10, 2025, the U.S. District Court for the Northern District of Illinois awarded Raynara, LLC over $1.84 million in total damages against more than 100 online sellers operating across Amazon, eBay, DHgate, and Wish — all found to have willfully infringed U.S. Design Patent No. USD765,662 covering a “Ring Holder Attachable to Phone Case.”

Case No. 1:24-cv-05973, presided over by Chief Judge Andrea R. Wood, closed after approximately 415 days with a permanent injunction and profit disgorgement orders binding on defendants, their payment processors, and major marketplace platforms simultaneously. The case offers a textbook example of the “Schedule A” enforcement model — a litigation strategy that has become a cornerstone of IP enforcement against anonymous offshore e-commerce sellers.

For patent attorneys, IP managers, and R&D teams operating in the consumer electronics accessories space, this outcome signals continued judicial receptivity to aggressive design patent enforcement against diffuse, pseudonymous marketplace infringers.

Case Overview

The Parties

The Patent at Issue

This case involved a key design patent protecting a popular consumer electronics accessory:

• • Patent Number: USD765,662 (Application No. US29/568,008)
• • Title: “Ring Holder Attachable to Phone Case”
• • Type: U.S. Design Patent
• • Scope: Protects the specific visual design of a ring-style grip holder attachable to a smartphone case.

Legal Representation

Plaintiff’s Counsel: Kevin John Keener of Keener & Associates PC — a firm with recognized experience in Schedule A patent and trademark enforcement litigation in the Northern District of Illinois.

Defendant Counsel: None entered. All defaulting defendants failed to appear.

Litigation Timeline & Procedural History

The case proceeded through the Northern District of Illinois — a jurisdiction that has become a preferred venue for Schedule A IP enforcement actions, owing to its experienced judiciary, procedural efficiency with anonymous defendant cases, and willingness to authorize ex parte asset restraints coordinated with third-party platforms.

The 415-day total duration reflects the standard arc for uncontested Schedule A litigation: initial filings, service by electronic publication and email, failure of defendants to appear, and ultimately an uncontested default judgment proceeding. The absence of adversarial litigation substantially compressed the merits phase.

Chief Judge Andrea R. Wood’s involvement lends additional institutional weight to the findings, particularly the jurisdictional analysis and willfulness determination.

The Verdict & Legal Analysis

Outcome

The court granted Raynara’s Motion for Default Judgment in full, entering:

• Permanent injunctive relief against all defaulting defendants and any persons acting in concert with them
• Profit disgorgement damages under 35 U.S.C. § 289, totaling approximately $1.84 million across all defendants
• Third-party platform orders binding Amazon, eBay, PayPal, Wish Holdings, and Amazon Pay to freeze and release restrained funds to Plaintiff within 14 calendar days
• Ongoing supplemental proceedings authority under FRCP 69 until full satisfaction of judgment

Notable individual damage awards included:

• Exoer (Amazon): $985,181.93 — the single largest award
• Libosa (Amazon): $394,020.06
• Vesmatity Stores (Amazon): $290,878.05
• Double Shine (Wish): $25,205.51
• jcbufa1 (Amazon): $49,230.53

Approximately 80 defendants received the statutory floor award of $250.00 each, reflecting minimal or undetectable sales activity.

Willfulness Finding

The court made an express finding of willful infringement, citing defendants’ deliberate use of seller aliases and active concealment of their identities. The court characterized their conduct as “egregious, willful, wanton, malicious, and deliberate” — language carrying significant weight under Halo Electronics, Inc. v. Pulse Electronics, Inc., 579 U.S. 93 (2016), which established a subjective recklessness standard for enhanced damages eligibility.

While the court awarded actual profits under § 289 rather than enhanced damages in this default context, the willfulness finding preserves Raynara’s remedial posture for any supplemental enforcement.

Jurisdictional Analysis

In the absence of adversarial presentation, the court independently analyzed personal jurisdiction, concluding that defendants targeting U.S. consumers — particularly Illinois residents — through marketplace storefronts offering U.S. shipping satisfied the minimum contacts standard. This analysis reinforces the Northern District of Illinois’s established framework for asserting jurisdiction over anonymous offshore sellers.

Legal Significance: Section 289 and Design Patent Damages

The damages calculation under 35 U.S.C. § 289 — which entitles design patent holders to the infringer’s total profits from the sale of any article embodying the patented design — is a particularly powerful enforcement tool. Unlike utility patent damages, § 289 does not require apportionment to the patented feature’s contribution to overall product value, as reaffirmed in Samsung Electronics Co. v. Apple Inc., 580 U.S. 53 (2016).

The variance in awards — from $985,181.93 to $250.00 — directly reflects each defendant’s documented sales volume, underscoring the importance of thorough pre-judgment sales data discovery from marketplace platforms.

Strategic Takeaways

For Patent Holders:

• Design patents on consumer product accessories can be effectively enforced at scale through Schedule A litigation when robust ornamental distinctiveness exists.
• Coordinating asset restraint orders with marketplace platforms before defendants can liquidate accounts is operationally critical.
• Profit disgorgement under § 289 creates significant leverage even against small-volume sellers.

For Accused Infringers:

• Failure to appear guarantees adverse judgment. Even a minimal responsive filing can disrupt default judgment timelines and create negotiation opportunities.
• Marketplace platform agreements typically compel cooperation with court orders — assuming your account funds are frozen, challenging the order through intervention is the only available remedy.

For R&D Teams & Product Developers:

• Freedom-to-operate (FTO) searches must include design patent clearance, not solely utility patents, particularly in high-volume accessory categories.
• Products with distinctive ornamental features targeting the U.S. market should be cleared against active design patent portfolios before listing on major marketplaces.

Industry & Competitive Implications

The mobile phone accessories market — encompassing ring holders, cases, grips, and mounts — generates billions in annual U.S. e-commerce revenue, with a substantial portion flowing through marketplace sellers based in China and Southeast Asia. This case reflects an accelerating trend: design patent holders are systematically deploying Schedule A enforcement campaigns to protect market share against anonymous online competitors.

The simultaneous restraint of assets across Amazon, eBay, Wish, and PayPal demonstrates that coordinated multi-platform enforcement is now procedurally routine in the Northern District of Illinois. Companies operating in this space — whether as brand owners or marketplace sellers — should treat design patent exposure as a primary commercial risk, not a secondary concern subordinate to utility patent strategy.

For IP portfolio managers, this case reinforces the return-on-investment case for design patent prosecution: USD765,662 was a single design patent generating over $1.84 million in court-ordered recovery against 100+ defendants, with platform-enforced asset collection.

FAQ

What patent was involved in Raynara, LLC v. Schedule A Defendants?

U.S. Design Patent No. USD765,662, titled “Ring Holder Attachable to Phone Case” (Application No. US29/568,008), covering the ornamental design of a ring-style phone grip accessory.

What was the basis for the default judgment in Case No. 1:24-cv-05973?

All defendants failed to answer or appear. The court found valid service by electronic publication and email, and deemed the complaint’s infringement allegations admitted under FRCP 55.

How might this verdict affect design patent litigation in the mobile accessories space?

It reinforces the viability of Schedule A enforcement campaigns as a scalable, cost-efficient enforcement mechanism for design patent holders facing diffuse online marketplace infringement.

For case documents, visit PACER and search Case No. 1:24-cv-05973 (N.D. Ill.). For the patent record, visit the USPTO Patent Full-Text Database.