Shenzhen JianYuanDa v. Annex A Defendants: Default Judgment in 175 Days
Shenzhen JianYuanDa Mirror Technology secured a default judgment against a group of anonymous e-commerce sellers accused of infringing design patent USD934576S, covering a mirror product. Judge Pallmeyer in the Northern District of Illinois granted permanent injunctions, domain transfers, asset freezes, and damages ranging from $20,000 to $200,000 per defendant across ten named online storefronts.
Design patent default judgment targets online mirror counterfeiters
Filed on 22 August 2024 in the Northern District of Illinois, this action was brought by Shenzhen JianYuanDa Mirror Technology Co., Ltd. against a set of anonymous defendants identified only in Annex A — a common enforcement tactic targeting e-commerce sellers operating across platforms such as Amazon, AliExpress, eBay, and Wish.com. The asserted patent, USD934576S (application number 29/746639), is a U.S. design patent covering the ornamental appearance of a mirror product. The plaintiff was represented by Ge Lei of Getech Law LLC.
With no defendant appearing or filing any response, JianYuanDa moved for entry of default and default judgment. Judge Rebecca R. Pallmeyer granted the motion on 13 February 2025, 175 days after filing. The court issued a permanent injunction barring further manufacture, distribution, and sale of infringing products, and ordered domain name registries and third-party payment processors — including PayPal, Alipay, Amazon Pay, and Alibaba — to freeze and release defendant funds within seven to fourteen days. Compensatory damages were assessed individually: $200,000 against Puiuisoul Stores and Koolstuffs; $75,000 each against Keyfisher, Ebaicycle, and ChaoYueLin; $40,000 against Fuyan sport; and $20,000 each against Wototic us, Maoyun, Unplug Studios, and fei99Long.
The 175-day resolution is consistent with uncontested default proceedings, where no substantive merits dispute arises. The public record does not reveal whether any defendant was ultimately located, whether assets were actually recovered, or the total funds held in frozen accounts. The willful infringement finding under 35 U.S.C. § 284 suggests the court accepted the plaintiff’s damages framing without adversarial challenge, which is typical but means the award quantum was not independently tested. What remains unknown is whether the named storefronts are related entities or independent operators, and whether supplemental proceedings to recover full damages were ever initiated.
Filing to Default Judgment in 175 days
175 days — resolved faster than the median N.D. Illinois patent case, consistent with uncontested default proceedings
Default judgment granted: what the order means for both parties
Default judgment: liability without a merits fight
A default judgment under Federal Rule of Civil Procedure 55 is entered when a defendant fails to appear or respond. The court accepts the plaintiff’s well-pleaded allegations as true and may award the requested relief. Here, all ten named defendants failed to contest the action, so infringement and willfulness were deemed admitted. This is procedurally final but practically difficult to enforce against anonymous offshore sellers.
FRCP 55 default judgmentPermanent injunction and asset freeze secured
JianYuanDa obtained a sweeping permanent injunction, domain transfer authority, and orders freezing and releasing funds held by PayPal, Alipay, Amazon Pay, and Alibaba. The court also granted ongoing authority to commence supplemental asset-discovery proceedings. In practice, the enforceability of the money judgment depends on whether sufficient funds were actually frozen before defendants could move assets — a common limitation in anonymous seller litigation.
Injunction + asset recoveryDefendants deemed liable by default — no recourse without vacatur
Defaulting defendants have limited options post-judgment. To challenge the order, a defendant would need to move to vacate the default judgment under FRCP 60(b), demonstrating a meritorious defence, good cause for non-appearance, and lack of prejudice to the plaintiff. Given the typical profile of anonymous e-commerce sellers in these cases, such a motion is rarely filed. The judgment stands unless actively contested.
FRCP 60(b) vacatur path onlyMarketplace platforms face direct obligations under this order
The order explicitly names Amazon, eBay, AliExpress, Alibaba, Wish.com, and payment processors as third-party providers with compliance obligations within seven days. This structure — increasingly standard in N.D. Illinois anonymous seller cases — effectively deputises platforms as enforcement agents. Sellers operating mirror or consumer décor products on these platforms should treat this judgment as a signal that design patent enforcement via default is an active and low-friction strategy for Chinese OEM rights holders.
Platform enforcement obligationsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Shenzhen JianYuanDa Mirror Technology Co., Ltd. | Company | Chinese mirror manufacturer — holder of design patent USD934576SSearch in Eureka ↗ |
| Defendant | The Entities and Individuals Identified in Annex A | Individual | Anonymous e-commerce sellers identified in Annex A, operating online storefronts across major marketplacesSearch in Eureka ↗ |
| Plaintiff counsel | Ge Lei | Attorney | Counsel for Shenzhen JianYuanDa Mirror Technology Co., Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Getech Law LLC | Law Firm | Representing Shenzhen JianYuanDa Mirror Technology Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Rebecca R. Pallmeyer | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment order is expansive in both injunctive scope and enforcement mechanism. By naming specific domain registrars, marketplace platforms, and payment processors as obligated third parties, the court created a multi-channel enforcement structure that does not depend on locating the defendants directly. The per-defendant damages — ranging from $20,000 to $200,000 — reflect a tiered approach presumably based on estimated sales volume or platform presence, though the public record does not disclose the methodology. Because no defendant appeared, the damages quantum was accepted without cross-examination or expert challenge, which is standard in default proceedings but means the award reflects the plaintiff’s framing rather than an adversarially tested figure.
USD934576S — Ornamental mirror design (App. No. 29/746639)
USD934576S is a U.S. design patent filed under application number 29/746639, covering the ornamental appearance — not functional features — of a mirror product. Design patents in the consumer goods space are granted for novel and non-obvious visual designs as applied to an article of manufacture. The ‘USD’ prefix designates a U.S. design patent, which has a term of 15 years from grant. Infringement is assessed using the ‘ordinary observer’ test: whether an ordinary consumer would find the accused product substantially similar in overall appearance to the patented design.
For a Chinese OEM with a distinctive mirror design sold internationally, USD934576S represents a relatively low-cost but strategically potent IP asset. Design patents in the home décor and consumer mirror sector are increasingly used by both domestic and foreign manufacturers to police e-commerce listings on Amazon, Alibaba, and similar platforms. Competitors offering visually similar mirrors — even if functionally different — face infringement exposure. The case signals that JianYuanDa is actively monitoring and enforcing this design right, raising the stakes for any brand sourcing visually similar mirror products from undisclosed manufacturers.
Should your team run an FTO against USD934576S?
Any company sourcing, importing, or selling mirrors through U.S. e-commerce channels — particularly on Amazon, eBay, or AliExpress — should evaluate whether its product designs could be considered substantially similar to the ornamental design claimed in USD934576S. This is especially relevant for private-label brands, wholesale distributors, and product aggregators sourcing from Chinese manufacturers, where design provenance may be unclear. The ordinary observer standard means even minor visual overlaps can create infringement risk.
PatSnap Eureka’s FTO Search Agent can map the claim scope of USD934576S against your product portfolio, flag visually similar design patents in the mirror and home décor space, and identify prior art that could support an invalidity argument if needed. For sourcing teams and product managers, an early-stage FTO analysis is significantly cheaper than defending a default judgment action — or worse, being named in a future Annex A complaint.
Run a freedom-to-operate analysis on USD0934576S to assess your product’s exposure
Run FTO in Eureka →Similar design patent enforcement cases in N.D. Illinois e-commerce litigation
Cases involving anonymous e-commerce seller defendants, design patent infringement, and default judgments in the Northern District of Illinois consumer goods space.
What this case signals for the e-commerce design patent IP landscape
Anonymous-seller default judgments in N.D. Illinois are a mature enforcement template — but the practical limits of recovery matter as much as the legal win.
N.D. Illinois is an established venue for anonymous e-commerce IP enforcement
The Northern District of Illinois has become a preferred venue for Chinese IP holders pursuing Annex A-style actions against anonymous online sellers. The court’s familiarity with the procedural template — TRO, asset freeze, default judgment — means cases can move quickly when defendants fail to appear. Patent owners in the consumer goods space should evaluate this venue when planning enforcement campaigns.
Design patents on ornamental products offer fast, low-cost enforcement leverage
USD934576S is a design patent, not a utility patent — the infringement analysis focuses on visual similarity, not functional claims. This makes it easier to plead and harder for sellers to design around. For product companies with distinctive mirror or décor aesthetics, filing design patents and monitoring marketplace listings is a commercially efficient protection strategy with a credible enforcement path.
Shenzhen v Entities — key questions answered
The Northern District of Illinois granted plaintiff Shenzhen JianYuanDa Mirror Technology’s motion for default judgment on 13 February 2025. All named defendants were deemed in default, a permanent injunction was issued, domain names were subject to transfer, and damages of $20,000–$200,000 per defendant were awarded under 35 U.S.C. § 284 for willful infringement of design patent USD934576S.
USD934576S (App. No. 29/746639) is a U.S. design patent covering the ornamental appearance of a mirror product. JianYuanDa asserted it against anonymous e-commerce sellers allegedly selling visually similar mirror products without authorisation across platforms including Amazon, AliExpress, eBay, and Wish.com. Design patents protect visual design, not function, and infringement is assessed under the ordinary observer test.
The court awarded per-defendant compensatory damages under 35 U.S.C. § 284: $200,000 against Puiuisoul Stores and Koolstuffs; $75,000 against Keyfisher, Ebaicycle, and ChaoYueLin; $40,000 against Fuyan sport; and $20,000 each against Wototic us, Maoyun, Unplug Studios, and fei99Long. The methodology was not publicly disclosed in the order, and the amounts were unchallenged due to the defendants’ non-appearance.
Yes, a defaulting defendant could move to vacate the default judgment under Federal Rule of Civil Procedure 60(b), but must demonstrate good cause for the failure to appear, a meritorious defence to the infringement claims, and absence of prejudice to the plaintiff. This is a high bar, and in anonymous e-commerce enforcement cases, such motions are rarely filed in practice.
The order requires named third-party providers — including Amazon, eBay, AliExpress, Alibaba, Wish.com, PayPal, Alipay, and Amazon Pay — to within seven days freeze and release defendant funds, disable online marketplace accounts used to sell infringing goods, and cease displaying associated advertisements. Domain registrars including GoDaddy, Namecheap, and Name.com are ordered to transfer or disable defendant domain names. Non-compliance with a court order of this type can expose platforms to contempt proceedings.
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