In a swift enforcement action before the U.S. District Court for the Northern District of Illinois, Shenzhen Yihong Lighting Co., Ltd. secured a default judgment against multiple e-commerce defendants found to have infringed U.S. Design Patent No. USD959,683, covering a red light therapy belt. Filed on December 12, 2023, and resolved by July 16, 2024—just 217 days later—the case concluded after named defendants DooYoung, Eynshoo, GALMAX, and Zhangzhou Meizi Electronic Technology Co., Ltd. failed to appear or respond. The court awarded total profits as damages, based on admissions arising from defendants’ failure to answer discovery, encompassing 1,208 combined units of infringing products sold.

This case exemplifies the growing wave of Amazon marketplace design patent enforcement actions targeting Chinese sellers, and illustrates how U.S. design patent holders can leverage the Schedule A complaint mechanism and e-service procedures to obtain rapid injunctive and monetary relief. IP counsel, in-house patent teams, and product engineers operating in the consumer wellness and phototherapy device space should take note of both the litigation strategy employed and the scope of the patent claims at issue.

Case Overview

The Parties

The Patent at Issue

U.S. Design Patent No. USD959,683 (application no. 29/781,516) protects the ornamental appearance of a red light therapy belt—a wearable consumer wellness device that emits therapeutic near-infrared or red light for pain relief and recovery. The patent claims the specific visual design elements of the belt, including its shape, panel layout, and overall aesthetic configuration, rather than its functional operation. Real-world applications include consumer health and wellness products sold through major e-commerce platforms such as Amazon.

• • USD0959683S

Legal Representation

Plaintiff Counsel: Ni Law Firm PLLC; Ni, Wang & Massand, PLLC (lead: Nicholas Edward Najera)

Litigation Timeline & Procedural History

The case was filed on December 12, 2023 in the U.S. District Court for the Northern District of Illinois—a jurisdiction frequently selected for Schedule A e-commerce enforcement actions due to its established procedures for anonymous defendant identification, electronic service, and rapid preliminary injunction practice. Presiding Chief Judge Sunil R. Harjani oversaw the proceedings at the first-instance district court level, where trial courts have authority to grant injunctions, enter default judgments, and award damages without appellate review at the outset.

The case resolved in just 217 days—a notably fast resolution attributable entirely to the defendants’ failure to appear. Following proper electronic service via publication and email, the court granted a preliminary injunction early in the proceedings, freezing defendants’ assets and marketplace activity. Because no defendants answered or contested the claims, the court entered default and subsequently default judgment under Fed. R. Civ. P. 55, deeming all complaint allegations admitted. The defendants’ failure to respond to discovery requests for production and requests for admission further resulted in deemed admissions of patent validity, infringement, and entitlement to total profit damages—eliminating any need for trial.

The Verdict & Legal Analysis

Outcome

The Northern District of Illinois entered default judgment in favor of Shenzhen Yihong Lighting Co., Ltd. against defendants DooYoung, Eynshoo, GALMAX, and Zhangzhou Meizi Electronic Technology Co., Ltd. The court awarded total profits as the measure of damages, calculated based on defendants’ deemed admission that a combined 1,208 units of infringing red light therapy belts had been sold. A preliminary injunction had already been granted earlier in the proceedings, and no determination of invalidity, non-infringement, or any affirmative defense was reached, as defendants never appeared.

Verdict Cause Analysis

The default judgment rested on several distinct legal findings that the court articulated in its July 16, 2024 order:

• Personal jurisdiction over the defendants was established because they operated interactive e-commerce storefronts targeting U.S. and Illinois consumers, offered shipping to Illinois, and screenshot evidence confirmed prior sales of infringing goods to Illinois residents.
• Design patent infringement under 35 U.S.C. § 289 was supported by side-by-side comparisons demonstrating that the accused products’ designs were substantially similar to the ornamental design claimed in USD959,683.
• Defendants’ failure to respond to Plaintiff’s First Set of Requests for Production and Requests for Admission resulted in deemed admissions that the asserted patent is valid, that defendants sold 1,208 units of accused products, and that plaintiff is entitled to total profits as damages.
• Electronic service via publication and email was found constitutionally sufficient to satisfy due process notice requirements, consistent with established Schedule A enforcement practice in the Northern District of Illinois.

Legal Significance

1. 1. This case reinforces that design patent holders can obtain total profit disgorgement under 35 U.S.C. § 289 through the deemed admissions mechanism when defendants fail to participate in discovery, bypassing the need for a damages trial or expert testimony.
2. 2. The court’s acceptance of screenshot evidence and rapid shipping times as a basis for personal jurisdiction over foreign e-commerce sellers continues to lower the evidentiary threshold for establishing Illinois contacts in Schedule A actions, a trend with implications for all marketplace-based IP enforcement.
3. 3. The preliminary injunction granted early in this case likely resulted in Amazon account suspensions and asset freezes for the named defendants, demonstrating that design patent holders can achieve practical marketplace exclusion well before any final judgment is entered.

Strategic Takeaways

For Patent Attorneys:

• Ensure your Schedule A complaints include robust screenshot evidence of defendant storefronts offering shipping to the forum state—courts in the Northern District of Illinois increasingly rely on this to establish personal jurisdiction over foreign e-commerce sellers without physical presence.
• Pair your infringement complaints with immediate requests for admission and production targeting unit sales and revenue figures; defendants’ failures to respond will trigger deemed admissions that can substitute entirely for damages discovery and expert analysis.
• File motions for preliminary injunction simultaneously with or immediately after complaint filing in design patent Schedule A cases to leverage marketplace platform (e.g., Amazon) enforcement mechanisms that freeze defendant accounts and assets before they can transfer funds offshore.
• When prosecuting design patents for consumer products sold on e-commerce platforms, ensure the claimed ornamental design is depicted from multiple angles and in context of use to maximize the scope of the ‘substantially similar appearance’ comparison available at the default judgment stage.

For IP Professionals:

• Maintain an active monitoring program for your design-patented consumer products on Amazon, Walmart Marketplace, and similar platforms—this case demonstrates that early detection of infringing listings enables rapid Schedule A enforcement actions that can be fully resolved within a single calendar year.
• Evaluate whether your company’s consumer product design portfolio includes registered U.S. design patents; the total profits remedy available under 35 U.S.C. § 289 and the streamlined default judgment pathway in the Northern District of Illinois make design patents a particularly cost-effective enforcement tool against marketplace sellers.

For R&D Teams:

• If you are developing wearable phototherapy or red light therapy products for the U.S. market, conduct a freedom-to-operate analysis against USD959,683 before finalizing your product’s visual design—the ‘substantially similar appearance’ standard used in design patent infringement is broader than utility patent claim scope and can capture products that function differently but look alike.
• Consider documenting design choices and design-around decisions during product development; if your product’s ornamental design was intentionally differentiated from a competitor’s patented design, this contemporaneous documentation can serve as critical evidence in any future infringement dispute.