Songchao Chen v. Schedule A Defendants: Default Judgment on Makeup Sponge Holder Design Patent
Plaintiff Songchao Chen secured a final default judgment against four Amazon marketplace sellers — Etsetra, KACCA-Y, Sarik-Store, and SOCOPLY — for infringing design patent USD975924S covering a makeup sponge holder. The Florida Southern District Court issued a permanent injunction and ordered disgorgement of infringer profits, with Amazon Pay directed to release frozen funds to the plaintiff within ten business days.
Amazon marketplace sellers held liable for makeup sponge holder design infringement
On August 10, 2023, Songchao Chen filed suit in the U.S. District Court for the Southern District of Florida against a group of anonymous online sellers identified on a Schedule A — a litigation format commonly used to pursue multiple e-commerce infringers simultaneously. The asserted patent, USD975924S (application no. US29/834329), protects the ornamental design of a makeup sponge holder. The four defendants — Etsetra, KACCA-Y, Sarik-Store, and SOCOPLY — were alleged to have sold infringing products through Amazon and other online marketplaces.
The case closed on May 22, 2025, when Judge Rodney Smith entered a final default judgment in favor of Songchao Chen. Because the defendants failed to appear or respond, the court accepted the plaintiff’s allegations as admitted and granted the full relief requested: a permanent injunction prohibiting further manufacture, import, promotion, sale, or distribution of infringing products, and an award of the defendants’ profits derived from infringing Amazon sales. Third-party providers including Amazon Pay were ordered to freeze and release defendant funds within ten business days.
At 651 days, the timeline is consistent with Schedule A enforcement actions where defendants are often unresponsive, requiring the plaintiff to pursue TRO, asset freezes, and eventually default procedures. The public record does not disclose the precise quantum of profits awarded — Exhibit A detailing the damages figures is referenced but not reproduced in the judgment text. What remains unknown is whether any of the four named defendants subsequently moved to vacate the default or whether full recovery was achieved from the frozen Amazon Pay accounts.
Filing to Default Judgment in 651 days
651 days from filing to default judgment — typical for Schedule A e-commerce enforcement actions
Default judgment entered: what the ruling means for both parties
Default judgment: liability established without a merits contest
A final default judgment is entered when defendants fail to appear or defend. The court treats the plaintiff’s well-pleaded allegations as admitted, meaning infringement of USD975924S was never contested on the merits. The judgment is legally binding and enforceable, but differs from a litigated verdict — defendants may, within limits, move to vacate under Fed. R. Civ. P. 55(c) if they can show good cause.
No merits adjudicationPermanent injunction and profit disgorgement secured
Songchao Chen obtained the broadest available civil IP relief: a permanent injunction barring all future infringing activity, an order requiring Amazon Pay to release frozen seller funds as partial damages, and ongoing authority to serve the order on newly discovered accounts. This suggests an effective enforcement model — asset freezes imposed early via TRO are converted into final recovery without requiring a damages trial.
Injunction + profits recoveredNon-appearance leaves defendants fully exposed with no appeal path
By failing to appear, Etsetra, KACCA-Y, Sarik-Store, and SOCOPLY forfeited all defences — including invalidity, non-infringement, and independent creation. Their Amazon Pay accounts are subject to immediate release to plaintiff. Without vacating the default, they cannot appeal the merits. This outcome is commercially catastrophic for ongoing sellers: marketplace listings disabled, funds seized, and permanent injunction enforceable globally through third-party providers.
Funds seized, listings disabledSchedule A enforcement remains a high-leverage tool against e-commerce infringers
This case reinforces the effectiveness of the Schedule A litigation model for design patent holders targeting Amazon third-party sellers. By combining TROs, e-mail service, and platform cooperation from Amazon, rights holders can freeze assets and obtain judgment without physical service. For sellers operating on Amazon with competing makeup or beauty accessory designs, this ruling signals that non-response carries severe financial and operational consequences.
E-commerce design enforcementFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Songchao Chen | Individual | Individual design patent holder — holder of USD975924S (makeup sponge holder)Search in Eureka ↗ |
| Defendant | The Individuals, Partnerships and Unincorporated Associations Identified On Schedule ‘ A ‘ | Individual | Amazon marketplace sellers Etsetra, KACCA-Y, Sarik-Store, and SOCOPLY, alleged infringersSearch in Eureka ↗ |
| Plaintiff counsel | Andrew Jonathan Palmer | Attorney | Counsel for Songchao ChenSearch in Eureka ↗ |
| Plaintiff law firm | Palmer Law Group PA | Law Firm | Representing Songchao ChenSearch in Eureka ↗ |
| Presiding judge | Judge Rodney Smith | Judge | Florida Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The default judgment’s scope is notably broad: it extends the injunction to affiliates, agents, and confederates of the defaulting defendants, and grants the plaintiff prospective authority to serve the order on newly identified accounts — effectively creating a rolling enforcement mechanism. The court’s reliance on e-mail service and third-party provider cooperation reflects established Schedule A procedure in this district. Because no defendant appeared, the validity and scope of USD975924S were not adjudicated on the merits, leaving the patent legally unweakened for future enforcement actions.
USD975924S — Ornamental Design for a Makeup Sponge Holder
USD975924S (application no. US29/834329) is a U.S. design patent protecting the ornamental appearance of a makeup sponge holder — the visual and aesthetic configuration of the product rather than its functional attributes. Design patents in this category typically claim the specific shape, contours, and surface ornamentation shown in the patent drawings. Protection is narrower than a utility patent but enforced under the ‘ordinary observer’ test: infringement is found where an ordinary consumer would mistake the accused product for the patented design.
In the highly competitive beauty accessories category on Amazon, design patents serve as a primary differentiator and enforcement tool. A registered design provides rights holders with the ability to pursue TROs and asset freezes rapidly — as demonstrated in this case — without the extended claim construction disputes typical of utility patent litigation. For competing sellers, the existence of an active design patent on a makeup sponge holder signals that product sourcing decisions require design clearance, particularly where supplier catalogues offer visually similar SKUs at scale.
Should your team run an FTO against USD975924S?
Any company sourcing, importing, or selling makeup sponge holders or visually similar beauty accessory products on U.S. e-commerce platforms — particularly Amazon — should treat USD975924S as a live enforcement risk. This case demonstrates that the rights holder is actively monitoring the marketplace and willing to pursue multiple sellers simultaneously through a well-established Florida Southern District enforcement template. Product teams planning new SKU launches in the beauty tools category should commission a design patent FTO before listing.
PatSnap Eureka’s FTO Search Agent can map the visual scope of USD975924S against your product designs, surface design patent family members, and identify prior art that could inform an invalidity argument if needed. Eureka also tracks the litigation history of Schedule A plaintiffs, helping your team assess enforcement frequency and prioritise clearance resources. Run a targeted FTO now to quantify exposure before your next Amazon product launch.
Run a freedom-to-operate analysis on USD0975924S to assess your product’s exposure
Run FTO in Eureka →Similar design patent Schedule A cases in Florida Southern District
Cases involving design patent enforcement against Amazon Schedule A sellers in Florida Southern District, covering beauty and personal care accessories.
What this case signals for the beauty accessories IP landscape
Default judgment enforcement via Amazon Pay demonstrates design patent holders’ growing leverage over anonymous e-commerce sellers.
Design patents are potent in Schedule A e-commerce enforcement
USD975924S illustrates how ornamental design patents — often underestimated — can generate injunctions, asset freezes, and profit disgorgement against multiple sellers simultaneously. Rights holders with registered designs in beauty and personal care should audit their portfolio for Schedule A readiness.
Amazon Pay cooperation converts TROs into near-immediate financial recovery
The judgment’s ten-business-day fund release mechanism, directed at Amazon Pay, shows that platform financial infrastructure is now a core enforcement channel. Companies monitoring competitive sellers on Amazon should track TRO activity in Florida Southern District as an early signal of enforcement intent.
Chen v Individuals — key questions answered
The Florida Southern District Court entered a final default judgment in favor of plaintiff Songchao Chen on May 22, 2025. The court issued a permanent injunction against defendants Etsetra, KACCA-Y, Sarik-Store, and SOCOPLY, and ordered disgorgement of profits from infringing sales of makeup sponge holders on Amazon.
The asserted patent is USD975924S (application no. US29/834329), a U.S. design patent covering the ornamental design of a makeup sponge holder. Design patents protect the visual appearance of a product rather than its functional features, and infringement is assessed under the ordinary observer test.
The default judgment means the four named defendants — who failed to appear — are permanently enjoined from selling infringing products and must surrender profits held in Amazon Pay accounts. Amazon and other third-party providers were ordered to disable listings and release frozen funds to the plaintiff within ten business days. The plaintiff also retains ongoing authority to serve the order on newly discovered seller accounts.
Schedule A litigation allows a single plaintiff to sue multiple anonymous e-commerce sellers in one action by listing them on a schedule rather than naming each individually. Combined with TROs, e-mail service, and platform cooperation, it enables rapid asset freezes and injunctions. Florida Southern District Court is a frequent venue for this type of action due to established local procedure and judicial familiarity with the format.
No. Because all four defendants defaulted and failed to appear, the validity and scope of USD975924S were never contested on the merits. The patent exits the litigation fully intact, with no invalidity findings, claim narrowing, or prosecution history estoppel arising from the proceedings. This strengthens the patent’s enforceability in any future actions.
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