Steel City Enterprises v. Schedule A Defendants: Default Judgment on Container Plug Design Patent
Steel City Enterprises, Inc. filed suit in the Northern District of Illinois against dozens of e-commerce sellers alleging infringement of USD977,973S, a design patent covering a container plug. After defendants failed to appear, Judge Jeffrey Cummings entered a final default judgment — resolving the case in 377 days without a contested merits ruling.
Mass e-commerce design patent action ends in uncontested default
Steel City Enterprises, Inc. filed this action on May 23, 2023, in the U.S. District Court for the Northern District of Illinois (Case No. 1:23-cv-03252) against a broad class of defendants identified on a Schedule A — a litigation strategy increasingly common in design patent enforcement against online marketplace sellers. The single patent asserted, USD977,973S (application no. US29/825986), covers the ornamental design of a container plug. Defendants included named sellers such as Amonsee, Astarexin, Davine Tech, FEIGO, Mlife City, Mxizi Store, Superbamboo, and numerous Chinese e-commerce entities.
The case closed on June 3, 2024, via a final default judgment entered by Judge Jeffrey I. Cummings. The court granted Steel City’s Motion for Entry of Final Default Judgment, formally deeming the Defaulting Defendants in default. This outcome arises when defendants fail to plead or otherwise defend the action — no merits adjudication of infringement or invalidity occurred. For Steel City, the judgment is an enforceable court order; for the defaulting sellers, it typically triggers injunctive relief and potential damages without any opportunity to contest liability.
The 377-day duration is broadly consistent with Schedule A default judgment timelines, which often involve extended service periods and preliminary injunction phases before default is entered. What remains unknown from the public record is the precise damages amount or injunctive scope awarded in the judgment, whether any named defendants appeared and were separately dismissed, and whether Steel City pursued enforcement against the underlying marketplace accounts. The volume of defendants — spanning dozens of storefronts — suggests a coordinated anti-counterfeiting or anti-knockoff campaign targeting online sales of the container plug design.
Filing to Default Judgment in 377 days
377 days — closed in just over a year, consistent with uncontested Schedule A design patent actions
Final default judgment: what the ruling means for both parties
Default judgment: liability without a merits contest
A final default judgment is entered when defendants fail to appear or respond to the complaint. The court accepts the plaintiff’s well-pleaded allegations as true and enters judgment accordingly. Crucially, no court has adjudicated whether USD977,973S is valid or actually infringed — the judgment reflects procedural default, not a finding on the merits. This distinction matters if Steel City seeks to assert collateral estoppel in future proceedings.
No merits adjudicationSteel City holds an enforceable judgment against all defaulting sellers
The default judgment gives Steel City an enforceable court order against each Defaulting Defendant. In Schedule A cases, this typically enables the plaintiff to seek platform takedowns, account freezes, and damages from funds held in escrow by marketplaces such as Amazon or eBay. Steel City can now pursue enforcement without further litigation — unless a defendant moves to vacate the default, which is procedurally possible but rarely successful absent extraordinary circumstances.
Enforceable against all defendantsDefaulting sellers face injunctions and damages with no path to contest
By failing to appear, each Defaulting Defendant waived the right to contest infringement or challenge the validity of USD977,973S. The judgment is binding. Defendants can move to vacate under Fed. R. Civ. P. 55(c) or 60(b) if they can show good cause or excusable neglect, but courts set a high bar. For foreign e-commerce operators, the practical consequence is likely marketplace account suspension and frozen revenue held on US platforms.
Waived right to contestSchedule A enforcement signals active design IP protection for container products
This case is consistent with a broader wave of Schedule A design patent actions filed in the Northern District of Illinois targeting marketplace sellers of consumer hardware and home goods. For any company selling container plug accessories online, this outcome signals that US design patent holders are actively monitoring and enforcing IP against third-party sellers. New market entrants should treat ornamental design clearance as a baseline pre-launch requirement.
Active enforcement postureFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Steel City Enterprises, Inc. | Company | Hardware/home goods IP holder — asserting USD0977973S covering container plug ornamental designSearch in Eureka ↗ |
| Defendant | The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on the Attached Schedule A | Individual | Dozens of e-commerce and marketplace sellers, predominantly China-based, identified on Schedule ASearch in Eureka ↗ |
| Co-Defendant | Amonsee | Individual | Search in Eureka ↗ |
| Co-Defendant | Astarexin | Individual | Search in Eureka ↗ |
| Co-Defendant | Davine Tech | Individual | Search in Eureka ↗ |
| Co-Defendant | dongren | Individual | Search in Eureka ↗ |
| Co-Defendant | FEIGO. | Individual | Search in Eureka ↗ |
| Co-Defendant | Mlife City | Individual | Search in Eureka ↗ |
| Co-Defendant | Mxizi Store | Individual | Search in Eureka ↗ |
| Co-Defendant | Others too numerous to list: shanghairongran dianzikejiyouxian gongsi, Jake.Secer Direct, nissim_store, sxp-us, shen zhen shi yuan meng dian zi ke ji you xian gong si, LKYADM, FEIXINXIN STORE, elix_store, Detiadar, soonbet, ANPPER Co Ltd, CHWM-US, acDesign, Hongzhi Store, goodstobest, hubeihsi, Shuifengshu Store, ShangHaiKuQinS hangMaoYouXian GongSi, bevillesjv93ka, keepshopping002, Aqziill, SPFX STORE, Flutaire US, Shiming E | Company | Search in Eureka ↗ |
| Co-Defendant | Superbamboo | Individual | Search in Eureka ↗ |
| Co-Defendant | Xinxiangyi Store | Individual | Search in Eureka ↗ |
| Plaintiff counsel | Benjamin Adam Campbell | Attorney | Counsel for Steel City Enterprises, Inc.Search in Eureka ↗ |
| Plaintiff counsel | Edward L. Bishop | Attorney | Counsel for Steel City Enterprises, Inc.Search in Eureka ↗ |
| Plaintiff counsel | Nicholas S. Lee | Attorney | Counsel for Steel City Enterprises, Inc.Search in Eureka ↗ |
| Plaintiff counsel | Sameeul Haque | Attorney | Counsel for Steel City Enterprises, Inc.Search in Eureka ↗ |
| Plaintiff law firm | Bishop Diehl & Lee, Ltd. | Law Firm | Representing Steel City Enterprises, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Jeffrey I Cummings | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order granting Steel City’s Motion for Entry of Final Default Judgment is a procedural disposition, not a merits ruling. The phrasing ‘deemed in default’ confirms that defendants forfeited their right to contest liability by failing to appear. This language is standard in N.D. Ill. Schedule A proceedings and does not constitute a judicial finding that USD977,973S is valid or that any defendant actually infringed — it reflects an unopposed acceptance of the plaintiff’s pleaded allegations. The enforceable judgment nonetheless carries full legal effect against each named Defaulting Defendant.
USD977,973S — Ornamental design for a container plug
USD977,973S (application no. US29/825986) is a US design patent protecting the ornamental appearance of a container plug. Design patents under 35 U.S.C. § 171 protect the visual, non-functional characteristics of an article of manufacture — in this case, the distinctive look of a plug designed for use with containers. Design patents have a term of 15 years from grant and are typically narrower in scope than utility patents, with infringement assessed under the ‘ordinary observer’ test established in Egyptian Goddess v. Swisa.
Despite their narrower scope, design patents have become a powerful enforcement tool in consumer hardware because they are relatively inexpensive to obtain and can be asserted against a wide range of visually similar products sold on e-commerce platforms. For the container accessories market, USD977,973S represents a potential barrier to entry for any seller whose product embodies a substantially similar ornamental design. The fact that Steel City successfully obtained default judgments against dozens of sellers in a single action suggests the patent covers a commercially significant product form that is being widely replicated in the market.
Should you run an FTO against USD977,973S before launching a container plug?
Any manufacturer, importer, or online seller of container plugs or closely related closure accessories targeting the US market should treat USD977,973S as a live clearance risk. This case demonstrates that the patent holder is actively enforcing — and that enforcement proceeds rapidly via default judgment in the Northern District of Illinois. A freedom-to-operate analysis should compare your product’s ornamental design against the patent’s drawings using the ordinary observer standard, not functional differentiation alone.
PatSnap Eureka’s FTO Search Agent can map USD977,973S against your product’s design, identify prior art that may bear on validity, and surface related design patent families that could indicate the breadth of Steel City’s IP portfolio. For teams launching physical products on Amazon or other US marketplaces, Eureka’s monitoring tools can flag new design patent filings in the container accessories space before they become enforcement risks — enabling proactive design-around strategies rather than reactive litigation responses.
Run a freedom-to-operate analysis on USD0977973S to assess your product’s exposure
Run FTO in Eureka →Similar container plug and Schedule A design patent cases in N.D. Illinois
Explore comparable Schedule A design patent enforcement actions filed in the Northern District of Illinois targeting e-commerce sellers of consumer hardware and container accessories.
What this case signals for the consumer hardware IP landscape
This default judgment illustrates how design patent holders can neutralise dozens of online infringers simultaneously without a single contested hearing.
Schedule A actions are now a primary enforcement tool against e-commerce counterfeiters
By bundling dozens of defendants under a single Schedule A complaint, rights holders like Steel City efficiently obtain injunctions and damages against marketplace sellers. The Northern District of Illinois has become the dominant venue for this strategy. Companies operating on Amazon, eBay, or similar platforms in consumer hardware categories face material exposure if design clearance has not been conducted.
Design patent default judgments create enforceable platform-level leverage
A final default judgment in a Schedule A case typically translates directly into marketplace account freezes and escrowed fund transfers — often without further litigation. For IP holders, this makes design patent filings a cost-efficient enforcement asset. For sellers, it means that ignoring a complaint is not a safe default: the cost of non-response is platform-wide suspension and potential damages.
Steel v Individuals — key questions answered
The Northern District of Illinois entered a final default judgment in favour of Steel City Enterprises on June 3, 2024, after all Defaulting Defendants failed to appear. The court granted Steel City’s Motion for Entry of Final Default Judgment, deeming defendants in default. No merits adjudication of infringement or validity occurred.
Steel City asserts USD977,973S (application no. US29/825986), a US design patent protecting the ornamental design of a container plug. Design patents cover the visual appearance of an article of manufacture and are enforced under the ordinary observer infringement test, not a functional or claim-by-claim analysis.
A Schedule A complaint bundles multiple defendants — typically e-commerce marketplace sellers — into a single action identified on an attached schedule rather than named individually in the caption. This procedural approach is widely used in the Northern District of Illinois to efficiently pursue design patent and trademark infringement against large numbers of online sellers, often operating from China.
Yes, in principle. A defaulting defendant may move to vacate under Fed. R. Civ. P. 55(c) or 60(b) by demonstrating good cause, a meritorious defence, and lack of prejudice to the plaintiff. However, courts apply a demanding standard, and in practice few e-commerce defendants successfully vacate default judgments. The window for such motions is limited, and foreign defendants face additional procedural hurdles.
In Schedule A proceedings, a final default judgment typically enables the plaintiff to seek injunctive relief, marketplace account deactivation, and transfer of funds held in escrow by platforms such as Amazon or eBay. This makes the judgment immediately commercially harmful to defaulting sellers even without further enforcement proceedings. The plaintiff can enforce the judgment against US-accessible assets without needing to pursue parallel proceedings in the defendants’ home jurisdictions.
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