Steel City Enterprises Wins Default Judgment in Design Patent Case
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📋 Case Summary
| Case Name | Steel City Enterprises, Inc. v. Schedule A Defendants |
| Case Number | 1:23-cv-06993 (N.D. Ill.) |
| Court | U.S. District Court for the Northern District of Illinois |
| Duration | Sep 2023 – Apr 2024 211 days |
| Outcome | Plaintiff Win — Default Judgment |
| Patents at Issue | |
| Accused Products | Counterfeit Jug Plug products |
Case Overview
The Parties
⚖️ Plaintiff
Owner of U.S. Design Patent No. D977,973 and manufacturer of genuine Jug Plug products, seeking to protect its intellectual property from unauthorized reproduction.
🚨 Defendants
A network of 13 online storefronts operating on platforms like Amazon, eBay, and Walmart, accused of selling products incorporating the protected ornamental design of Steel City’s Jug Plug.
The Patent at Issue
This case involved U.S. Design Patent No. D977,973, protecting the ornamental appearance of Steel City’s “Jug Plug” product. Design patents protect unique visual characteristics, distinct from functional elements, making enforcement a visually comparative exercise under the Egyptian Goddess standard.
- • US D977,973 — Ornamental design of the Jug Plug product.
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The Verdict & Legal Analysis
Outcome
The U.S. District Court for the Northern District of Illinois entered final default judgment against all 13 remaining defendants. The court found willful patent infringement of U.S. Design Patent D977,973 (Claim I) and awarded permanent injunctive relief, damages under both 35 U.S.C. § 284 (reasonable royalty) and § 289 (total profits), and attorney’s fees under 35 U.S.C. § 285.
The differential treatment of Red Deer Express, which faced § 289 total profits disgorgement ($27,938.88 plus fees) compared to the other 12 defendants assessed under the § 284 reasonable royalty standard ($4,666.67 each plus fees), highlights strategic calculations in design patent damages.
Key Legal Issues
The court’s willfulness finding flowed directly from the defendants’ default, deeming the factual allegations of willful infringement admitted without an evidentiary hearing. Personal jurisdiction was established based on defendants operating e-commerce storefronts targeting U.S. consumers, offering shipping to Illinois, and selling infringing products to Illinois residents.
The “exceptional case” finding under § 285 for attorney’s fees was predicated on willful infringement combined with the defendants’ complete failure to appear or contest the claims. This case reinforces the power of 35 U.S.C. § 289 for total profits disgorgement and the effectiveness of the “Schedule A” litigation strategy in the Northern District of Illinois against mass online infringers, including the validation of electronic service and early TRO-based asset freezes.
Freedom to Operate (FTO) Analysis
This case highlights critical IP risks in consumer product design within e-commerce. Choose your next step:
📋 Understand This Case’s Impact
Learn about the specific risks and implications from this litigation.
- View patent D977,973 and its prosecution history
- Analyze related design patents in the product category
- Understand damages calculations in default judgments
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High Risk Area
Ornamental designs of Jug Plug products
1 Design Patent
Specific to Jug Plug ornamental design
Design-Around Options
Available for distinct aesthetic elements
✅ Key Takeaways
The Northern District of Illinois remains a receptive venue for Schedule A design patent enforcement actions against e-commerce sellers.
Search related case law →§ 289 total profits and § 285 attorney’s fees together create a strong damages package in design patent default cases.
Explore damages precedents →Willfulness established via default eliminates the burden of proving subjective willfulness under Halo Electronics.
Analyze willfulness standards →Frequently Asked Questions
U.S. Design Patent No. D977,973 (Application No. 29/825,986), covering the ornamental design of the Jug Plug product.
Twelve defendants were assessed under 35 U.S.C. § 284 (reasonable royalty), while Red Deer Express was assessed under 35 U.S.C. § 289 (total profits disgorgement), reflecting documented sales volume that made the § 289 calculation more appropriate for that specific defendant.
The court found willful infringement combined with complete failure to appear by all defaulting defendants, a pattern consistently supporting exceptional case findings and attorney’s fee awards in this district.
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References
- PACER Case Lookup – Case No. 1:23-cv-06993
- U.S. Patent and Trademark Office — Design Patent Database
- Cornell Legal Information Institute — 35 U.S.C. § 284
- Cornell Legal Information Institute — 35 U.S.C. § 289
- Cornell Legal Information Institute — 35 U.S.C. § 285
This article is for informational purposes only and does not constitute legal advice. All case information is drawn from publicly available court records. For platform capabilities, visit PatSnap.