Tan Grow v. Schedule A: Default Judgment in Foldable Pet Wash Station Case
Tan Grow, Inc. sued unnamed online marketplace sellers for infringing three patents covering foldable dog washing stations and liquid containers. With no defendant appearance, the Eastern District of Virginia entered a default judgment of $3,755.10 split across two named defendants — closing the case 268 days after filing.
Online sellers face default judgment in foldable pet-wash patent row
Tan Grow, Inc. filed suit on October 21, 2024, in the Eastern District of Virginia against a group of defendants identified only as ‘The Unincorporated Associations Identified in Schedule A’ — a complaint structure routinely used against anonymous e-commerce sellers. The action alleged infringement of three patents: US11939111B2, US10543957B2, and US10882662B2, all covering foldable dog washing station and foldable liquid container technology. The products at issue are consumer pet-care items sold through online marketplaces.
The case closed on July 16, 2025, when the court entered a default judgment under Federal Rule of Civil Procedure 55, after the defendants failed to appear or file any response. Judgment was entered in favour of Tan Grow and against two specifically named defendants: #13 FELIMODA (awarded $3,650.75) and #29 an unnamed seller (awarded $104.35). The remainder of the Schedule A defendants were either not reached or not pursued to judgment at this stage.
The 268-day resolution is consistent with the pace of uncontested default proceedings. The absence of any defendant appearance means no invalidity challenge, claim construction, or damages contest was placed on the record, leaving Tan Grow’s three patents unscrutinised on the merits. What drove the selective naming of only two defendants in the final judgment — and whether Tan Grow will pursue further enforcement actions against other Schedule A sellers — is not disclosed in the public record.
Filing to Default Judgment in 268 days
268 days — faster than the median patent infringement case in this district
Default judgment entered: what the ruling means for both parties
Rule 55 default: plaintiff wins without a merits contest
A default judgment under FRCP 55 is entered when a defendant fails to appear or respond. The court does not adjudicate infringement or validity on the merits — it treats the plaintiff’s well-pleaded allegations as admitted. This means Tan Grow’s patents were never tested by an adversarial invalidity challenge, leaving the patents intact but without the litigation-hardened endorsement a contested win would provide.
FRCP 55 — no merits adjudicationTan Grow secures enforceable money judgment
Tan Grow obtained $3,650.75 against FELIMODA and $104.35 against the unnamed seller — modest sums, but the judgments are enforceable court orders. More strategically, a default judgment establishes a record of enforcement activity that can deter other marketplace sellers. Whether Tan Grow can collect these amounts from anonymous offshore sellers, however, is a practical limitation not resolved by the judgment itself.
$3,755.10 total — enforceable judgmentNon-appearing sellers face monetary judgment and potential injunction risk
FELIMODA and the unnamed seller have a default judgment on record against them. Failure to appear forfeits the right to contest infringement or validity at this stage. While the sums are small, continued sale of infringing products could expose these sellers to contempt or further enforcement. Other Schedule A defendants not named in the final judgment may still face separate proceedings if Tan Grow continues its enforcement campaign.
Judgment by default — no contest on recordSchedule A enforcement signals broader deterrence play
The Schedule A filing structure is common among IP holders targeting mass marketplace infringement. Even small per-defendant recoveries can, in aggregate, fund an enforcement programme that deters copycat sellers. For competing manufacturers in the foldable pet-wash and portable liquid container space, Tan Grow’s three unchallenged patents now carry a litigation track record — raising the risk calculus for any seller stocking functionally similar products without an FTO clearance opinion.
Deterrence — patents remain unchallengedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Tan Grow, Inc. | Company | Consumer pet-product innovator — holder of US11939111B2, US10543957B2, US10882662B2Search in Eureka ↗ |
| Defendant | The Unincorporated Associations Identified in Schedule A | Individual | Unincorporated online marketplace sellers; two identified as FELIMODA and an unnamed sellerSearch in Eureka ↗ |
| Plaintiff counsel | Erik Lund | Attorney | Counsel for Tan Grow, Inc.Search in Eureka ↗ |
| Plaintiff counsel | Joseph J. Zito | Attorney | Counsel for Tan Grow, Inc.Search in Eureka ↗ |
| Plaintiff law firm | Dnl Zito Castellano | Law Firm | Representing Tan Grow, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Virginia Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The judgment’s specificity — naming FELIMODA at $3,650.75 and an unnamed seller at $104.35 — reflects damages calculated per-defendant rather than as an aggregate award. The FRCP 55 default framing means the court accepted Tan Grow’s allegations as true without evidentiary contest. No invalidity finding, no claim construction order, and no injunction is visible in the public record, suggesting Tan Grow’s primary objective here was monetary recovery and deterrence rather than injunctive relief.
US11939111B2 — Foldable dog washing station and liquid container technology
US11939111B2 (application US18/224559), US10543957B2 (application US16/405984), and US10882662B2 (application US16/041822) collectively protect foldable and collapsible structures used in portable dog washing stations and liquid containers. These patents sit at the intersection of consumer pet care and functional packaging design, covering mechanical folding mechanisms, structural support, and liquid containment features. The sequential application numbers suggest a deliberate family-building strategy to layer protection across related product configurations.
For competitors in the portable pet-grooming and outdoor pet-care space, this three-patent family creates a meaningful claim thicket. The products involved — foldable dog washing stations and foldable liquid containers — are high-velocity SKUs on major e-commerce platforms, making them attractive targets for Schedule A enforcement. Any manufacturer or importer offering functionally comparable products should conduct claim-by-claim mapping against all three patents before commercialisation, particularly given that Tan Grow has now demonstrated willingness to litigate.
Should you run an FTO against US11939111B2 and its family?
If your company designs, manufactures, imports, or sells foldable dog washing stations, collapsible pet tubs, or portable liquid containers, this three-patent family warrants a formal FTO review. Tan Grow has filed enforcement proceedings in the Eastern District of Virginia — a plaintiff-active venue — and obtained default judgments. The absence of a contested merits ruling means invalidity arguments remain available, but only if raised proactively before litigation commences.
PatSnap Eureka’s FTO Search Agent can map your product’s technical features against the claims of US11939111B2, US10543957B2, and US10882662B2 simultaneously, flagging overlap risk and identifying prior art that could support an invalidity position. For sourcing teams dealing with offshore suppliers, Eureka can also surface related applications in the same family to check for continuation risk — a critical step before committing to large inventory positions in this product category.
Run a freedom-to-operate analysis on US11939111B2 to assess your product’s exposure
Run FTO in Eureka →Similar patent cases: foldable consumer goods & Schedule A enforcement
Cases involving foldable consumer product patents and Schedule A marketplace defendants in U.S. district courts, with comparable enforcement profiles and default outcomes.
What this case signals for the foldable pet-product IP landscape
A low-damages default doesn’t mean low-stakes IP. Tan Grow’s unchallenged patents now anchor a growing enforcement portfolio.
Uncontested patents carry hidden risk for marketplace sellers
Because no defendant challenged validity or infringement, US11939111B2, US10543957B2, and US10882662B2 emerge from this case entirely intact. Any seller of foldable dog washing stations or portable liquid containers on Amazon, eBay, or similar platforms should treat these patents as active enforcement threats, not theoretical risks.
Schedule A tactics are accelerating in consumer goods IP
Filing against anonymous ‘Schedule A’ defendants allows a patent holder to obtain broad discovery and injunctions before sellers can organise a defence. This approach is increasingly common in product categories dominated by offshore manufacturers. R&D teams and sourcing managers should audit supplier agreements for indemnification clauses covering exactly this type of action.
Tan v Unincorporated — key questions answered
Tan Grow asserted three patents: US11939111B2 (application US18/224559), US10543957B2 (application US16/405984), and US10882662B2 (application US16/041822). All three cover foldable dog washing station and foldable liquid container technology and were asserted against Schedule A online marketplace sellers.
The case closed on July 16, 2025, with a default judgment under FRCP 55 in favour of Tan Grow. Two defendants were named in the judgment: FELIMODA (awarded $3,650.75) and an unnamed seller (awarded $104.35). No defendant appeared or contested the action, so no merits determination on infringement or validity was made.
Filing against ‘Schedule A’ defendants allows a plaintiff to sue multiple anonymous online sellers simultaneously before their identities are publicly confirmed. Courts routinely permit early discovery to identify sellers via platform records. This structure is common in marketplace IP enforcement and allows patent holders to obtain injunctions and damages against many defendants in a single action.
No. Because no defendant appeared to challenge validity, the patents US11939111B2, US10543957B2, and US10882662B2 emerge from this litigation entirely intact. A default judgment contains no invalidity ruling. The patents remain enforceable and can be asserted in future proceedings against other sellers of competing foldable pet-wash or liquid container products.
The case, No. 1:24-cv-01855, was filed and adjudicated in the Eastern District of Virginia. The court entered default judgment on July 16, 2025. Plaintiff was represented by Erik Lund and Joseph J. Zito of DNL Zito Castellano, a firm with a noted track record in marketplace IP enforcement actions.
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