Zhiwu Zheng v. Schedule A Defendants: Default Judgment on Design Patent D944,787
Plaintiff Zhiwu Zheng secured a default judgment and permanent injunction against anonymous e-commerce sellers alleged to have copied the ornamental design of a magnetic mobile phone mount base protected by U.S. Design Patent D944,787. The court found willful infringement and ordered Amazon to disable infringing storefronts across all Schedule A defendants — none of whom appeared to contest the action.
Design patent default judgment targets anonymous Amazon sellers
On October 20, 2024, Zhiwu Zheng filed suit in the Northern District of Illinois (Case No. 1:24-cv-10814) against a class of unnamed e-commerce sellers identified only by seller aliases listed in Schedule A. The action asserted willful infringement of U.S. Design Patent No. D944,787 S, which protects the ornamental appearance of a magnetic base for mobile phone support. The defendants operated storefronts — primarily on Amazon — that offered for sale unauthorised copies of the patented design to U.S. consumers, including those in Illinois.
No defendant filed an answer or otherwise appeared. On October 22, 2025, Judge Jeffrey I. Cummings granted Plaintiff’s Motion for Entry of Default and Default Judgment in its entirety. The court found personal jurisdiction over all defaulting defendants on the basis that they actively targeted U.S. and Illinois consumers through e-commerce storefronts accepting U.S. dollar payments and offering U.S. shipping. A permanent injunction was entered restraining all defendants from further infringement, and the court ordered platforms including Amazon to disable the infringing stores and de-index them from search results.
The 367-day resolution is consistent with the typical cadence of Schedule A default judgment cases in the Northern District of Illinois, where plaintiffs frequently leverage the court’s well-developed procedures for anonymous e-commerce defendants. The absence of any defence suggests either deliberate non-appearance by overseas sellers or an inability to be located. The individual per-defendant damages amounts are set out in the sealed Schedule A, so the total financial award is not ascertainable from the public docket. What remains unknown is whether enforcement against the underlying payment processors and platforms will produce meaningful recovery.
Filing to Default Judgment in 367 days
367 days from filing to default judgment — faster than the N.D. Illinois median for contested IP disputes
Default judgment entered: what the ruling means for both parties
Default judgment: court rules without defendant participation
A default judgment under Federal Rule of Civil Procedure 55 is entered when a defendant fails to appear or respond. The court accepts well-pleaded allegations as true and assesses relief. Here, the court found willful infringement under 35 U.S.C. § 284 without any adversarial challenge, meaning the merits were never tested. The judgment is final and enforceable, but can in principle be challenged by defendants who later appear and demonstrate good cause.
FRCP 55 default procedureZheng wins injunction and damages — enforcement is the next hurdle
Zhiwu Zheng secured permanent injunctive relief, a finding of willful infringement, and per-defendant damages as scheduled. Critically, the court ordered Amazon and other platforms to disable infringing storefronts and de-index search results on request. However, converting a judgment against anonymous overseas sellers into actual payment recovery is a known practical challenge in Schedule A litigation — the paper victory is clear, but cash recovery is uncertain.
Permanent injunction grantedNon-appearance forfeits all defences — stores face immediate shutdown
By failing to answer, the Schedule A defendants forfeited any invalidity, non-infringement, or jurisdictional defences. Each defaulting defendant faces a permanent injunction, store deactivation on Amazon, and financial liability in amounts set out in Schedule A. Any seller wishing to challenge the judgment must move to vacate under FRCP 60(b), demonstrating excusable neglect or lack of proper notice — a high bar given the court’s finding that electronic service was constitutionally adequate.
All defences waived by defaultAmazon storefront shutdowns signal coordinated IP enforcement risk
This case is part of a broader wave of design patent enforcement actions in N.D. Illinois targeting anonymous marketplace sellers. For legitimate accessory manufacturers and Amazon third-party sellers, it signals that design patents on consumer electronics accessories — even narrow ornamental designs — can generate injunctions and store deactivations without trial. Sellers operating in the mobile accessories space should conduct design clearance searches before listing products on major platforms.
E-commerce IP enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Zhiwu Zheng | Individual | Individual patent holder — holder of design patent USD944787S covering magnetic phone mount baseSearch in Eureka ↗ |
| Defendant | The Partnerships And Unincorporated Associations Identified On Schedule A, | Individual | Anonymous e-commerce sellers operating under pseudonymous seller aliases on platforms including AmazonSearch in Eureka ↗ |
| Plaintiff counsel | Lance Y. Liu | Attorney | Counsel for Zhiwu ZhengSearch in Eureka ↗ |
| Presiding judge | Judge Jeffrey I Cummings | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s default judgment order is notable for its breadth: it combines a willfulness finding under 35 U.S.C. § 284, a permanent injunction, and explicit obligations on Amazon as a third-party platform. The personal jurisdiction analysis — based solely on defendants’ targeting of U.S. consumers through marketplace storefronts — follows established N.D. Illinois precedent in Schedule A cases and was uncontested. Because no defendant appeared, the design validity and scope of D944,787 were never adjudicated on the merits. The judgment binds only named defaulting defendants and does not preclude separate sellers from challenging the patent’s validity in future proceedings.
USD944787S — ornamental design for a magnetic mobile phone mount base
U.S. Design Patent No. D944,787 S (application number 29/778,344) protects the ornamental appearance — not functional features — of a magnetic base used to support mobile phones. Design patents in the U.S. cover the visual characteristics of an article of manufacture and are assessed for infringement under the ‘ordinary observer’ test: whether an ordinary observer, familiar with the prior art, would be deceived into thinking the accused product is the same as the patented design. The ‘S’ suffix confirms this is a design patent grant.
In the crowded mobile phone accessories market, ornamental design rights have become a primary enforcement tool because they are faster to obtain and easier to assert against copycat manufacturers than utility patents. D944,787 covers a specific magnetic base configuration, a product category with dozens of competing SKUs on major platforms. Any manufacturer or seller offering magnetically mounted phone support products with similar visual profiles faces potential exposure, particularly given that this judgment signals an active enforcement posture from the rights holder.
Should you run an FTO analysis against USD944787S?
Any company designing, importing, or listing magnetic phone mount accessories — including stands, dashboard mounts, desk bases, and similar support products — should assess their exposure against D944,787. The ‘ordinary observer’ standard means even non-identical designs can infringe if they produce a substantially similar overall visual impression. Third-party Amazon sellers in this category are at particular risk given the platform-level enforcement mechanisms demonstrated in this case.
PatSnap Eureka’s FTO Search Agent can map the visual claim scope of USD944787S against your product designs, identify prior art that may narrow or invalidate the claim, and surface related design patent families filed by the same applicant. Running this analysis before product listing or import decisions can prevent the type of default judgment exposure that eliminated multiple seller storefronts in this case.
Run a freedom-to-operate analysis on USD0944787S to assess your product’s exposure
Run FTO in Eureka →Similar design patent enforcement cases in N.D. Illinois mobile accessories
Explore related Schedule A design patent infringement actions filed in the Northern District of Illinois targeting e-commerce sellers of mobile phone accessories.
What this case signals for the mobile accessories IP landscape
Schedule A design patent actions in N.D. Illinois have become a high-volume enforcement tool. This case illustrates both the power and the limits of that strategy.
Design patents are potent weapons against anonymous marketplace sellers
The ornamental design patent D944,787 was sufficient to ground a permanent injunction and compel Amazon store shutdowns without any merits challenge. For consumer electronics accessory designers, securing design patent protection before commercialisation is increasingly essential — even narrow design claims can deliver rapid, platform-level enforcement outcomes.
Electronic service enables fast default judgments against overseas sellers
The N.D. Illinois court approved email and electronic publication as constitutionally adequate service on e-commerce defendants who never appear. This procedural pathway compresses timelines significantly compared to international service under the Hague Convention, making the district a preferred venue for Schedule A patent enforcement actions targeting Amazon marketplace sellers.
Zheng v Partnerships — key questions answered
The Northern District of Illinois entered a default judgment on October 22, 2025 in favour of plaintiff Zhiwu Zheng. The court found willful infringement of design patent D944,787 and issued a permanent injunction ordering defendants to cease infringing activity and directing Amazon to disable all infringing storefronts identified in Schedule A.
USD944787S protects the ornamental design of a magnetic base for a mobile phone support — a consumer electronics accessory. The defendants were alleged to have sold unauthorised copies of this design through anonymous Amazon seller accounts. Design patents cover visual appearance only; functional aspects of magnetic phone mounts are not within the scope of this patent.
The court found personal jurisdiction because the defendants actively targeted U.S. and Illinois consumers: they set up e-commerce stores shipping to Illinois, accepted U.S. dollar payments, and offered infringing products to Illinois residents. This analysis is standard in N.D. Illinois Schedule A cases and was uncontested due to defendants’ non-appearance.
Yes, in principle. A defaulting defendant may move to vacate the judgment under Federal Rule of Civil Procedure 60(b) by demonstrating good cause — typically excusable neglect, a meritorious defence, or insufficient notice. However, the court found electronic service constitutionally adequate, raising the bar for a notice-based challenge. Any motion must be filed promptly after the defendant becomes aware of the judgment.
Upon Zhiwu Zheng’s request, Amazon is ordered to: disable and deactivate the infringing seller storefronts listed in Schedule A; cease displaying infringing advertisements; and take steps to remove links to the infringing stores from search results. These obligations extend to any entity in privity with the defaulting defendants that receives notice of the injunction.
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