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Schedule A Settlement Data: What 10 Sellers Paid

10/3/2026

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Schedule A Settlement Data: What 10 Sellers Paid

By Kenneth G. Eade, founding attorney, AMZ Sellers Attorney® · Published October 3, 2026

Key takeaways
  • Across 10 Schedule A settlement agreements dated December 2022 to August 2026, sellers paid a median of $5,750, ranging from $2,000 to $24,000.
  • Two sellers who reported zero sales still paid, about $2,000 and about $3,900. Once the account is frozen, the freeze is the leverage.
  • In one matter, about half the settlement was taken straight from the frozen Amazon account.
  • Sellers paid within days; plaintiffs released accounts on their own schedule. Six of 10 agreements set no release deadline, and one had no release clause at all.
  • Every agreement was confidential, included no admission of liability, and required the seller to stop selling and never challenge the IP.
$5,750median payment
$2,000lowest
$24,000highest
6 of 10no release deadline

A Schedule A defendant usually learns two numbers at once: how much the court has frozen, and what the plaintiff wants. This analysis looks at what sellers actually agreed to pay and sign in 10 Schedule A settlements, and at what the agreements say, and don't say, about getting the money back.

How We Built This Dataset

We reviewed the 10 distinct Schedule A settlement agreements in our files, removing duplicate drafts and signed copies of the same agreement. The cases were filed in four federal districts by seven different plaintiff law firms. Seven involved Amazon storefronts, one involved eBay, and two did not name the platform. All agreements are confidential, so we report only aggregated figures. No case, plaintiff, storefront, or seller is identified.

One note on the numbers sellers ask about most: none of the 10 agreements recited the frozen balance. That figure lives in the TRO and the platform's freeze notice, not in the settlement. That is itself a lesson: get the frozen amount in writing before you negotiate.

Where the Cases Were Filed

Court Agreements
Northern District of Illinois 6
Western District of Pennsylvania 2
Southern District of Florida 1
Middle District of Florida 1

What Sellers Paid, by Claim Type

Claim type Agreements Payment range
Trademark, alone or with copyright 4 $5,000 to $24,000
Copyright only 2 About $2,000 to about $3,900
Design patent with copyright 2 $2,000 to $14,000
Utility patent 2 $4,000 to $6,500
All 10 10 $2,000 to $24,000; median $5,750; average $9,639.86

Brand cases settled higher. With 10 agreements this is a pattern, not a statistic, but it matches what we see in negotiation: trademark plaintiffs price the brand, not the sale.

Payment and Release Terms

Term What the agreements said
Payment deadline 2 days or 2 business days in 5 agreements; 7 days in 1; 10 days in 1; not stated in 3
Payment taken from the frozen account Done in 1 (about half the settlement); offered as a payment route in 2; used to collect liquidated damages on late payment in 1
Who instructs release The plaintiff, in every agreement with a release clause
Release deadline 5 business days (1); 30 days (1); 30 business days (1); "a reasonable time" (1); none stated (6)
No account-release clause at all 1
Dismissal With prejudice (4); without prejudice (1); type not stated (5)

The Clauses Every Agreement Contained

Clause Agreements
Confidentiality 10 of 10
No admission of liability 10 of 10 (2 convert to an admission if the seller breaches)
Seller acknowledges the IP is valid and agrees not to challenge it 10 of 10
Stop selling the accused products 10 of 10
Mutual release 10 of 10
Each side pays its own attorney fees 10 of 10
Covenant not to sue 6 of 10
Liquidated damages if the seller breaches ($10,000 and $15,000) 2 of 10
Private arbitration of disputes over the agreement 2 of 10
Destroy remaining inventory 1 of 10
Identify the seller's supplier 1 of 10
Disclose account balances on nine platforms 1 of 10

Five Lessons From the Data

1. Zero sales is not zero exposure

Two sellers stated in their agreements that they had no inventory and no sales of the accused product. They still paid about $2,000 and about $3,900. A frozen account changes the economics even when the infringement case is weak, which is why speed matters more than outrage.

2. Assume the frozen balance is part of the deal

One plaintiff collected about half its settlement "by default" from the seller's Amazon account before the seller paid the rest. Two other agreements built that transfer into the payment terms. Know what is in the account before you agree to a number.

3. Negotiate the release, not just the price

Sellers paid within 2 days in half the agreements, but six agreements gave the plaintiff no deadline to release the account. A settlement without a release deadline, and without an order or notice that names the storefront and the platforms, can leave a paid-up seller frozen for weeks.

4. The boilerplate is negotiable at the edges

The core clauses were nearly identical across seven law firms. What changed between agreements was the amount, the payment deadline, the release deadline, dismissal with or without prejudice, and liquidated damages. Those are the terms worth fighting over.

5. Read the template

Two agreements named the plaintiff inconsistently or named the wrong party in a draft, and one omitted the release clause entirely. Errors like these are leverage if you catch them before signing and a problem if you don't.

For the full defense process, see our Schedule A and Amazon TRO defense page.

FAQ

How much does it cost to settle a Schedule A case?

In 10 Schedule A settlement agreements from 2022 to 2026, sellers paid between $2,000 and $24,000, with a median of $5,750 and an average of $9,639.86. Half paid $5,000 or less. Trademark cases settled between $5,000 and $24,000; copyright and patent cases settled between $2,000 and $14,000.

Can the plaintiff take the settlement from my frozen Amazon account?

Yes. In one agreement in our data, about half of the settlement was taken directly from the seller's restrained Amazon account. Two other agreements allowed the platform to transfer the payment from the frozen account, and one allowed the plaintiff to deduct liquidated damages from the seller's accounts if payment was late.

How long does it take to release frozen funds after a Schedule A settlement?

Release happens only after the plaintiff confirms payment, and the plaintiff controls the release instruction. In our data, release deadlines ranged from 5 business days to 30 business days where they were stated at all. Six of the 10 agreements set no deadline, and one contained no account-release clause.

Served in a Schedule A Case?

Get the frozen amount, the deadlines, and a negotiating position before you answer the plaintiff.

Request a free case review

Aggregated, anonymized data from 10 Schedule A settlement agreements; no individual settlement is disclosed. Past results do not guarantee future outcomes. This is general information, not legal advice.

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