1. Response to Amazon's Initial Rejection

We respectfully and firmly dispute this determination. This escalated submission has been specifically prepared to address each of the grounds on which Amazon may reject a copyright infringement report. In particular: (1) Section 3.1 provides a detailed description of the specific aesthetic and artistic features of the copyrighted work that are reproduced in the reported infringing product, with explicit mapping between the doddl original (ASIN B0779CZ9FD) and the BabyGoo infringing listing (ASIN B0D3ZTLWYB); (2) Section 3.3 provides full test buy details, including the Amazon Order ID for a purchase of the infringing product made directly from the reported seller on Amazon.co.jp; and (3) Section 3.1 explicitly addresses the distinction between the aesthetic and artistic features of the handle design that are protected by copyright, and the functional purpose those features may also serve — making clear that the copyright claim is in the creative expression, not in any functional method.

The infringement is clear, serious, and ongoing. BabyGoo has directly copied the three-dimensional artistic design of doddl's award-winning cutlery handle — the core protected element of our intellectual property — and is actively selling those copies on Amazon.co.jp, causing significant and quantifiable commercial harm to doddl and our authorised Japanese distribution partner.

2. Ownership of a Valid Copyright

2.1 Creation and Authorship

The doddl cutlery handle design was conceived and created by Catherine Dodd, Co-Founder and CEO of Doddl Ltd. Development began in late 2013 following personal experience with the challenges of teaching three young children to self-feed. Over more than two years of intensive research, development, and testing — conducted in collaboration with child development experts, universities, and specialist research institutes — Catherine Dodd created a wholly original and distinctive cutlery handle design unlike anything previously available on the market.

The design was first made public through a Kickstarter crowdfunding campaign launched in March 2016, establishing a clear and documented date of original publication. The product subsequently launched commercially across doddl's own website and Amazon marketplaces globally.

The handle design is not a functional necessity. It is the result of deliberate artistic and developmental choices: the precise contours, the teardrop-shaped body, the organic narrowing at the neck, the soft-touch side panels with tactile texture — all are original creative expression fixed in a tangible medium, satisfying the requirements for copyright protection in the UK, the US, and under the Berne Convention (which applies in Japan).

2.2 Registered Intellectual Property

Note: While Japan-specific design registration was not pursued at the time of original product launch, copyright protection arises automatically upon creation under the Berne Convention, to which Japan is a signatory. Formal registration is not a prerequisite for copyright protection or enforcement.

3. Evidence of Copying — The Handle Design

3.1 What Makes the doddl Handle Original

The doddl handle design is a three-dimensional artistic work of original creative expression. The copyright claimed in this notice is in the artistic, aesthetic, and visual elements of the handle design — specifically its distinctive shape, silhouette, proportions, and surface detailing — not in any functional method of use. Each of the features listed below was the result of a deliberate aesthetic and creative choice; none of them was dictated by functional necessity, and each could have been expressed differently while achieving the same functional purpose. The specific aesthetic features of the handle as embodied in the doddl Toddler Spoon & Fork Set (ASIN B0779CZ9FD / SKU DOD004) that have been reproduced in the BabyGoo product (ASIN B0D3ZTLWYB) are as follows:

• A broad, flat, teardrop-shaped body — the specific teardrop silhouette, its precise proportions, and its flat-palm profile are aesthetic design choices. A handle could encourage an open-palm grip through many other shapes; the teardrop form is not functionally required and was chosen for its visual distinctiveness as much as its developmental benefit.
• An organic, curved narrowing at the neck where the handle meets the utensil head — the precise curvature, taper profile, and organic quality of this narrowing are aesthetic choices. Finger guidance could be achieved through a straight taper, a ridge, or a step; the specific organic curved neck of the doddl handle is an expressive artistic decision, not a functional necessity.
• Recessed oval soft-touch side panels (TPE material) — the specific oval shape of these panels, their precise positioning on the body of the handle, their recessed depth, and their visual contrast with the surrounding hard plastic are all aesthetic and expressive choices. Tactile grip zones could take innumerable forms; the specific oval recessed panel design as expressed in the doddl handle is an original artistic choice.
• The overall three-dimensional handle silhouette as a whole — the combined visual impression created by the teardrop body, curved neck, and recessed oval panels working together constitutes a wholly original artistic work. This overall aesthetic expression was not dictated by function; prior to doddl's design, children's cutlery handles took entirely different forms. The doddl silhouette is the result of original creative authorship.

This combination of form, proportion, and surface detail constitutes a substantial body of original artistic expression. Copyright subsists in this three-dimensional design as an artistic work. The copyrighted work being reported as infringed is the three-dimensional handle design of the doddl Toddler Spoon & Fork Set (ASIN B0779CZ9FD / SKU DOD004), as created by Catherine Dodd and first published in March 2016. The infringing product is the BabyGoo Toddler Cutlery Set (ASIN B0D3ZTLWYB), sold on Amazon.co.jp, which reproduces the specific aesthetic features of that handle design as described above.

3.2 Direct Physical Comparison

The BabyGoo product (ASIN B0D3ZTLWYB) was purchased directly from the infringing listing on Amazon.co.jp by Blue Ocean Tradings LLC., doddl's sole authorised Japanese distributor. The physical product was subsequently shipped to doddl Ltd in the UK and examined in person by Catherine Dodd. The order ID for this purchase is provided in Section 3.3 below. The photographs below document the results of that physical examination. The handle designs are, to any reasonable observer, substantially identical.

Figure 1: doddl handle (top) vs BabyGoo handle (bottom) — top view showing identical teardrop silhouette

Figure 2: Both products side by side — handle shape, proportions and neck profile are indistinguishable

The following images show the BabyGoo product physically placed against BabyGoo's own Chinese design registration documents — revealing that BabyGoo's registered design drawings directly describe the same teardrop handle shape as doddl's original design.

Figure 3: BabyGoo product held against its own design registration — the handle matches doddl's protected design

Figure 4: BabyGoo's own design drawings confirm the teardrop handle profile — directly replicating doddl's original work

Figure 5: BabyGoo handle against its own side-view registration — confirming the identical narrowed-neck profile

Figure 6: doddl handle against BabyGoo's design registration front view — the oval soft-touch panel area is replicated in both

These images constitute compelling evidence of copying. The BabyGoo product physically matches not only doddl's product but also BabyGoo's own formally lodged design registration drawings — which themselves replicate doddl's protected handle silhouette.

3.3 Test Buy Evidence

In order to substantiate this claim, a test purchase of the infringing product was made directly from the reported seller on Amazon.co.jp. The purchase was made by Blue Ocean Tradings LLC., doddl's sole authorised Japanese distributor. Full details of that transaction are set out below.

4. Evidence of Access

BabyGoo had clear and demonstrable access to the doddl product prior to creating its infringing design. Specifically:

• The doddl Toddler Spoon and Fork Set (DOD004 / ASIN B0779CZ9FD) has been listed and actively sold on Amazon.co.jp since 2022, with the product having been publicly available globally since March 2016.
• doddl achieved Best Seller status in the children's cutlery category on Amazon.co.jp. During peak months, monthly revenue from the Japanese market exceeded £250,000. doddl was among the highest-ranked and most-reviewed products in the category — plainly visible to any competitor conducting basic market research.
• BabyGoo launched its infringing product in June 2024 — after doddl had established dominant market presence on Amazon.co.jp. The timing is not coincidental; it is the pattern of a copycat brand targeting an established market leader.
• BabyGoo's own Amazon listing infographics include a direct visual comparison between the doddl handle silhouette and their own product — conclusively proving not only that they were aware of doddl's product, but that they deliberately referenced it in their own marketing materials, using doddl's distinctive design to promote their copy.

5. Substantial Similarity

Under copyright law — including the Berne Convention applicable in Japan, and the UK and US frameworks under which our rights are registered — it is not necessary to show that the entire work was copied, only that a qualitatively substantial part of the protected expression was taken.

In this case, the similarity is not partial — it is near-total with respect to the protected element. The following specific features of the doddl handle design have been directly replicated in the BabyGoo product:

The differences between the two products are confined to the utensil ends, which BabyGoo has modified slightly. This is a well-recognised pattern in product design copying: a copycat reproduces the protected creative expression while making superficial changes to unprotected functional elements in an attempt to avoid enforcement. The courts — and Amazon's own Brand Registry policies — recognise this approach and do not consider it to negate infringement of the copied elements.

BabyGoo's own Amazon listing infographics explicitly compare the two handle designs side-by-side, confirming that BabyGoo is marketing the similarity of their handle to doddl's as a selling point — demonstrating both awareness of the original work and deliberate commercial exploitation of it.

6. Unauthorised Use

Doddl Ltd has never licensed, authorised, or permitted BabyGoo or any associated entity to manufacture, sell, or otherwise exploit the doddl handle design in any territory, including Japan.

The infringing listing (ASIN B0D3ZTLWYB) is being offered for sale on Amazon.co.jp entirely without the knowledge or consent of the rights owner. The product is being sold at a significantly lower price than doddl's authorised listing, causing direct and ongoing commercial harm — including measurable loss of sales, damage to doddl's Best Seller ranking, and reputational damage to doddl's established position in the Japanese market.

The commercial impact is severe. At its peak, doddl's authorised Japanese sales exceeded £250,000 per month. The arrival of BabyGoo's infringing product in June 2024, underpricing doddl directly and leveraging doddl's own design to compete, has caused significant and documented harm to both doddl and our authorised Japanese distribution partner.

7. Good Faith Belief Statement

We have a genuine and reasonable good-faith belief that BabyGoo's use of the doddl handle design is not authorised by doddl Ltd, is not authorised by any agent of doddl Ltd, and is not authorised by law. The use is a clear infringement of doddl's registered and unregistered intellectual property rights.

8. Statement of Accuracy

I, Catherine Dodd, Co-Founder and CEO of Doddl Ltd, and the original creator and rights owner of the doddl cutlery handle design, hereby confirm under penalty of perjury that the information contained in this notice is accurate, complete, and made in good faith. I am the rights owner and am fully authorised to submit this notice.

9. Requested Action

We respectfully request that Amazon Brand Registry:

• Immediately remove the infringing listing: ASIN B0D3ZTLWYB from Amazon.co.jp.
• Prevent re-listing of any substantially similar products by BabyGoo or associated sellers.
• Take appropriate action against BabyGoo's seller account in recognition of the deliberate and commercially harmful nature of this infringement.
• Provide confirmation of the actions taken so that doddl can assess whether further legal steps are required.

Doddl is a legitimate, award-winning brand — holder of the prestigious King's Award for Innovation — with over 25,000 five-star reviews and distribution across more than 30 countries. We have built our success through years of original research, development, and investment. We respectfully call upon Amazon to uphold its own policies protecting intellectual property rights, and to ensure that genuine innovators are not commercially undermined by those who copy and undercut them on your platform.