You filed the takedown. The listing came down. The seller is still there, and the marketplace will not tell you what it did about them. That is the point in the process where most brands stop, and it is exactly where the work starts. A listing removal is the marketplace doing the minimum. Getting the seller dealt with takes a different filing, in a different channel, with different evidence.
Every marketplace of any size has a repeat infringer policy, because the law requires one. Under 17 U.S.C. 512(i)(1)(A), a service provider only keeps its safe harbour from copyright liability if it has adopted and reasonably implemented a policy for terminating subscribers who are repeat infringers, and has told its users about it. The policy is only triggered by evidence of repetition, and the only party in a position to document repetition against your brand is you.
Stop counting listings. Name the folder after the shop ID and keep a running count per seller: notices filed, listings removed, counter-notices received, and listings that came back. When you escalate, the filing reads like a case, not a complaint: this seller ID, these seven notices, these dates, these five removals, these four relistings of substantially the same material. Under your repeat infringer policy, please review the account.
Use the platform's repeat-infringer or brand-protection escalation channel, not the standard listing report form. The standard form treats each filing as a new incident. The escalation channel is where the account-level tools live: suspension, payment holds, and cross-account enforcement that links related storefronts. In Europe, the Digital Services Act, Regulation 2022/2065, obliges platforms to suspend users who frequently submit manifestly illegal content under Article 23, and requires marketplaces to collect and verify trader details under Article 30. Those are levers, not background law. Cite them.
Go around the listing. Payment processors and marketplace payment systems have their own fraud and intellectual property violation processes, and a documented repeat operation can lose its ability to collect. Domain registrars and hosts have abuse desks. Search engines delist. None of these is a substitute for the marketplace acting, but each one raises the operation's cost, and cost is the only thing that deters an operation that treats takedowns as a line item.
And keep the documentation running even after you win the first round. Evasion sellers rebuild the cluster under a slightly modified parent listing within a week. Each rebuild with the same pattern strengthens the repeat-offender case. Enforcement is attrition, and good documentation is how you win it.
Keep reading: Counterfeit Sellers on Social Shops: TikTok and Instagram Takedowns, VeRO and Brand Registry: Filing on Etsy and eBay, and Why Counterfeits Come Back After a Takedown cover the nearby cases in this series.
Under 17 U.S.C. 512(i)(1)(A), a service provider only keeps its safe harbour from copyright liability if it has a policy for terminating subscribers who are repeat infringers. The policy is triggered by evidence of repetition, which the brand has to document.
File by seller, not by listing. Keep a running count per seller of notices filed, removals, counter-notices, and relistings, then use the platform's repeat-infringer or brand-protection escalation channel rather than the standard report form.
Regulation 2022/2065 obliges platforms to suspend users who frequently submit manifestly illegal content under Article 23, and requires marketplaces to collect and verify trader details under Article 30. Cite both when escalating in Europe.
Go around the listing. Payment processors have their own fraud and IP violation processes, registrars and hosts have abuse desks, and search engines delist. Each raises the operation's cost, which is the only thing that deters it.