Honeyera LLC v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Honeyera, LLC (Jurisdiction not specified)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule "A" (Allegedly reside in the People's Republic of China or other foreign jurisdictions)
  • Plaintiff’s Counsel: Law Office of David Gulbransen
• Case Identification: 1:25-cv-03682, N.D. Ill., 04/04/2025
• Venue Allegations: Venue is alleged based on Defendants targeting consumers in the United States, including Illinois, through interactive commercial internet stores, accepting payment in U.S. dollars, and making sales to Illinois residents.
• Core Dispute: Plaintiff alleges that numerous unidentified online retailers are selling door hanger organizers that infringe its design patent.
• Technical Context: The technology concerns the ornamental design of over-the-door storage organizers, a common consumer product for household organization.
• Key Procedural History: The complaint is structured as an action against a "Schedule A" of unidentified defendants, a common procedural posture in cases against large numbers of online sellers who allegedly operate anonymously and in concert.

Case Timeline

Date	Event
2022-04-21	U.S. Patent No. D1,023,613S Application Date
2024-04-23	U.S. Patent No. D1,023,613S Issue Date
2025-04-04	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Design Patent No. D1,023,613S - “Door Hanger Organizer”

The patent-in-suit is U.S. Design Patent No. D1,023,613S, issued April 23, 2024 (the “D’613 Patent”).

The Invention Explained

• Problem Addressed: The patent does not explicitly state a problem in a background section, as is typical for a design patent. The context implies a need for a new, original, and ornamental design for an article of manufacture, specifically a door hanger organizer (D’613 Patent, Grant Sheet).
• The Patented Solution: The patent claims the specific visual appearance of a door hanger organizer. The design consists of a rectangular backing with four vertically stacked, uniform pockets, and four circular holes at the top for mounting (D’613 Patent, FIG. 1). The figures further detail the design's appearance when mounted on a door and containing items, with the door, hooks, and items shown in broken lines to indicate they are environmental context and not part of the claimed design (D’613 Patent, FIG. 7-8, col. 2:5-13).
• Technical Importance: The patent protects a specific aesthetic for a widely sold consumer good, aiming to distinguish the patent holder's product from others in the market based on its visual appearance (Compl. ¶15).

Key Claims at a Glance

• The complaint asserts the single claim of the D’613 Patent (Compl. ¶30).
• The claim is for: "The ornamental design for a door hanger organizer, as shown and described." (D’613 Patent, col. 1:57-59). The essential elements are the visual features depicted in the solid lines of the patent's drawings, including:
  • The overall configuration of a vertically-oriented organizer with four pockets.
  • The specific shape, proportion, and appearance of the four pockets.
  • The arrangement of four circular hook holes at the top of the organizer.

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific products by name or model number. It refers generally to "Infringing Products," which are "unauthorized products that infringe upon the patented design" sold through numerous "Defendant Internet Stores" (Compl. ¶¶ 6, 19).

Functionality and Market Context

The complaint alleges that the accused products are door hanger organizers that bear "reproduction, copy or colorable imitation of the design claimed in the Patented Design" (Compl. ¶33(a)). These products are allegedly sold through a "massive network of Defendant Internet Stores" that are designed to appear as legitimate retailers but are part of a coordinated "illegal infringement ring" (Compl. ¶¶ 13, 22). The complaint provides an image of the patented design in an environmental context, showing it used to store toys. (Compl. Ex. 1; D'613 Patent, FIG. 8).

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendants' products are "colorable imitations" of the patented design, which, in the context of design patents, is assessed by the "ordinary observer" test. The test asks whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design.

D’613 Patent Infringement Allegations

Claim Element (from "The ornamental design for a door hanger organizer, as shown and described.")	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The overall ornamental appearance of a door hanger organizer as shown in FIG. 1.	Defendants are accused of selling "online products that infringe directly and/or indirectly the ornamental design claimed in the '613 Patent." The complaint alleges these products are "colorable imitation[s]" of the patented design. A figure from the patent shows a perspective view of the organizer mounted on a door. (Compl. Ex. 1; D'613 Patent, FIG. 7).	¶¶ 30, 33(a)	col. 1:57-59; FIG. 1; FIG. 7
A configuration of four vertically stacked pockets on a rectangular backing.	The complaint alleges that the "Infringing Products" copy the creative content protected by the patent registration. A figure in the patent, incorporated into the complaint, shows the organizer with items inside the pockets. (Compl. Ex. 1; D'613 Patent, FIG. 8).	¶¶ 19, 23	FIG. 1; FIG. 8
A set of four circular holes arranged at the top of the organizer for mounting.	The complaint alleges Defendants sell products that are "reproduction[s]" or "cop[ies]" of the patented design. The front view of the patent clearly depicts these four holes as part of the claimed design. A figure shows a front view of the organizer. (Compl. Ex. 1; D'613 Patent, FIG. 1).	¶¶ 30, 33(a)	FIG. 1

Identified Points of Contention

• Scope Questions: A central question will be whether the accused products are "substantially the same" in overall visual appearance as the claimed design from the perspective of an ordinary observer. The analysis will depend on the visual evidence of the accused products, which is not included in the complaint.
• Technical Questions: Given the nature of the defendants, a primary challenge will be evidentiary: linking the specific products sold by each anonymous entity listed in Schedule A to the patented design and establishing that these products are, in fact, colorable imitations. The complaint alleges the products come from a "common source," which, if proven, could streamline this analysis (Compl. ¶23).

V. Key Claim Terms for Construction

In a design patent case, claim construction focuses on the scope of the claimed design as a whole, rather than on discrete textual terms. The primary "term" for construction is the claim itself.

• The Term: "The ornamental design for a door hanger organizer, as shown and described."
• Context and Importance: The scope of this claim will define what constitutes an infringing product. The key issue for the court will be to determine which visual features are protected and how similar an accused product must be to infringe. Practitioners may focus on the effect of the broken lines in the patent's figures, as they define the boundary between the claimed design and its environment.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim covers the "ornamental design," suggesting protection is not limited to an exact replica but extends to designs with the same overall visual effect. The use of simple, clean lines and basic geometric shapes (rectangles, circles) could be argued to create a broad, minimalist aesthetic that other similar designs might capture.
  • Evidence for a Narrower Interpretation: The patent's description explicitly states that the broken lines showing a door, hooks, and articles within the pockets "show environment of use and form no part of the claimed design" (D’613 Patent, col. 2:9-13). This language expressly limits the claim to the organizer itself, as depicted in solid lines, and prevents the patentee from claiming the design in combination with the environmental elements. The specific proportions and arrangement of the pockets and holes as shown in FIG. 1 provide a precise visual that could support a narrower scope.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants are "directly and personally contributing to, inducing and engaging in the sale of Infringing Products" (Compl. ¶20). The basis for this allegation appears to be the claim that Defendants operate as an "interrelated group of infringers working in active concert" (Compl. ¶20).
• Willful Infringement: Willfulness is alleged based on the assertion that Defendants had "full knowledge of Honeyera ownership of the ‘613 Patent" and that their infringing acts were "intentional, and in disregard of and with indifference to the rights of the Plaintiff" (Compl. ¶¶ 21, 31). The complaint further alleges that the Defendants' use of tactics to conceal their identities is evidence of willfulness (Compl. ¶¶ 20, 22).

VII. Analyst’s Conclusion: Key Questions for the Case

1. The "Ordinary Observer" Test: The central question will be one of visual similarity: assuming the Plaintiff can produce examples of the accused products, would an ordinary observer, familiar with other door organizers, be deceived into thinking the Defendants' products are the same as the specific ornamental design protected by the D’613 Patent?
2. Proving Infringement at Scale: A key procedural and evidentiary hurdle will be linking the infringement to the defendants: can the Plaintiff effectively demonstrate that the numerous, anonymous entities listed on Schedule A are in fact selling products that infringe the D'613 patent and that these entities can be treated as a "collective enterprise" as alleged? (Compl. ¶31).
3. Scope of the Design: A legal question underlying the entire case is the effective scope of the claimed design: how broadly will the court construe the protection afforded to the specific arrangement of pockets and holes shown in the D'613 Patent, and at what point does a different arrangement create a distinct, non-infringing visual impression?