DCT

1:25-cv-05635

Honeyera LLC v. Partnerships Unincorp Associations

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Honeyera, LLC (Florida)
    • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule "A" (allegedly People's Republic of China or other foreign jurisdictions)
    • Plaintiff’s Counsel: Law Office of David Gulbransen
  • Case Identification: 1:25-cv-05635, N.D. Ill., 05/20/2025
  • Venue Allegations: Venue is based on allegations that Defendants operate interactive commercial internet stores that directly target and make sales to consumers in Illinois.
  • Core Dispute: Plaintiff alleges that numerous unidentified online retailers are selling "door hanger organizers" that infringe its U.S. design patent.
  • Technical Context: The technology falls within the consumer home goods market, specifically over-the-door storage and organization products.
  • Key Procedural History: The complaint targets a large number of unidentified defendants, alleging they are part of a coordinated "illegal infringement ring" using concealed identities and fake online storefronts to sell infringing products. This structure is common in anti-counterfeiting litigation against diffuse international online sellers.

Case Timeline

Date Event
2022-04-21 ’613 Patent Filing/Priority Date
2024-04-23 ’613 Patent Issue Date
2025-05-20 Complaint Filing Date

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

  • Patent Identification: U.S. Design Patent No. D1,023,613 S, titled "Door Hanger Organizer", issued April 23, 2024.

The Invention Explained

Design patents protect the unique, ornamental appearance of an article of manufacture, not its functional or structural features.

  • Problem Addressed: Unlike utility patents, design patents do not solve a technical problem. They provide a novel aesthetic design for an article. The complaint alleges that products associated with the ’613 Patent are recognized by consumers (Compl. ¶15).
  • The Patented Solution: The patent claims the specific ornamental design for a "door hanger organizer" as depicted in its drawings (’613 Patent, "CLAIM"). Key visual features include an elongated, rectangular body with four tiered, horizontally-oriented pockets of equal size. The top of the organizer features four circular hook holes arranged horizontally. The design as a whole presents a clean, symmetrical, and minimalist appearance (e.g., ’613 Patent, FIG. 1). A perspective view illustrates how the article is intended to be hung from hooks on a door (’613 Patent, FIG. 7).
  • Technical Importance: The commercial value of the design lies in its distinct visual appearance, which, according to the complaint, consumers associate with the Plaintiff's authorized products (Compl. ¶15).

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is: "The ornamental design for a door hanger organizer, as shown and described." (’613 Patent, "CLAIM"). The scope of this claim is defined by the patent's drawings.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Infringing Products" sold through numerous "Defendant Internet Stores" listed in a sealed Schedule A (Compl. ¶19). These are described as "illegal imitations" of Plaintiff's "Honeyera Products" (Compl. ¶13, ¶15).

Functionality and Market Context

The complaint alleges the accused products are unauthorized copies that infringe the ornamental design of the ’613 Patent (Compl. ¶6, ¶30). The focus of the allegations is less on the products themselves and more on the defendants' business practices, which are alleged to include operating under fictitious names, using multiple online storefronts to evade enforcement, and concealing their identities and locations, which are believed to be in China or other foreign jurisdictions (Compl. ¶18, ¶22, ¶23).

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or side-by-side visual comparison between the patented design and the accused products. The infringement theory is presented narratively.

The central allegation is that Defendants have made, used, offered for sale, or sold products that are "reproduction[s], cop[ies] or colorable imitation[s]" of the design claimed in the ’613 Patent (Compl. ¶30, ¶33.a). For design patent infringement, the legal test is whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design. The complaint asserts that the accused products are sufficiently similar to the patented design to cause such confusion (Compl. ¶¶6, 13).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Factual Question: The primary question for the court will be factual: do the accused products sold by Defendants embody a design that is "substantially the same" as the one claimed in the ’613 Patent? Answering this will require a visual comparison between the accused products and the patent's drawings.
  • Evidentiary Question: A threshold challenge for the Plaintiff will be to produce evidence—such as the physical products or high-quality photographs—of the items sold by each of the numerous, anonymous defendants to demonstrate the visual similarity required for infringement.

V. Key Claim Terms for Construction

In design patent litigation, the claim is understood to be the design itself as shown in the drawings. Formal claim construction of text is less common than in utility patent cases, but the court may issue a construction describing the ornamental features of the design.

  • The Term: "door hanger organizer"
  • Context and Importance: This phrase from the patent's title defines the "article of manufacture" to which the ornamental design is applied. Its interpretation is important for determining the scope of relevant prior art for any potential validity challenges. Practitioners may focus on this term to argue whether prior art for other types of storage solutions (e.g., wall-mounted pocket organizers, shoe racks) is analogous and thus relevant.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The phrase itself is relatively general and could be argued to encompass a variety of hanging organizers.
    • Evidence for a Narrower Interpretation: The figures, particularly the perspective view in Figure 7 showing the article mounted on a door with hooks, consistently depict an over-the-door article. This could support a narrower construction limiting the article of manufacture to an organizer specifically designed for use on a door (’613 Patent, FIG. 7).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that through their operation of the online stores, Defendants are "contributing to, inducing and engaging in the sale of Infringing Products" (Compl. ¶20). The prayer for relief also requests an injunction against "aiding, abetting, [or] contributing to" infringement (Compl. ¶33.b).
  • Willful Infringement: Willfulness is alleged based on the assertion that Defendants had "full knowledge of Honeyera ownership of the ‘613 Patent" and that their infringement has been "intentional, and in disregard of and with indifference to the rights of the Plaintiff" (Compl. ¶21, ¶31). The allegation of "significant copying" of the design further supports this claim (Compl. ¶19).

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

  1. A Core Evidentiary Question: Can the Plaintiff acquire and present evidence demonstrating that the products sold by the numerous, disparate online sellers are, in the eyes of an ordinary observer, "substantially the same" as the specific ornamental design claimed in the ’613 Patent? The outcome of the case hinges on this visual, factual comparison.
  2. A Question of Enforcement: Given the allegations of a diffuse network of foreign sellers actively concealing their identities (Compl. ¶¶9, 22), a central practical challenge will be effective enforcement. Can the Plaintiff successfully identify the Defendants, obtain jurisdiction, and locate assets to satisfy a potential judgment?
  3. A Question of Scope: A secondary issue may concern the scope of the design itself. Will the "article of manufacture" be construed narrowly as only an "over-the-door" organizer, or more broadly? This determination would be critical to assessing any prior art Defendants may raise in a validity defense.