DCT

1:25-cv-09179

Honeyera LLC v. Partnerships Unincorp Associations

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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-09179, N.D. Ill., 08/04/2025
  • Venue Allegations: Venue is asserted based on Defendants operating interactive commercial internet stores that target and make sales to consumers in the United States, including Illinois.
  • Core Dispute: Plaintiff alleges that numerous online retailers are selling products that infringe its U.S. design patent for a door hanger organizer.
  • Technical Context: The dispute is in the consumer home goods sector, relating to the ornamental design of over-the-door storage and organization products.
  • Key Procedural History: The complaint does not allege any prior litigation, post-grant proceedings, or licensing history relevant to the patent-in-suit. It does allege that the defendants are part of a larger "illegal infringement ring" that employs common tactics to evade enforcement.

Case Timeline

Date Event
2022-04-21 U.S. Patent No. D1,023,613 Application Filing Date
2024-04-23 U.S. Patent No. D1,023,613 Issue Date
2025-08-04 Complaint Filing Date

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

  • Patent Identification: U.S. Design Patent No. D1,023,613 S, "DOOR HANGER ORGANIZER", issued April 23, 2024.

The Invention Explained

  • Problem Addressed: As a design patent, the patent does not address a technical problem but instead provides a "new, original, and ornamental design for an article of manufacture" ('613 Patent, p.1).
  • The Patented Solution: The patent protects the specific visual appearance of a door hanger organizer. The claimed design consists of the features shown in solid lines in the patent's figures, which depict a vertically oriented rectangular body with four stacked, horizontally elongated pockets and four circular holes at the top for hanging ('613 Patent, FIG. 1). The patent explicitly disclaims the environment of use, stating that the broken lines showing a door, hooks, and items within the pockets "form no part of the claimed design" ('613 Patent, col. 1:63-68).

Key Claims at a Glance

  • The patent contains a single claim for "The ornamental design for a door hanger organizer, as shown and described" ('613 Patent, col. 1:55-57).
  • The core ornamental features comprising the claimed design are:
    • A vertically elongated rectangular backing.
    • A series of four stacked, horizontal pockets affixed to the backing.
    • A set of four circular holes arranged horizontally across the top of the backing.

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products by name or model number. Instead, it refers to them collectively as "Infringing Products" sold by the anonymous Defendants through various "Defendant Internet Stores" (Compl. ¶¶ 13, 19).

Functionality and Market Context

The complaint alleges the accused products are "illegal imitations" and "colorable imitation[s]" of products associated with Plaintiff's patented design (Compl. ¶¶ 13, 33.a). These products are allegedly sold through "fake online storefronts" designed to appear as legitimate retailers but which sell "inferior imitations" (Compl. ¶13). The complaint alleges Defendants use these online stores to trade on Plaintiff's goodwill and reputation (Compl. ¶6).

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or a detailed, element-by-element comparison of the accused products to the patented design. The infringement theory is based on the general allegation that Defendants "sell online products that infringe directly and/or indirectly the ornamental design claimed in the ‘613 Patent" (Compl. ¶30). The core of the allegation is that the accused products are "colorable imitation[s]" of the design shown in the patent (Compl. ¶33.a). The complaint does not contain screenshots or other visual evidence of the accused products for comparison. For example, the complaint includes the patent-in-suit as Exhibit 1, which provides a front view of the claimed design showing four stacked pockets and four circular holes for hanging (Compl. ¶7, Ex. 1, FIG. 1). However, no corresponding visual of an accused product is provided.

  • Identified Points of Contention:
    • Evidentiary Question: A central issue will be whether Plaintiff can produce sufficient evidence to demonstrate that the products sold by the numerous, anonymous Defendants are in fact visually similar to the claimed design. The infringement test for a design patent is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing the accused product believing it is the patented design.
    • Scope Question: Given the simple geometry of the design, a question may arise as to the scope of protection and how different an accused product must be to avoid infringement.

V. Key Claim Terms for Construction

As this is a design patent case, claim construction does not focus on interpreting textual terms but rather on the scope of the claimed ornamental design as a whole, as depicted in the patent's drawings. The "claim" is the visual design itself.

  • The Term: "The ornamental design for a door hanger organizer, as shown and described."
  • Context and Importance: The entire infringement analysis will depend on the visual comparison between the accused products and the overall appearance of the design claimed in the '613 Patent. Practitioners may focus on the scope of the design as a whole, particularly how much deviation from the drawings is permissible before a design is no longer considered infringing.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that the claim covers the overall visual impression of a four-pocket vertical organizer with top hanging holes, and that minor variations in proportion or stitching should not defeat a finding of infringement.
    • Evidence for a Narrower Interpretation: A party could argue the design is strictly limited to the specific proportions and features depicted in the solid lines of the patent drawings. The explicit disclaimer of the door, hooks, and contents as mere environment of use strongly supports limiting the protected design to only the organizer itself ('613 Patent, col. 1:63-68).

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" through their operation of the online stores (Compl. ¶20). The prayer for relief also seeks to enjoin aiding and abetting infringement (Compl. ¶33.b).
  • Willful Infringement: Willfulness is alleged based on "information and belief" that Defendants had "full knowledge of Honeyera ownership of the ‘613 Patent" (Compl. ¶21). The complaint further alleges that the infringing acts were "willful, intentional, and in disregard of and with indifference to the rights of the Plaintiff" (Compl. ¶31).

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

This case presents as a "John Doe" enforcement action against a network of alleged online infringers, a common strategy for combating diffuse infringement on e-commerce platforms. The resolution will likely center on the following questions:

  1. An evidentiary question will be paramount: What proof will Plaintiff adduce to show that the products sold by the various anonymous Defendants are, in fact, "colorable imitations" of the patented design? Without direct visual comparisons in the complaint, the case will depend on evidence produced during discovery or proceedings for preliminary relief.

  2. A core issue will be one of infringement scope: Assuming evidence of the accused products is presented, the court will need to determine whether an ordinary observer would be deceived. This will involve comparing the accused products to the specific visual elements shown in solid lines in the '613 Patent's drawings, and may require consideration of prior art designs for similar organizers to determine the novelty and scope of the patented design.