Hexin Holdings Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Hexin Holding Limited (Hong Kong)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule “A” (foreign entities)
  • Plaintiff’s Counsel: YK Law LLP
• Case Identification: 1:25-cv-13116, N.D. Ill., 10/27/2025
• Venue Allegations: Venue is asserted on the basis that Defendants are foreign entities engaged in infringing activities, including offering to sell, selling, and importing products into the district, thereby causing harm within the district.
• Core Dispute: Plaintiff alleges that numerous foreign e-commerce store operators are selling shapewear products that infringe its U.S. design patent for a shaped support belt.
• Technical Context: The dispute is in the consumer apparel industry, specifically the women's shapewear market, where ornamental design is a significant driver of consumer choice and brand recognition.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history involving the patent-in-suit.

Case Timeline

Date	Event
2021-03-04	D933,333 Patent Priority Date (Application Filing Date)
2021-10-19	D933,333 Patent Issue Date
2025-10-27	Complaint Filing Date

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

U.S. Design Patent No. D933,333 - "SHAPED SUPPORT BELT"

• Patent Identification: U.S. Design Patent No. D933,333 ("the '333 Patent"), "SHAPED SUPPORT BELT," issued October 19, 2021.

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its utilitarian function. The '333 Patent addresses the creation of a new, original, and ornamental design for a shaped support belt. (’333 Patent, Title, Claim).
• The Patented Solution: The patent claims the specific visual appearance of the support belt as depicted in its figures. Key ornamental features include the overall hourglass-like contoured shape when viewed from the front, a wide central vertical fastening panel, and multiple horizontal bands creating a layered look. (’333 Patent, FIG. 1-2). The patent explicitly states that the broken lines in the drawings, which depict stitching patterns, form part of the claimed design, making the stitching a protected ornamental feature. (’333 Patent, Description).
• Technical Importance: In the shapewear market, the aesthetic design of a garment is critical to its commercial appeal and ability to be distinguished from competing products. (Compl. ¶¶9-10).

Key Claims at a Glance

• Design patents contain a single claim. The asserted claim is for "The ornamental design for a shaped support belt, as shown and described." (’333 Patent, Claim).
• The scope of this claim is defined by the visual illustrations in the patent, which include:
  • A perspective view (FIG. 1)
  • Front, rear, left side, right side, top, and bottom elevation views (FIGS. 2-7)
  • Views showing the belt with straps in unfolded and alternate configurations (FIGS. 8-11)

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "body contouring products" and "shapeware products" sold by Defendants. (Compl. ¶1, ¶18). These are collectively referred to as the "Infringing Products." (Compl. ¶1).

Functionality and Market Context

• The complaint alleges Defendants are "sophisticated sellers" operating e-commerce storefronts on platforms such as Amazon, Temu, Shein, and TikTok. (Compl. ¶15, ¶21). These products are allegedly advertised and sold using Plaintiff’s patented design to mislead consumers into believing the products are authorized by or emanate from Plaintiff. (Compl. ¶20). The complaint further alleges that Defendants use tactics such as operating under multiple seller aliases to conceal their identities and sell infringing goods at "below-market prices." (Compl. ¶15, ¶19).

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or include any images, screenshots, or other visual evidence of the accused products. The infringement theory is presented narratively, alleging that Defendants "are making, using, selling, offering for sale, and importing products bearing Plaintiff's patented design without authorization or license" (Compl. ¶1). The core allegation is that the ornamental appearance of the Defendants' shapewear products is substantially the same as the design claimed in the '333 Patent. (Compl. ¶18, ¶33). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: The central issue in a design patent case is the comparison of the accused product's design to the patented design from the perspective of an ordinary observer. Lacking any visual depiction of the accused products, the primary question for the court will be evidentiary: what is the actual ornamental design of the Defendants’ products, and is that design substantially the same as the one shown in the figures of the ’333 Patent?
  • Scope Questions: The infringement analysis may raise the question of whether minor differences between the accused products and the patent drawings are sufficient to avoid a finding of substantial similarity in the overall visual impression.

V. Key Claim Terms for Construction

In design patent litigation, claim construction is typically limited, as the drawings largely define the claim scope. However, the title of the patent can inform the scope of the article of manufacture.

• The Term: "shaped support belt"
• Context and Importance: This term, from the patent’s title, defines the article of manufacture to which the ornamental design is applied. Its interpretation is important because infringement requires the appropriation of the patented design on the same or a similar article. Practitioners may focus on this term if Defendants argue their products are a different article of manufacture (e.g., a medical brace, a fashion accessory corset) to which the design patent does not apply.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The general nature of the term "shaped support belt" could be argued to encompass a wide range of torso-covering garments intended for support or shaping, allowing the design to be applied to various products within the broader shapewear category. (’333 Patent, Title).
  • Evidence for a Narrower Interpretation: The specific visual characteristics shown in the patent's eleven figures, which depict a particular style of a flexible, wraparound garment, could be used to argue for a narrower definition limited to articles with a similar form factor and construction. (’333 Patent, FIGS. 1-11).

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendants are an "interrelated group of e-commerce sellers" who are "aware of Hexin Products" and have acted "knowingly and willfully" in using the patented design. (Compl. ¶17, ¶29). The prayer for relief seeks enhanced damages pursuant to 35 U.S.C. § 284 and recovery of Defendants' profits under 35 U.S.C. § 289, which is consistent with an allegation of willful infringement. (Compl. Prayer for Relief ¶4-5).

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

• A core issue will be one of visual comparison: As the complaint lacks any images of the accused products, the fundamental question will be evidentiary—what is the actual appearance of the Defendants' products, and would an ordinary observer, familiar with the prior art, be deceived into believing the accused design is the same as the patented design shown in the '333 Patent?
• A second key question will be one of enforcement and procedure: The case targets a large number of allegedly anonymous and foreign e-commerce sellers. A central challenge will be identifying the responsible parties and effectuating any judgment against a diffuse group of defendants who are alleged to be actively concealing their identities.