Aperçu du dossier

In a decisive outcome resolved in just 118 days, the U.S. District Court for the Northern District of Illinois entered a default judgment and permanent injunction in favor of Hexin Holding Limited against a network of anonymous online sellers accused of infringing a registered U.S. design patent on shapewear products. Case No. 1:25-cv-12564, closed on February 10, 2026, under Chief Judge Andrea R. Wood, illustrates the growing effectiveness of the “Schedule A” enforcement model—a litigation strategy increasingly used by IP holders to combat e-commerce counterfeiting at scale.

The case centered on Design Patent USD1066881S (Application No. 29/877074), protecting the ornamental appearance of a shapewear bearing product. Plaintiff Hexin Holding, represented by YK Law LLP, secured not only a permanent injunction but also court-ordered asset seizures directly from Amazon and TikTok marketplace accounts—a significant enforcement outcome for design patent holders operating in competitive online retail markets.

Les parties

Le brevet en cause

This case centered on U.S. Design Patent USD1066881S (Application No. 29/877074), protecting the ornamental appearance of a shapewear bearing product. Design patents under 35 U.S.C. § 171 protect the unique visual characteristics of a manufactured article. Unlike utility patents, design patent infringement is assessed through the “ordinary observer” test established in *Egyptian Goddess, Inc. v. Swisa, Inc.* (Fed. Cir. 2008)—asking whether an ordinary observer would find the accused design substantially similar to the patented design.

• • US D1066881S — Ornamental design of a shapewear bearing product

Les produits incriminés

The infringing products were shapewear bearing items sold through online marketplace seller aliases on Amazon and TikTok Shop, platforms that have become central battlegrounds in design patent enforcement against counterfeit and copycat goods.

Représentation juridique

• • Plaintiff’s Counsel: Faye Yifei Deng, YK Law LLP (Los Angeles, CA)
• • Defendant’s Counsel: None on record — a key factor enabling default judgment

Litigation Timeline & The Verdict

Chronologie du litige et historique de la procédure

The case was filed in the Northern District of Illinois, a preferred venue for Schedule A design patent actions due to its established procedural familiarity with high-volume e-commerce infringement cases and receptiveness to ex parte temporary restraining orders (TROs) and asset freezes. The 118-day resolution is notably expedient, consistent with default judgment timelines in Schedule A cases where defendants—typically anonymous offshore sellers—fail to appear or respond. Chief Judge Andrea R. Wood presided over the matter at the district court (first instance) level. The rapid closure reflects both the procedural posture of an uncontested default and the streamlined enforcement mechanisms available under this litigation model.

Résultat

The court entered default judgment in favor of Hexin Holding Limited, finding Defaulting Defendants liable for design patent infringement under 35 U.S.C. § 271. The judgment included:

• • A permanent injunction restraining all infringing activity
• • Damages awarded under 35 U.S.C. § 289 (infringer’s total profits)
• • Mandatory asset seizure from Amazon and TikTok financial accounts
• • Release of Plaintiff’s $10,000 cash bond

Note: Specific per-defendant damages amounts are referenced in Schedule A of the judgment but were not individually disclosed in the case summary provided.

Analyse des causes du verdict

Liability was established through default under Federal Rule of Civil Procedure 55, triggered by defendants’ failure to appear or respond to the complaint. Under Rule 55, a defaulting party is deemed to have admitted all well-pleaded allegations of the complaint—here, that defendants sold shapewear products bearing the protected ornamental design without authorization.

The court’s infringement finding under 35 U.S.C. § 271 confirms that unauthorized use, sale, or offering for sale of a patented design constitutes direct infringement. Damages were assessed under 35 U.S.C. § 289, the design patent-specific damages statute providing for recovery of the infringer’s total profits—a more plaintiff-favorable standard than the apportionment often required under utility patent damages law (35 U.S.C. § 284).

Permanent Injunction Scope

The injunction issued is notably comprehensive, covering:

• • Prohibition on all use of USD1066881S in connection with unauthorized products
• • Bar on passing off infringing goods as genuine Hexin products
• • Prohibition on acts likely to cause consumer confusion as to sponsorship or approval
• • Embargo on manufacturing, shipping, storing, or distributing infringing inventory

Platform-specific orders directed Amazon and TikTok to:

• • Disable associated seller accounts within 7 calendar days
• • Cease displaying advertisements connected to infringing listings
• • Release frozen funds to Plaintiff within 14 calendar days

Signification juridique

This judgment reinforces several critical legal principles:

Design Patent Damages Under § 289: The court’s application of § 289—total profit disgorgement—underscores why design patents remain powerful enforcement tools, particularly post-*Samsung Electronics Co. v. Apple Inc.* (U.S. 2016), which clarified that “article of manufacture” for § 289 purposes may be a component rather than an entire product.

Platform Accountability: Direct orders to Amazon and TikTok to freeze and release funds represent the maturation of judicial willingness to treat third-party platforms as enforceable intermediaries—a trend with significant implications for IP enforcement architecture.

Schedule A Litigation Efficacy: Default rates in Schedule A cases remain high, validating this model as a cost-effective tool for IP holders facing diffuse, anonymous infringement networks.