Guangzhou Ganghun v. Schedule A Defendants — Design Patent Dispute Over Face Paint Palette Box
Guangzhou Ganghun Trade, Ltd. brought a design patent infringement action in the Northern District of Illinois against ten named e-commerce sellers — including Pozilan, Blue Squid, and CCbeauty — asserting USD0939776S, a design patent covering a palette box for face and body paint. The case resolved within 238 days of filing.
Swift closure in a multi-defendant face paint design patent dispute
Filed on 22 January 2024 in the U.S. District Court for the Northern District of Illinois before Judge LaShonda A. Hunt, this case (1:24-cv-00566) was brought by Guangzhou Ganghun Trade, Ltd. — a Chinese trading company — against a group of online marketplace sellers collectively identified as ‘The Partnerships and Unincorporated Associations identified in Schedule A.’ The asserted intellectual property is USD0939776S (application number US29/764139), a design patent protecting the ornamental appearance of a palette box used for face and body paint.
The case closed on 16 September 2024, approximately 238 days after filing. The public record does not specify a basis of termination — no verdict, settlement terms, or dismissal grounds are recorded in the available data. This ambiguity is consistent with confidential resolution or a voluntarily-filed stipulation of dismissal, both of which are common outcomes in Schedule A e-commerce enforcement actions.
A 238-day resolution is notably swift, suggesting the matter likely settled or was otherwise resolved before reaching substantive motion practice or trial. Schedule A cases of this type — targeting clusters of online sellers, often on Amazon or similar platforms — frequently resolve quickly once defendants are identified and served, or following a temporary restraining order that disrupts infringing sales. The absence of recorded defendant counsel is consistent with default or early settlement dynamics common to this enforcement model.
Filing to dismissal in 238 days
238-day duration — resolved well under the median for design patent cases in N.D. Illinois
Case closed without a publicly recorded basis of termination
Schedule A actions target clusters of online sellers simultaneously
The ‘Schedule A’ complaint structure — naming defendants collectively — is a well-established enforcement tactic in N.D. Illinois, particularly against Amazon, eBay, and Alibaba marketplace sellers. It allows a single filing to reach dozens of alleged infringers at once, lowering per-defendant enforcement costs and enabling rapid ex parte TRO and asset-freeze motions before defendants can transfer funds or dissolve storefronts.
Multi-defendant e-commerce enforcementNo termination basis on record — what does that mean?
When a case closes without a recorded basis of termination, the public record is silent on whether it ended by settlement, voluntary dismissal with prejudice, voluntary dismissal without prejudice, or default judgment. Each carries distinct legal consequences. A dismissal with prejudice bars refiling; one without prejudice preserves the plaintiff’s right to re-assert. The distinction matters for defendants assessing ongoing risk, but cannot be determined from available data here.
Termination basis unrecordedDesign patents protect ornamental appearance, not functional features
USD0939776S is a design patent — it protects only the specific ornamental appearance of the palette box as depicted in the patent drawings. Competitors who sell functionally similar face and body paint palette boxes are not necessarily infringing: if the overall visual impression of their product differs sufficiently from the patented design, no infringement arises. This narrow scope can encourage early settlement once defendants assess their design against the patent figures.
Ornamental design — narrow scopeAbsence of defence counsel suggests default or rapid settlement
No defendant law firm or attorney is recorded in the case data — a pattern consistent with two common Schedule A outcomes: defendants failing to appear (leading to default judgment) or defendants settling quickly, often via confidential agreement, before filing a formal appearance. The speed of resolution (238 days) and absence of docket activity on the defence side both point toward an early resolution rather than contested litigation.
No defence counsel on recordFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Guangzhou Ganghun Trade, Ltd. | Company | Chinese trading company and e-commerce IP enforcer — holder of USD0939776SSearch in Eureka ↗ |
| Defendant | The Partnerships and Unincorporated Associations identified in Schedule A | Company | Group of online marketplace sellers including Pozilan, Blue Squid, CCbeauty, and seven othersSearch in Eureka ↗ |
| Plaintiff counsel | Hao Ni | Attorney | Counsel for Guangzhou Ganghun Trade, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Nicholas Edward Najera | Attorney | Counsel for Guangzhou Ganghun Trade, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Stevenson Moore | Attorney | Counsel for Guangzhou Ganghun Trade, Ltd.Search in Eureka ↗ |
| Presiding judge | Judge LaShonda A. Hunt | Chief Judge | Illinois Northern District Court — Chief JudgeSearch in Eureka ↗ |
Stipulation of dismissal — official text
No verdict is recorded in the public case data for Case No. 1:24-cv-00566. The case closed on 16 September 2024 without a publicly available ruling, judgment, or stated basis of termination. This outcome is consistent with confidential settlement or voluntary dismissal — both common in Schedule A e-commerce enforcement actions — but the specific resolution terms and their legal effect on each named defendant cannot be confirmed from available records.
USD0939776S — Ornamental Design for a Face & Body Paint Palette Box
USD0939776S (filed as application US29/764139) is a U.S. design patent protecting the ornamental appearance of a palette box designed for face and body paint products. Design patents under 35 U.S.C. § 171 cover only the visual, non-functional aspects of a product as depicted in the patent’s drawings — they do not protect the underlying utility or function of the item. The scope of protection is determined by the ‘ordinary observer’ test: whether an ordinary purchaser would be deceived into believing an accused product is the same as the patented design.
In the competitive face and body paint accessories market — heavily concentrated on platforms such as Amazon and AliExpress — ornamental packaging and palette design can be a meaningful differentiator. A design patent like USD0939776S gives its holder a legally enforceable tool to challenge sellers offering visually similar products, even if those products are functionally equivalent. For competitors in this category, the patent represents a clear design exclusion zone that should be evaluated before launching similar palette products in the U.S. market.
Should you run an FTO analysis against USD0939776S?
Any company manufacturing, importing, or selling face and body paint palette boxes for the U.S. market should assess whether their product’s visual design falls within the scope of USD0939776S. This is particularly relevant for Amazon marketplace sellers, private-label cosmetics brands, and face paint kit manufacturers. The ‘ordinary observer’ standard used for design patent infringement is relatively broad — a product need not be identical to infringe, only substantially similar in overall visual impression.
PatSnap Eureka’s FTO Search Agent allows product and IP teams to map USD0939776S’s design claims against existing product lines and identify design-around opportunities. Running a freedom-to-operate search now — before U.S. market entry — can surface infringement risk early and inform design modifications that avoid the patented aesthetic. Claim monitoring alerts can also flag any continuation or related design applications filed by Guangzhou Ganghun that might extend the protected design family.
Run a freedom-to-operate analysis on USD0939776S to assess your product’s exposure
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What this case signals for the e-commerce design patent enforcement landscape
Schedule A actions are a growing enforcement vector for IP holders targeting online marketplaces. Here is what practitioners and product teams should know.
N.D. Illinois remains the dominant venue for Schedule A IP enforcement
The Northern District of Illinois — particularly Chicago — has become the preferred forum for Schedule A e-commerce IP actions in the U.S. Its courts have established efficient procedures for ex parte TROs and asset freezes targeting marketplace sellers. Companies sourcing or selling consumer goods through online platforms should monitor dockets in this district for competitive intelligence.
Design patents are a cost-effective tool against marketplace copycats
Design patents are cheaper and faster to obtain than utility patents and can be highly effective against e-commerce sellers copying product aesthetics. For consumer goods with distinctive visual designs — like this face paint palette — a design patent portfolio can support rapid, low-cost enforcement actions against multiple defendants simultaneously, often resolving before significant litigation cost is incurred.
Guangzhou v The — key questions answered
Case 1:24-cv-00566 is a design patent infringement action filed by Guangzhou Ganghun Trade, Ltd. in the Northern District of Illinois on 22 January 2024. The plaintiff asserted USD0939776S — a design patent covering a palette box for face and body paint — against ten named online marketplace sellers including Pozilan, Blue Squid, and CCbeauty. The case closed on 16 September 2024 after 238 days.
USD0939776S (application number US29/764139) is a U.S. design patent protecting the ornamental appearance of a palette box for face and body paint. Design patents cover only visual, non-functional aspects of a product. Infringement is assessed under the ‘ordinary observer’ test — whether an ordinary purchaser would be deceived into thinking an accused product is the same as the patented design.
The Northern District of Illinois has become a preferred venue for Schedule A IP enforcement actions because its courts have developed efficient procedures for ex parte temporary restraining orders and asset freezes targeting online marketplace sellers. These procedural advantages allow plaintiffs to act quickly against multiple defendants — often freezing marketplace accounts and PayPal funds — before defendants can respond or move assets.
When a federal case closes without a recorded basis of termination, the public docket does not reveal whether it ended via settlement, voluntary dismissal (with or without prejudice), or default judgment. Each outcome has different legal consequences — particularly regarding whether the plaintiff can refile and whether defendants remain at legal risk. The specific resolution in Case 1:24-cv-00566 cannot be confirmed from available public data.
Companies selling face and body paint palette boxes in the U.S. — particularly through online marketplaces — should assess their product designs against USD0939776S. Design patent infringement does not require an identical product; substantial visual similarity under the ‘ordinary observer’ test is sufficient. A freedom-to-operate analysis against the patent’s drawings is advisable before U.S. market launch or expansion.
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