Hytto (Lovense) Wins Default Judgment in Massager Design Patent Case
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📋 Case Summary
| Case Name | Hytto Pte. Ltd. v. Schedule A Defendants |
| Case Number | 1:23-cv-15369 |
| Court | U.S. District Court for the Northern District of Illinois |
| Duration | Oct 2023 – Apr 2024 6 months |
| Outcome | Plaintiff Win — Default Judgment |
| Patents at Issue | |
| Accused Products | Massagers and sexual stimulation devices sold through internet storefronts |
Case Overview
The Parties
⚖️ Plaintiff
A Singapore-incorporated technology company, Lovense is a globally recognized brand in the connected adult wellness device market with a substantial IP portfolio.
🛡️ Defendant
Over 80 online store operators, predominantly China-based e-commerce sellers, accused of replicating Lovense’s ornamental designs on marketplace platforms.
Patents at Issue
This case involved two U.S. design patents covering the ornamental appearance of massager and sexual stimulation devices. Design patents protect unique visual characteristics rather than functional attributes.
- • US D792,980S — Ornamental appearance of a massager device
- • US D948,069S — Ornamental design of a sexual stimulation device
Designing a similar product?
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The Verdict & Legal Analysis
Outcome
The Northern District of Illinois **granted Hytto’s Motion for Entry of Default and Default Judgment** against all remaining Defaulting Defendants. This outcome reflects the procedural efficiency of multi-defendant Schedule A litigation when defendants fail to engage.
Key Legal Issues
The basis of the action was **patent infringement**, specifically the unauthorized reproduction and commercial sale of products bearing ornamental designs substantially similar to Hytto’s registered design patents. Under the “ordinary observer” test, infringement is found if an ordinary observer would be deceived into believing the accused design is the same as the patented design. The defendants’ default led the court to accept Hytto’s well-pled allegations as admitted, obviating a substantive infringement analysis.
Freedom to Operate (FTO) Analysis
This case highlights critical IP risks in consumer product design, especially in e-commerce. Choose your next step:
📋 Understand This Case’s Impact
Learn about the specific risks and implications from this litigation.
- View related design patents in the wellness technology space
- Identify active companies in design patent enforcement
- Understand procedural mechanics of default judgments
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High Risk Area
Connected adult wellness device designs
Active Enforcement
Hytto (Lovense) actively protecting IP
Strategic Protection
Layered, multi-generational design patents
✅ Key Takeaways
The Northern District of Illinois remains a favorable venue for Schedule A multi-defendant design patent enforcement actions.
Explore litigation trends →Design patents are highly effective enforcement tools in e-commerce infringement scenarios due to their visual nature.
Learn more about design patents →Frequently Asked Questions
The case involved two U.S. design patents: USD792,980S (Application No. US 29/589,750) and USD948,069S (Application No. US 29/780,753), covering the ornamental designs of massager and sexual stimulation devices.
The Defaulting Defendants failed to appear or respond to the complaint. Under Federal Rule of Civil Procedure 55, the court granted Hytto’s Motion for Entry of Default and Default Judgment against all non-dismissed defendants.
It reinforces the viability of Schedule A enforcement strategies for design patent holders facing large-scale e-commerce infringement, particularly against marketplace sellers operating across international supply chains.
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References
- USPTO Patent Full-Text Database
- PACER Case Locator
- Northern District of Illinois Court
- Cornell Legal Information Institute — Federal Rule of Civil Procedure 55
- PatSnap — IP Intelligence Solutions for Law Firms
This article is for informational purposes only and does not constitute legal advice. All case information is drawn from publicly available court records. For platform capabilities, visit PatSnap.