Hexin Holdings Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Hexin Holding Limited (Hong Kong)
  • Defendant: Caroti and the Individual and/or Entity Operating Caroti (Unknown Jurisdiction)
  • Plaintiff's Counsel: YK Law LLP
• Case Identification: 1:26-cv-04877, N.D. Ill., 05/07/2026
• Venue Allegations: Venue is asserted based on the defendant being a foreign entity believed to be engaged in infringing activities directed at the U.S., including selling and importing products into the Northern District of Illinois.
• Core Dispute: Plaintiff alleges that Defendant's e-commerce sales of shapewear infringe a U.S. design patent for a shaped support belt.
• Technical Context: The dispute is in the consumer apparel market, specifically concerning the ornamental design of women's shapewear, a product category where visual appearance is a key market differentiator.
• Key Procedural History: The filing is an Amended Complaint. The Plaintiff notes it has patented over 126 different works related to its shapewear business, suggesting a broader intellectual property portfolio and enforcement strategy.

Case Timeline

Date	Event
2021-03-04	D'333 Patent Priority Date (Filing Date)
2021-10-19	U.S. Design Patent No. D933,333 Issues
2026-05-07	Complaint Filing Date

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

• Patent Identification: U.S. Design Patent No. D933,333, "Shaped Support Belt," issued October 19, 2021.
• The Invention Explained:
  • Problem Addressed: As a design patent, the '333 Patent does not articulate a technical problem; rather, it protects a novel, non-obvious, and ornamental design for an article of manufacture D'333 Patent, claim
  • The Patented Solution: The patent claims the specific ornamental appearance of a "shaped support belt" D'333 Patent, claim The design, illustrated across eleven figures, features a wide, hourglass-contoured belt body with a prominent, vertically-oriented rectangular front panel, which appears to be a closure mechanism D'333 Patent, Fig. 2 The design is further characterized by specific stitching, indicated by broken lines, which frames the central panels and runs along the top and bottom edges of the belt, forming part of the claimed design D'333 Patent, description D'333 Patent, Fig. 2
  • Technical Importance: The complaint alleges that Plaintiff's promotional efforts have caused the public to become familiar with the Hexin Design and associate it exclusively with Plaintiff's products Compl. ¶9
• Key Claims at a Glance:
  • The single claim of the '333 Patent is for "The ornamental design for a shaped support belt, as shown and described" D'333 Patent, claim
  • The protected design consists of the visual elements depicted in the patent's drawings, including:
    • The overall hourglass shape and proportions of the belt.
    • A large, rectangular front panel flanked by two narrower vertical panels.
    • The specific pattern of stitching (claimed via broken lines) that outlines the panels and the belt's perimeter.
  • The complaint reserves the right to assert infringement of other patents, but no other specific claims are identified Compl. ¶¶19, 21

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Infringing Products" identified as shapewear sold under the seller alias "Caroti" on an Amazon e-commerce storefront Compl. ¶1 Compl. ¶12 Compl., Amended Schedule A

Functionality and Market Context

The accused products are described on the Amazon listing as "Trainer-Cincher-Trimmer-Control-Shapewear" Compl., Amended Schedule A The complaint alleges that Defendant is a "sophisticated seller" operating through online marketplace platforms to sell infringing products at "below-market prices" Compl. ¶14 Plaintiff claims these activities are intended to mislead the public into believing the products emanate from Plaintiff, causing price erosion and loss of sales Compl. ¶11 Compl. ¶19

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendant's products infringe the '333 patent by embodying a design that is substantially the same as the patented design. The core of a design patent infringement analysis is the "ordinary observer" test, which involves a visual comparison of the claimed design and the accused product's design. As the complaint does not include images of the accused product, such a comparison cannot be made from the pleading alone.

D'333 Patent Infringement Allegations

Claim Element (from Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a shaped support belt, as shown and described.	The complaint alleges Defendant sells, offers for sale, and imports products that "feature" and "use" the patented Hexin Design, and that "embody or practice" the design.	¶19; ¶28; Prayer ¶1(a)	D'333 Patent, Figs. 1-11

• Identified Points of Contention:
  • Visual Similarity: The central question for the court will be whether an ordinary observer, giving the attention a purchaser usually gives, would be deceived into purchasing the accused "Caroti" product believing it to be the Plaintiff's patented design. This will require a side-by-side comparison of the accused product and the figures of the '333 patent.
  • Scope Questions: The analysis may focus on whether the accused product's overall visual impression is substantially the same as the claimed design, including the specific proportions, paneling configuration, and claimed stitching patterns shown in the '333 patent. Any differences in these features between the accused product and the patent drawings could form the basis of a non-infringement defense.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of claim construction. In design patent cases, the claim is typically understood to be defined by the drawings rather than by textual limitations, making formal claim construction a less central issue than in utility patent litigation. The dispositive analysis will likely be the visual comparison under the "ordinary observer" test.

VI. Other Allegations

• Willful Infringement: The complaint seeks treble damages, implying a charge of willful infringement Compl., Prayer ¶4 The factual basis for this allegation includes the assertion that the "Defendant is aware of Hexin Products and is aware that its illegal infringing actions alleged herein are likely to cause injury to Plaintiff" Compl. ¶16 The complaint further alleges that the Defendant is a "sophisticated seller" who participates in online forums with other infringers to discuss tactics for evading detection and litigation Compl. ¶14 Compl. ¶23

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

1. Identity and Jurisdiction: A threshold issue will be one of identification and service. Given that the Defendant is an unnamed individual or entity operating under a seller alias ("Caroti") and is believed to be foreign, the Plaintiff's ability to successfully identify, locate, and establish personal jurisdiction over the correct party will be critical to the case's progression.
2. Substantive Infringement: The core substantive question will be one of visual identity. Does the accused shapewear product sold by "Caroti" create an overall visual impression that is substantially the same as the ornamental design claimed in the D'333 patent in the eye of an ordinary observer? The outcome will depend entirely on a visual comparison that is not possible from the complaint alone.
3. Willfulness and Damages: Should infringement be found, a key question will be whether the Plaintiff can prove egregious conduct. The court will need to determine if the allegations of the Defendant's sophistication, knowledge of Plaintiff's brand, and active efforts to conceal its identity and evade enforcement are sufficient to meet the high standard for a finding of willful infringement and an award of enhanced damages.