Amorepacific Corp. v. Juanhe Co. Ltd., No. 24 CV 12417 (N.D. Ill. July 15, 2025) (Jenkins, J.).
Judge Jenkins granted plaintiff Amorepacific’s summary judgment motion against defendant Juanhe for trademark infringement and false designation of origin involving the LANEIGE beauty brand.
The Court found no genuine dispute that Juanhe used the LANEIGE mark without authorization to sell lip kits through Walmart.com at significantly lower prices than genuine products. Juanhe’s argument that Amorepacific performed no physical examination of shipped products was rejected, with the Court holding that the statute requires only use of a mark likely to confuse consumers, not proof of inferior quality or physical inspection of the accused products.
The Court found willfulness based on Juanhe’s unauthorized use of obvious marks in advertising, demonstrating willful blindness. However, the Court awarded $45k in statutory damages rather than plaintiff’s requested $150k, considering the limited evidence of actual sales (29 units totaling $222), Juanhe’s cessation of sales after January 2025, and the lack of evidence of a large-scale counterfeiting operation.
The Court also awarded attorney’s fees under 15 U.S.C. § 1117(b), finding that willful blindness triggers the mandatory fee provisions for cases involving intentional use of counterfeit marks, and Juanhe identified no extenuating circumstances precluding such an award.