The complaint
One Source to Market, LLC v. Henckels J.A. Zwilling, LLC, No. 2:26-cv-13118 (C.D. Cal.), is a 29-page complaint filed November 9, 2026, with a jury demand. The plaintiff, which does business as HexClad Cookware, is a California limited liability company with its principal place of business in Los Angeles, California. The complaint alleges, on information and belief, that the defendant is a Delaware limited liability company with its principal place of business in Pleasantville, New Jersey, and that it maintains an office in Commerce, California, and at least two outlet stores in the district, in Commerce and Riverside, California.
The marks and trade dress
The complaint asserts registered and common-law rights in the HexClad name and logos, and a trade dress it describes as the distinctive hexagonal pattern on HexClad cooking surfaces. USPTO TSDR shows four live Principal Register registrations owned by One Source To Market, LLC, or, for Registration No. 5,111,350, by One Source To Market, identified there as a limited liability company: Registration No. 5,111,350, HEXCLAD in standard characters, registered December 27, 2016 and renewed, for cookware, namely pots and pans, in Class 21; Registration No. 6,699,277, HEXCLAD in standard characters, registered April 12, 2022, for retail and online retail store services featuring cookware and kitchen tools, and retail and online retail store services featuring pots, pans, and lids, in Class 35; Registration No. 6,981,450, HEXCLAD in standard characters, registered February 14, 2023, for kitchen knives and steel cutlery in Class 8 and for mixing bowls and knife blocks in Class 21; and Registration No. 7,218,402, a design of the letters HC inside a hexagon with the word HEXCLAD to the right, registered November 14, 2023, for kitchen knives and steel cutlery in Class 8, for mixing bowls, knife blocks, non-electric cookware, namely pots and pans, non-electric woks, plates, cutting boards, and pot lids in Class 21, and for retail and online retail store services featuring cookware and kitchen tools in Class 35.
The alleged conduct
The complaint says One Source to Market began selling HexClad pans in the United States in 2016 and, beginning in 2017, promoted them through in-store demonstrations at Costco stores, along with online advertising and a television commercial. It alleges that Henckels introduced a hybrid cookware line under the name HXAGON at Costco at the start of 2024, using a hexagonal pattern the complaint calls a copy of HexClad's trade dress, and that Henckels offered HXAGON alongside HexClad at those demonstrations. It alleges, on information and belief, that Henckels struck a deal with Costco to introduce HXAGON in its stores. It attributes to Henckels a strategy of selling HXAGON at a lower price point and trading on goodwill associated with the HexClad brand, and it describes customer and press confusion that it ties to the HXAGON name and design, including warranty claims and returns sent to One Source to Market for Henckels pans.
The complaint says One Source to Market's counsel wrote to Henckels on March 8, 2024 and demanded that it stop using the HXAGON name or HexClad's trade dress, and that Henckels' counsel answered on March 27, 2024 with a letter denying any possibility of confusion or of trademark or trade dress infringement. It says Henckels then began marketing its hybrid cookware under the name Paradigm. It alleges, on information and belief, that Henckels made no other changes to its products, their designs, or its marketing practices, and that HXAGON-branded products are still being sold at certain retail outlets. It seeks damages for past trademark infringement through the earlier use of the HXAGON name, damages for past and continuing trade dress infringement and unfair competition, and a permanent injunction.
The claims and the prayer
Count I pleads federal trademark infringement under 15 U.S.C. § 1114(a). Count II pleads trade dress infringement, federal unfair competition, and false designation of origin under 15 U.S.C. § 1125(a). Count III pleads a violation of California Business and Professions Code § 17200 et seq. Count IV pleads common-law trademark and trade dress infringement. Count V pleads common-law unfair competition. The complaint asks the court to enter judgment for One Source to Market on all claims; to award damages under 15 U.S.C. §§ 1117 and 1125 and California statutory and common law; to order disgorgement of profits and restitution; to award costs, legal fees, and other expenses; to enjoin further infringement of the trademarks and trade dress; to award reasonable attorneys' fees and costs, including under 15 U.S.C. § 1117, which it seeks because it calls the case exceptional; and to award other appropriate relief.