DCT
2:18-cv-01583
Eagle Eyes Traffic Industry USA Holding v. Ajp Distributors Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Eagle Eyes Traffic Industry USA Holding, LLC (Nevada)
- Defendant: AJP Distributors Inc. (California)
- Plaintiff’s Counsel: Inhouse Co. Law Firm
- Case Identification: 2:18-cv-01583, C.D. Cal., 02/27/2018
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is a California corporation with its principal place of business in the district, and conducts substantial business including the sale of the accused products within the district.
- Core Dispute: Plaintiff alleges that Defendant’s aftermarket projection headlights and their components infringe two design patents covering the ornamental appearance of a vehicular headlight assembly and a light guide bar.
- Technical Context: The patents relate to the aesthetic design of automotive aftermarket parts, a market where distinctive visual appearance is a primary driver of consumer choice.
- Key Procedural History: The complaint does not mention any prior litigation, inter-partes review proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2012-03-29 | U.S. Patent No. D706,967 Application Filing Date |
| 2012-12-04 | U.S. Patent No. D690,040 Priority Date |
| 2013-09-17 | U.S. Patent No. D690,040 Issued |
| 2014-06-10 | U.S. Patent No. D706,967 Issued |
| 2018-02-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D690,040 - Exterior Surface Configuration of a Vehicular Headlight, Issued September 17, 2013
The Invention Explained
- Problem Addressed: In the field of automotive components, there is a constant need for new and original ornamental designs to distinguish products in the marketplace. The '040 Patent addresses the need for a novel aesthetic for a vehicle headlight assembly.
- The Patented Solution: The patent claims the specific ornamental design for a vehicular headlight as depicted in its figures ('040 Patent, Claim 1). The design features a vertically-oriented rectangular housing with two square upper lamp portions and two lower circular projector-style lamp portions, each of which is wrapped by a U-shaped light bar element, creating a stacked, symmetrical appearance ('040 Patent, Figs. 1-2).
- Technical Importance: The design provides a distinct visual signature for a vehicle's front end, combining geometric shapes (squares, circles) and modern lighting elements (projector lamps, light bars) into a cohesive assembly.
Key Claims at a Glance
- The patent contains a single claim for the ornamental design shown in the drawings (Compl. ¶14).
- The prominent visual features of the claimed design include:
- A generally rectangular housing.
- A stacked, two-over-two arrangement of four primary light sources.
- Two upper light sources with a generally square or rectangular shape.
- Two lower light sources with a circular, projector-style appearance.
- A distinct U-shaped or semi-circular light guide bar element encircling the bottom and sides of each of the two lower projector lamps.
U.S. Design Patent No. D706,967 - Light Guide Bar For Vehicle Lamp, Issued June 10, 2014
The Invention Explained
- Problem Addressed: Similar to the '040 Patent, the '967 Patent addresses the need for a new and distinct ornamental design, but for a specific component within a vehicle lamp rather than the entire assembly.
- The Patented Solution: The patent claims the ornamental design for a "light guide bar," which is a component used to create illuminated accents in modern vehicle lamps ('967 Patent, Claim 1). The design consists of a C-shaped or hooked bar with a rectangular cross-section, featuring a prominent curve that transitions into two straight, perpendicular arms of unequal length ('967 Patent, Figs. 1, 4).
- Technical Importance: This component design allows for the creation of unique, linear lighting signatures, often used as daytime running lights or accent lights, that can define the style of a headlight assembly.
Key Claims at a Glance
- The patent contains a single claim for the ornamental design shown in the drawings (Compl. ¶25).
- The prominent visual features of the claimed design include:
- An open, C-shaped or U-shaped overall profile.
- A continuous, curved lower section.
- Two upwardly-extending, straight arms.
- A generally rectangular cross-sectional shape throughout the bar.
III. The Accused Instrumentality
Product Identification
The complaint identifies "Defendant's projection headlights" as the accused products (Compl. ¶8). Specifically, it names the "GMC Sierra U-Bar Halo Projector Headlights" as infringing the '040 Patent and the "Light Guide Bar incorporated in its F-150 3D Halo Projector Headlights" as infringing the '967 Patent (Compl. ¶¶14, 29). The complaint states these products are sold on platforms including Amazon.com and Ebay.com (Compl. ¶5).
Functionality and Market Context
The accused products are aftermarket headlights designed to replace original equipment manufacturer (OEM) headlights on specific vehicle models (Compl. ¶¶14-15, 29). Their primary function is illumination, but their market appeal is driven by their custom aesthetic, which alters the stock appearance of the vehicle. The complaint alleges these products incorporate the patented designs to attract customers (Compl. ¶¶15-16, 26-27). The complaint includes a side-by-side visual comparison of the patented '040 design and a photograph of the accused "GMC Sierra U-Bar Halo Projector Headlight" from an Amazon product listing (Compl. ¶15, p. 5).
IV. Analysis of Infringement Allegations
D690,040 Infringement Allegations
| Claim Element (Visual Feature) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A stacked, two-over-two arrangement of four primary light sources. | The accused "GMC Sierra U-Bar Halo Projector Headlight" features a stacked arrangement of four light sources. | ¶15-16, p. 5 | '040 Patent, Claim 1; Fig. 2 |
| Two lower light sources with a circular, projector-style appearance. | The two lower lamps in the accused product are circular, projector-style lights. | ¶15-16, p. 5 | '040 Patent, Claim 1; Fig. 2 |
| A U-shaped light guide bar element encircling each of the two lower projector lamps. | The accused product features a prominent U-shaped light bar surrounding each of the two lower circular projector lamps. | ¶15-16, p. 5 | '040 Patent, Claim 1; Fig. 1 |
D706,967 Infringement Allegations
| Claim Element (Visual Feature) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An open, C-shaped or U-shaped overall profile. | The light guide bar in the accused headlight has a C-shaped profile. | ¶26-27, p. 9 | '967 Patent, Claim 1; Fig. 1 |
| A continuous, curved lower section transitioning into two upwardly-extending, straight arms. | The accused light guide bar, as shown in product photos, has a curved base and two straight, vertical arms. | ¶26-27, p. 9 | '967 Patent, Claim 1; Fig. 4 |
Identified Points of Contention
- Scope Questions: The central question for both design patents will be whether an "ordinary observer," giving the attention a typical purchaser would, would be deceived into believing the accused products are the same as the patented designs. The complaint directly alleges this legal standard is met (Compl. ¶¶19, 30). The dispute will hinge on the overall visual similarity, not on a technical or functional comparison.
- Technical Questions: While not a technical case, the comparison will require a visual analysis of the designs as a whole. A question for the court will be which visual features dominate the overall impression of the designs and whether minor differences, if any, between the patent figures and the accused products are sufficient to avoid a finding of substantial similarity. The complaint provides a close-up photo comparison for the '967 Patent, which may allow for a detailed examination of the bar's surface texture and proportions (Compl. ¶27, p. 9).
V. Key Claim Terms for Construction
In design patent litigation, the claim is the design itself as depicted in the drawings, and traditional claim construction of written terms is generally not performed. The analysis focuses on the scope of the claimed design as a whole. The "construction" issue is therefore the interpretation of the overall visual impression of the design.
- The "Term": The overall ornamental design of the "vehicular headlight" ('040 Patent) and the "light guide bar" ('967 Patent).
- Context and Importance: The scope of the design protection is the core of the case. A broader interpretation focusing on the general layout and arrangement of elements would favor the plaintiff, while a narrower interpretation focusing on precise proportions, curvatures, and surface details could favor the defendant.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The solid lines in the patent drawings define the claimed design. An interpretation could focus on the overall visual effect created by the combination of elements shown in solid lines—the stacked lamps and U-bars for the '040 Patent, and the C-shape for the '967 Patent—arguing these are the dominant features an ordinary observer would notice.
- Evidence for a Narrower Interpretation: A party could argue that the specific angles, curves, and relative proportions shown in the figures are integral to the design and that any deviation is significant. For the '040 Patent, for example, the exact shape of the inner bezels and the width-to-height ratio could be argued as limiting the scope ('040 Patent, Fig. 2). For the '967 Patent, the precise curvature and the length of the straight arms could be argued as defining the boundaries of the claimed design ('967 Patent, Fig. 1).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant is aware that its customers and end-users use the accused products in an infringing manner based on online discussions (Compl. ¶9). It further alleges that Defendant "intentionally sells, ships or otherwise delivers the accused products... with knowledge that are designed to and do practice the infringing features" ('040 Patent) and that the products "imitate and in fact infringe" ('967 Patent), which may support a claim for induced infringement (Compl. ¶¶21, 32).
- Willful Infringement: The complaint alleges knowledge of infringement "since at least the filing of this complaint" for both patents (Compl. ¶¶13, 24). It also pleads that Defendant "intentionally" sells products that "imitate and in fact infringe," which could form the basis for a willfulness claim based on either pre- or post-suit conduct (Compl. ¶¶21, 32).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be the application of the "ordinary observer" test: viewing the designs as a whole, are the accused AJP Distributor headlights "substantially the same" as the designs claimed in the '040 and '967 patents? The case will likely depend on a side-by-side visual comparison and arguments over which features dominate the overall aesthetic impression.
- A secondary question may involve design element scope: does the '967 patent for the "Light Guide Bar" cover a standalone component, and does infringement of the '040 "Vehicular Headlight" assembly patent necessarily follow from the incorporation of a substantially similar light bar? The relationship between the component patent and the assembly patent may become a point of legal argument.
- A key evidentiary question will be one of intent: what evidence, beyond the conclusory allegations in the complaint, will Plaintiff present to demonstrate that Defendant's alleged infringement was willful, particularly for the period before the lawsuit was filed?