DCT

2:20-cv-11606

Coplus Inc v. Zhejiang Yuanzheng Auto Motorcycle Accessories Co Ltd

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2017-03-03 '791 Patent application filed
2018-03-13 '791 Patent issued
2020-08-17 Plaintiff provides infringement notice to U.S. distributor Burnz Auto
2021-04-27 First Amended Complaint filed

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

U.S. Design Patent No. D812,791 - "Vehicle Light"

  • Patent Identification: U.S. Design Patent No. D812,791, "Vehicle Light", issued March 13, 2018

The Invention Explained

  • Problem Addressed: While design patents do not articulate a technical problem in the same manner as utility patents, the complaint suggests the commercial problem is the need to differentiate products in a competitive market. The complaint alleges the patented design is "distinctive" and has achieved "commercial success" by providing "differentiation to other competitors' designs" (Compl. ¶16).
  • The Patented Solution: The patent protects the specific ornamental, non-functional appearance of a vehicle headlight assembly (D'791 Patent, Claim). The protected design is defined by the visual characteristics shown in solid lines in the patent's figures, including the overall shape of the housing, the specific arrangement of the interior projector lens and accent lighting elements, and the bezel contours (D'791 Patent, Figs. 1-7). The patent explicitly disclaims the functional rear portions of the assembly by stating, "The broken lines in the drawings are for illustrative purpose only and form no part of the claimed design" (D'791 Patent, Description).
  • Technical Importance: The commercial importance of the design is asserted through the plaintiff's own practice of the patent for its aftermarket headlights for the Subaru WRX STI vehicle (Compl. ¶15).

Key Claims at a Glance

  • The patent contains a single claim: "The ornamental design for a vehicle light, as shown and described." (D'791 Patent, Claim).
  • The scope of this claim is defined by the visual representations in Figures 1-7 of the patent, limited to the features depicted in solid lines.

III. The Accused Instrumentality

Product Identification

The accused products are aftermarket vehicle headlights for the 2015-2019 Subaru WRX STI vehicle, identified in the complaint as the "Subaru Infringing Product" (Compl. ¶18).

Functionality and Market Context

The accused products are alleged to be manufactured by Defendant Zhejiang under the brand name "VLAND" and distributed in the U.S. by third parties, such as Burnz Auto Accessories (Compl. ¶¶18, 19, 26). The complaint identifies advertisements for the products under the name "V1 Sequential Headlights 2015+ WRX STI" (Compl. ¶20). The complaint includes a photograph of the accused product installed on a vehicle, showing its appearance in its intended environment. (Compl. p. 7). These products function as direct replacements for the OEM headlights on the specified vehicle models.

IV. Analysis of Infringement Allegations

The complaint alleges infringement under the "ordinary observer" test, asserting that an ordinary consumer would be deceived by the substantial similarity between the patented design and the accused product (Compl. ¶34). To support this, the complaint provides a side-by-side visual comparison. This comparison shows a patent figure next to a photograph of the accused product, inviting a direct visual assessment of their similarity (Compl. p. 7, ¶34).

The core allegations can be summarized by comparing the prominent visual features of the patented design to those of the accused product as depicted in the complaint.

D'791 Patent Infringement Allegations

Claimed Design Feature (from D'791 Patent Figures) Alleged Infringing Feature (from Complaint Visuals) Complaint Citation Patent Citation
The overall exterior shape and contour of the headlight assembly as viewed from the front. The accused product is alleged to have the same overall exterior shape and front-facing contour. ¶¶33, 34 Fig. 2
A prominent C-shaped light-guide element forming the upper and side border of the assembly's interior. The accused product incorporates a C-shaped light-guide element in a visually identical position and shape. ¶¶33, 34 Fig. 2
A rectangular main projector lens assembly, offset toward the inner side of the unit. The accused product features a similarly shaped and positioned rectangular main projector lens assembly. ¶¶33, 34 Fig. 2
A series of horizontal, fin-like structures located below the main projector lens assembly. The accused product contains a series of horizontal, fin-like structures in a corresponding location. ¶¶33, 34 Fig. 2
  • Identified Points of Contention:
    • The Ordinary Observer Test: The central dispute will be whether an ordinary observer, familiar with the prior art, would find the designs substantially the same. This analysis will depend on the visual evidence presented at trial.
    • Role of Prior Art: The infringement analysis for a design patent is conducted in view of the prior art. A potential point of contention is whether the similarities between the patented design and the accused product are merely reflections of features already common in the prior art for automotive headlights. The complaint does not discuss specific prior art designs.
    • Impact of Branding: Defendant may argue that its "VLAND" branding on the accused products (Compl. ¶26, 27) mitigates any potential for consumer confusion. The question for the court will be whether such branding is sufficient to overcome a finding of substantial similarity in the designs themselves.

V. Key Claim Terms for Construction

In design patent cases, formal claim construction is rare. The "claim" is the design itself, as depicted in the drawings. However, disputes can arise over the scope of the design, particularly what is included and excluded.

  • The Term: "The ornamental design for a vehicle light"
  • Context and Importance: The scope of what this term covers is defined entirely by the solid and broken lines in the patent's figures. The distinction is critical because infringement can only be based on similarity to the protected aspects (solid lines) of the design. Practitioners may focus on this distinction to argue that any perceived similarities reside in the disclaimed, functional parts of the headlight (broken lines).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The solid lines in the drawings encompass the entire visible front face and side profile of the headlight, including its overall shape, lens configuration, and internal bezels, suggesting the design as a whole is protected (D'791 Patent, Figs. 1-2, 4-7).
    • Evidence for a Narrower Interpretation: The patent contains an explicit disclaimer: "The broken lines in the drawings are for illustrative purpose only and form no part of the claimed design" (D'791 Patent, Description). This language strictly limits the protected design to the elements shown in solid lines, excluding the rear housing, mounting points, and other functional hardware.

VI. Other Allegations

  • Indirect Infringement: While no separate count for indirect infringement is pleaded, the prayer for relief seeks to enjoin Defendant from contributing to and inducing infringement (Compl. p. 9, ¶b). The factual basis for such a claim may be inferred from allegations that Defendant, as the manufacturer, supplies the allegedly infringing headlights to U.S. distributors for resale (Compl. ¶¶18, 19).
  • Willful Infringement: The complaint alleges that Defendant's infringement is willful (Compl. ¶39). This allegation is based on the assertion that Defendant continued its infringing activities despite having actual or constructive notice of the ’791 Patent. The complaint points to the August 2020 notice letter sent to Defendant's U.S. distributor as a basis for this knowledge or willful blindness (Compl. ¶¶24, 39).

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

The resolution of this case will likely depend on the court's and/or jury's findings on a few central questions:

  • A core issue will be one of visual comparison: In the eye of an ordinary observer familiar with prior art aftermarket headlights, is the overall ornamental design of the accused "VLAND" product substantially the same as the design protected by the ’791 Patent?
  • A key evidentiary question will be the impact of prior art: To what extent are the similarities between the two designs also present in pre-existing headlight designs? The outcome of the infringement analysis may turn on whether the accused product is closer to the patented design than it is to the prior art.
  • A central factual question for willfulness will be one of notice: Does the pre-suit notice of infringement sent to Defendant's U.S. distributor constitute effective notice to the foreign manufacturer, Zhejiang, such that any subsequent importation or sale could be considered willful?