DCT
2:24-cv-09275
Chenfan Ji v. Partnership Or Unincorp Association
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Chenfan Ji (People's Republic of China)
- Defendant: The Partnership or Unincorporated Association Identified on Schedule “A” and Amazon.com, Inc. (Delaware)
- Plaintiff’s Counsel: Au Law Office, P.C.
- Case Identification: 2:24-cv-09275, C.D. Cal., 10/28/2024
- Venue Allegations: Venue is alleged based on Defendants’ sales of infringing products within the district, derivation of substantial revenue from those sales, and, for Amazon.com, the maintenance of a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendants’ ring light products infringe a U.S. design patent covering the ornamental design for an "Annular Remote Control Photography Supplement Lamp."
- Technical Context: The dispute concerns consumer-grade LED ring lights, a product category widely used for photography, video conferencing, and social media content creation.
- Key Procedural History: No prior litigation, licensing history, or other significant procedural events are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2020-06-03 | Priority Date for U.S. Patent No. D965,668 |
| 2022-10-04 | U.S. Patent No. D965,668 Issued |
| 2024-07-25 | Accused "AMBITFUL" Product Listing Accessed |
| 2024-10-22 | Accused "Hagibis" Product Listing Accessed |
| 2024-10-28 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D965,668 - Annular Remote Control Photography Supplement Lamp
Issued October 4, 2022 (the “’668 Patent”).
The Invention Explained
- Problem Addressed: The complaint does not describe a specific problem addressed by the patent. Design patents protect the ornamental appearance of an article of manufacture, not its functional utility (Compl. ¶1, 9; ’668 Patent, Claim).
- The Patented Solution: The ’668 Patent claims the specific ornamental design for a ring-shaped photography lamp. The claimed design, depicted in solid lines in the patent's figures, features a simple, smooth, unadorned front face and a more complex rear housing (D’668 Patent, FIG. 2). The rear housing is characterized by a distinctive pattern of vents, including an outer ring of repeating leaf-like cutouts and an inner ring of elongated rectangular cutouts (D’668 Patent, FIG. 3). The design also includes a specific configuration for the mounting bracket at the bottom of the ring. Portions of the lamp shown in broken lines, such as internal components, are explicitly disclaimed and do not form part of the claimed design (D’668 Patent, Description).
- Technical Importance: The complaint does not allege any specific technical importance; the focus is on the ornamental design (Compl. ¶13).
Key Claims at a Glance
- The single claim of the ’668 Patent is for "The ornamental design for annular remote control photography supplement lamp, as shown and described" (D'668 Patent, Claim). This claim protects the overall visual appearance of the lamp as depicted in the patent's drawings.
III. The Accused Instrumentality
Product Identification
The complaint identifies two accused product lines: the "Hagibis 21 inch Ring Light" and the "AMBITFUL KN-21C 21inch... Ring Light" (collectively, the "Infringing Products") (Compl. ¶11, 12).
Functionality and Market Context
The accused products are described as large, dimmable LED ring lights sold with tripods, phone holders, and remote controls (Compl. ¶11, 12). They are marketed for applications such as video streaming, makeup application, vlogging, and video conferencing, and are sold on Amazon.com (Compl. ¶10, 11, 12). The complaint includes an image of the "Hagibis" product, which shows the rear of the ring light, its controls, and included accessories. (Compl. p. 5).
IV. Analysis of Infringement Allegations
The complaint asserts that in the eye of an ordinary observer, the accused products are "substantially the same" as the patented design (Compl. ¶13). While the complaint does not provide a detailed element-by-element comparison, it provides images of the patented design and the accused products, which allows for a comparison of their ornamental features. The image on page 6 of the complaint depicts the "AMBITFUL" product and its accessories (Compl. p. 6).
’668 Patent Infringement Allegations
| Ornamental Feature of the Claimed Design (from D'668 Patent) | Alleged Infringing Feature (from Complaint Images) | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall annular, ring-shaped configuration of the lamp housing. | The accused products have an annular, ring-shaped housing. | ¶11, 12; p. 5, 6 | FIG. 1, 2, 3 |
| The smooth, unadorned front surface of the lamp ring. | The accused products appear to have a smooth, unadorned front surface diffuser. | ¶12; p. 6 | FIG. 2 |
| The specific ornamental pattern of vents on the rear of the housing, including outer leaf-like cutouts and inner rectangular cutouts. | The accused products feature a vented rear housing. The specific pattern shown in the complaint's images will be a key point of comparison. | ¶11; p. 5 | FIG. 3 |
| The configuration of the mounting bracket area at the bottom of the ring. | The accused products have a mounting bracket area at the bottom of the ring for attachment to a tripod. | ¶11, 12; p. 5 | FIG. 1, 3 |
Identified Points of Contention
- Ornamental vs. Functional Features: A likely point of contention will be whether certain features of the design, such as the annular shape and the rear venting pattern, are dictated by function (e.g., even light distribution, heat dissipation) or are primarily ornamental. The weight given to allegedly functional features in the infringement analysis is a common issue in design patent cases.
- Scope Questions: The core question for the court will be whether the overall visual impression of the accused products is "substantially the same" as the claimed design. This will involve comparing the specific details, particularly the rear vent pattern shown in the patent's Figure 3, with the patterns on the accused products as depicted in the complaint's exhibits (Compl. ¶13; p. 5).
V. Key Claim Terms for Construction
In design patent cases, the "claim" is the visual design itself, as depicted in the drawings. Construction focuses on the scope of the design rather than the definition of words.
- The "Term": The scope of the claimed design as defined by the solid lines in the drawings.
- Context and Importance: The determination of what is claimed (solid lines) versus what is unclaimed environment (broken lines) is fundamental. The analysis will focus on which visual features an ordinary observer would consider part of the overall design, with the rear ventilation pattern being a particularly prominent and detailed feature.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Scope: The title Annular... Lamp and the overall form factor could suggest that the patent's scope covers a general class of ring lights, with less emphasis on the specific details of the rear housing (D'668 Patent, Title). The disclaiming of internal components via broken lines means the design is not limited by the specific type of lighting technology used (D'668 Patent, Description).
- Evidence for a Narrower Scope: The detailed and specific rendering of the rear ventilation pattern in Figure 3, with its distinct repeating leaf-like and rectangular shapes, is a significant part of the overall ornamental appearance (D'668 Patent, FIG. 3). A court could find that this specific pattern is a critical limitation of the design, meaning only products with a highly similar pattern would be considered infringing. The patent's description explicitly states that "broken lines... form no part of the claimed design," reinforcing that the claim is limited to the visual features shown in solid lines (D'668 Patent, Description).
VI. Other Allegations
- Indirect Infringement: The complaint includes a conclusory allegation that Defendants "induce, aid, or authorize others to import" the accused products, but does not plead specific facts to support this claim (Compl. ¶14).
- Willful Infringement: Willfulness is alleged based on the belief that "Defendants have notice of the ’668 Patent, and their infringing acts are deliberate and intentional" (Compl. ¶19). The complaint does not specify whether this alleged notice was pre-suit or post-suit.
VII. Analyst’s Conclusion: Key Questions for the Case
- The Ordinary Observer Test: The central issue is one of design patent infringement: from the perspective of an ordinary observer familiar with prior art ring lights, is the overall ornamental design of the accused "Hagibis" and "AMBITFUL" products substantially the same as the design claimed in the ’668 Patent?
- Significance of the Rear Pattern: A key evidentiary question will be how much weight is given to the specific, detailed ventilation pattern on the rear of the lamp housing. The case may turn on whether the accused products' rear patterns are close enough to the patent's distinctive "leaf-like" and rectangular cutouts to create the same overall visual impression.
- Functionality vs. Ornamentality: The dispute may involve the distinction between functional and ornamental features. A court will have to consider arguments over whether features like the ring shape and the presence of vents are dictated by function, which could diminish their importance in the infringement analysis, or if the specific appearance of these features is primarily ornamental and protected by the patent.