2:25-cv-03802
LFA Co Ltd v. Nanjing 9000 E Commerce Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LFA Co. Ltd. (Taiwan)
- Defendant: NANJING 9000 E-COMMERCE CO., LTD. (China); Nanjing Zumalan Information Technology Co., Ltd. (China); et al.
- Plaintiff’s Counsel: Inhouse Co. Law Firm
- Case Identification: 2:25-cv-03802, C.D. Cal., 04/30/2025
- Venue Allegations: Venue is asserted based on Defendants allegedly conducting substantial business and selling the accused products to consumers within the Central District of California via e-commerce websites such as amazon.com and ebay.com.
- Core Dispute: Plaintiff alleges that Defendants’ aftermarket automobile tail lights infringe its U.S. design patent for an Automobile Tail Light.
- Technical Context: The dispute is in the automotive aftermarket parts industry, where the ornamental and aesthetic appearance of components like tail lights is a significant factor for consumers.
- Key Procedural History: The complaint alleges that Plaintiff previously submitted "multiple infringement reports to Amazon and eBay," suggesting Defendants had pre-suit knowledge of the patent and the infringement allegations. The asserted patent is subject to a terminal disclaimer, a procedural step taken during prosecution that may affect the patent's term and enforceability.
Case Timeline
| Date | Event |
|---|---|
| 2020-04-25 | '481 Patent Application Filing Date |
| 2024-10-22 | '481 Patent Issue Date |
| 2025-04-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,048,481 S - Automobile Tail Light
The patent-in-suit is U.S. Design Patent No. D1,048,481 S, issued October 22, 2024. (Compl. ¶14).
The Invention Explained
- Problem Addressed: Design patents protect ornamentation rather than function. The patent provides a new, original, and ornamental design for an article of manufacture—specifically, a replacement tail light intended to be compatible with certain vehicle models. (Compl. ¶16).
- The Patented Solution: The patent claims the specific visual appearance of an automobile tail light as depicted in its figures. (’481 Patent, Claim). Key ornamental features shown in solid lines include the overall vertically-oriented shape, an inner recessed portion containing a vertical stack of rectangular light elements, and a distinct circular lamp at the base. (’481 Patent, Figs. 1-2). The patent explicitly disclaims the elements shown in broken lines, indicating they represent environmental structure and are not part of the protected design. (’481 Patent, Description).
- Technical Importance: The design provides a distinct aesthetic in the competitive market for aftermarket automotive parts, where visual differentiation is a primary driver of consumer choice. (Compl. ¶¶ 21, 23).
Key Claims at a Glance
- The patent contains a single claim for "The ornamental design for an automobile tail light, as shown and described." (’481 Patent, Claim).
- The claimed design consists of the visual characteristics embodied in the patent’s drawings, including:
- A vertically elongated housing with curved side profiles.
- A prominent inner assembly featuring a vertical column of discrete, rectangular light sources.
- A single, larger circular light source positioned at the bottom of the assembly.
- The specific proportions and arrangement of these elements relative to each other.
III. The Accused Instrumentality
Product Identification
The "Accused Products" are aftermarket tail lights compatible with 1988-1998 Chevrolet Silverado, Suburban, Tahoe, and Yukon vehicle models. (Compl. ¶¶ 16, 21). These products are allegedly sold by Defendants on Amazon and eBay under storefront names including "Mayello," "Mayello_offroad," "locknight-autoparts," and "MAYELLO-AUTOEM." (Compl. ¶¶ 9-12).
Functionality and Market Context
The accused products are functional replacements for original equipment manufacturer (OEM) tail lights. The complaint alleges infringement based on their ornamental appearance, not their utilitarian function. (Compl. ¶23). The complaint presents a side-by-side visual comparison of the patented design and a photograph of an accused product to support its infringement theory. (Compl. p. 6). This comparison shows the accused product as sold by Defendants. (Compl. ¶19).
IV. Analysis of Infringement Allegations
The standard for design patent infringement is the "ordinary observer" test, which asks whether an ordinary observer, giving such attention as a purchaser usually gives, would be deceived into purchasing the accused product supposing it to be the patented one. The complaint alleges this standard is met. (Compl. ¶23). The following table summarizes the visual comparison presented in the complaint.
'481 Patent Infringement Allegations
| Key Ornamental Feature (from '481 Patent Figures) | Alleged Infringing Functionality (from Accused Product) | Complaint Citation | Patent Citation |
|---|---|---|---|
| A vertical array of rectangular light elements within a recessed portion of the housing. | The accused product incorporates a vertical array of rectangular red light elements in a similar recessed portion. | ¶19; p. 6 | Fig. 2 |
| A single circular lamp positioned below the vertical array. | The accused product features a single circular lamp, appearing to be a reverse light, positioned below the vertical array of red lights. | ¶19; p. 6 | Fig. 2 |
| The overall shape and contours of the tail light assembly as depicted in solid lines. | The overall shape and contours of the accused product housing appear to be the same or substantially the same as the patented design. | ¶¶19-20; p. 6 | Figs. 1, 3 |
Identified Points of Contention
- Scope Questions: A central question will be the application of the "ordinary observer" test. The analysis will focus on whether the accused products are "substantially the same" as the claimed design when viewed as a whole. (Compl. ¶23). The resemblance must be such that it would deceive an ordinary observer into purchasing the accused product believing it was the patented design.
- Visual Questions: While the side-by-side comparison in the complaint suggests a high degree of similarity, the defense may focus on any perceived minor differences in surface contour, bezel design, materials, or the precise proportions of the light elements to argue that an ordinary observer would not be deceived. The effect of the disclaimed environmental structure (shown in broken lines in the patent) on the overall visual impression may also become a point of dispute.
V. Other Allegations
Indirect Infringement
The prayer for relief includes a request to enjoin aiding and abetting of infringement. (Compl. p. 8, Prayer for Relief 2.b). However, the factual allegations in the body of the complaint focus on direct infringement by the named Defendants through their own making, using, and selling activities. (Compl. ¶22).
Willful Infringement
The complaint alleges that Defendants had knowledge of Plaintiff's patented design because Plaintiff "has submitted multiple infringement reports to Amazon and eBay." (Compl. ¶18). It further alleges that Defendants' infringement was intentional and undertaken with knowledge that the Accused Products practice the features of the ’481 Patent. (Compl. ¶24). These allegations form the basis for the request for treble damages. (Compl. p. 9, Prayer for Relief 5).
VI. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual comparison: Applying the "ordinary observer" test, is the overall ornamental appearance of the Defendants' tail lights "substantially the same" as the design claimed in the ’481 Patent, such that a typical purchaser would be deceived? The court's analysis will depend heavily on a side-by-side comparison of the products and the patent figures.
- A key evidentiary question will be one of knowledge and willfulness: Can Plaintiff produce sufficient evidence to prove that the named Defendants had actual knowledge of the ’481 Patent and the specific infringement allegations—for example, through the infringement reports submitted to e-commerce platforms—and continued to infringe despite that knowledge?
- A third question, which may arise during litigation, will be the role of prior art: The ultimate infringement analysis by the court will consider the patented design in the context of the prior art. The scope of protection afforded to the ’481 Patent will be determined by what features are truly new and ornamental versus what was already common in the field of automotive tail light design.