DCT
5:20-cv-00660
Sysonic Eletronics Inc v. Deepmotor Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sysonic Electronics, Inc. (California)
- Defendant: DeepMotor, Inc. (California); Arch Ebusiness International, Inc. (California); Yong Wei (California)
- Plaintiff’s Counsel: Sheppard, Mullin, Richter & Hampton LLP
- Case Identification: 5:20-cv-00660, C.D. Cal., 04/01/2020
- Venue Allegations: Venue is alleged to be proper because the corporate and individual defendants reside in the Central District of California and have allegedly committed acts of infringement, including maintaining established places of business, within the district.
- Core Dispute: Plaintiff alleges that Defendants' aftermarket ignition coil covers infringe its design patent for an ornamental ignition coil cover.
- Technical Context: The dispute is in the field of aftermarket automotive components, where unique ornamental designs can serve as a key product differentiator.
- Key Procedural History: The complaint alleges a significant prior business relationship, stating that from 2012 to 2018, Plaintiff used Defendant Yong Wei as the manufacturer for its ignition coil covers. During this period, Plaintiff allegedly provided Wei with the patented design and the patent number for product marking. Plaintiff alleges that after this relationship ended in 2018, Wei established the corporate defendants to sell competing products that copy the patented design.
Case Timeline
| Date | Event |
|---|---|
| 2012-08-03 | ’759 Patent Priority Date (Filing Date) |
| 2012-2018 | Alleged period of business relationship between Sysonic and Wei |
| 2015-08-04 | ’759 Patent Issued |
| 2018 | Alleged end of business relationship between Sysonic and Wei |
| 2018 | Alleged incorporation of Defendant DeepMotor by Defendant Wei |
| 2020-04-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Design Patent No. D735,759, "Ignition Coil Cover," issued August 4, 2015 (the “’759 Patent”).
The Invention Explained
- Problem Addressed: The complaint suggests the design was created to address a commercial, rather than a technical, problem: the need for a "unique and distinctive design that differentiates its products from others" in the aftermarket vehicle parts field (Compl. ¶17).
- The Patented Solution: The ’759 Patent protects the specific ornamental appearance of an ignition coil cover, not its function (D’759 Patent, Claim). The design consists of an elongated, rectangular body with rounded ends, a series of U-shaped cutouts along one of its long sides, and distinct recessed panels on its top surface (’759 Patent, FIG. 1). The patent’s description notes that the figures depict a "fabricated aluminum two-piece ignition coil cover design" (’759 Patent, DESCRIPTION).
- Technical Importance: The complaint alleges the patented design was "commercially successful" and provided "differentiation to other competitors' designs" (Compl. ¶22).
Key Claims at a Glance
- Design patents contain a single claim. The asserted claim is: "The ornamental design for an ignition coil cover, as shown and described."
- The essential visual elements of this design include:
- An elongated body with a generally rectangular top surface and rounded ends.
- A series of repeating, uniform U-shaped cutouts along one of the long side walls.
- A flat top surface featuring recessed panels.
- A circular opening near one end of the top surface.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "ignition coil covers" offered for sale by Defendant DeepMotor and sold and distributed by Defendant Arch (Compl. ¶¶ 26-27, 29).
Functionality and Market Context
The complaint alleges these are aftermarket automotive parts sold in competition with Plaintiff's products, including on eBay (Compl. ¶¶ 25-26). The complaint asserts that the accused products are "substantially the same" as Plaintiff's own commercial embodiment of the ’759 Patent (Compl. ¶29). A side-by-side photograph in the complaint shows the "Sysonic Ignition Coil Cover" next to the "Defendants' Ignition Coil Cover," depicting visually similar articles (Compl. ¶29, p. 5).
IV. Analysis of Infringement Allegations
The complaint alleges that the accused ignition coil covers are "so nearly identical" to the patented design that an ordinary observer would be deceived (Compl. ¶33). This allegation is supported by a visual comparison showing the patent's primary figure alongside a photograph of the accused product (Compl. ¶33, p. 6). The infringement theory rests on a direct comparison of the overall ornamental appearance.
’759 Patent Infringement Allegations
| Claim Element (Visual Features from Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for an ignition coil cover, as shown and described. | The complaint alleges that the Defendants' ignition coil covers embody a design that is "substantially the same as" and "so nearly identical" to the design claimed in the ’759 Patent. | ¶¶ 29, 33 | D’759 Patent, Claim |
| Specific Features: | The complaint provides photographic evidence suggesting the accused product incorporates the key visual features of the patented design. | ||
| Elongated body with rounded ends and recessed top panels | The accused product is depicted as having an elongated body with rounded ends and recessed panels on its top surface. | ¶¶ 29, 33 | D’759 Patent, FIG. 1 |
| A series of U-shaped cutouts along a long side wall | The accused product is depicted with a series of U-shaped cutouts along its side that appear to match the configuration in the patented design. | ¶¶ 29, 33 | D’759 Patent, FIG. 1 |
| A circular opening near one end | The accused product is depicted with a circular opening near one end, consistent with the patented design. | ¶¶ 29, 33 | D’759 Patent, FIG. 1 |
Identified Points of Contention
- Scope Questions: The central question in a design patent case is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented one. The dispute will likely focus on whether any minor differences between the accused product and the patent drawings are sufficient to differentiate the designs' overall visual impressions.
- Technical Questions: While not a technical dispute in the utility patent sense, a factual question will be how the construction of the accused product compares to the patent's description of a "two-piece" design (’759 Patent, DESCRIPTION). If the accused product is made as a single piece, Defendants may argue this is a legally relevant distinction.
V. Key Claim Terms for Construction
In design patent litigation, the claim is defined by the drawings, and formal claim construction of words is rare. The analysis focuses on the scope of the claimed design as a whole.
- The Term: "The ornamental design for an ignition coil cover, as shown and described."
- Context and Importance: This phrase constitutes the entire claim, and its scope is the central issue of the infringement analysis. The court's interpretation of what is covered by the patent's drawings will be dispositive. Practitioners may focus on this "term" because the entire case hinges on the comparison between the visual impression created by the patent figures and that of the accused product.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim is for the "ornamental design," which is typically understood to cover the overall visual appearance, not minor or functional details. The consistent depiction of the core features across multiple figures (’759 Patent, FIGS. 1-16) suggests these features, in combination, form the core of the protected design, regardless of minor variations in material or manufacturing.
- Evidence for a Narrower Interpretation: The patent specification explicitly describes the invention as a "fabricated aluminum two-piece ignition coil cover design" and provides separate figures for a "first piece" and a "second piece" (’759 Patent, DESCRIPTION). A defendant could argue the claim is limited to a design embodied in a two-piece construction, or that the specific proportions and relationships shown in the drawings narrowly define the protected scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement against Defendant Wei individually (Count III). This is based on the allegation that Wei "personally directs the infringing activities of DeepMotor" (Compl. ¶47). Factual support includes the allegation that Wei was previously Plaintiff's manufacturer for the patented product and was provided with the design and patent number, thereby possessing knowledge of the patent and the infringing nature of the accused products (Compl. ¶¶ 23, 30, 32).
- Willful Infringement: Plaintiff alleges willful infringement against DeepMotor and Wei (Compl. ¶¶ 35, 39, 48). The claim is predicated on allegations of pre-suit knowledge stemming from the prior manufacturing relationship (Compl. ¶23), where Wei was allegedly aware of the ’759 patent. The complaint also asserts constructive notice to all Defendants based on Plaintiff's marking of its own products with the patent number (Compl. ¶¶ 21, 37, 42, 46).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual identity: applying the "ordinary observer" test, is the overall ornamental appearance of the Defendants' ignition coil cover substantially the same as the design claimed in the ’759 Patent? The case will likely depend on a direct visual comparison and arguments over the significance of any minor differences.
- A key evidentiary question will be one of knowledge and intent: what evidence supports the allegation that Defendant Wei, based on his prior manufacturing relationship with the Plaintiff, knowingly and intentionally directed the corporate Defendants to copy the patented design? The resolution of this question will be critical to the claims of willfulness and personal liability for inducement.
- A central question for damages will be the remedy: should infringement be found, will Plaintiff be entitled to a reasonable royalty or, more significantly under 35 U.S.C. § 289 for design patents, the Defendants' total profits from the infringing sales? The willfulness allegations further raise the possibility of enhanced damages.