DCT

3:26-cv-00804

Lfa Co Ltd v. Amazon.com Services LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:26-cv-00804, N.D. Cal., 01/25/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California because Defendant has committed acts of infringement in the district, sold an accused product to Plaintiff within the district, and maintains a regular and established place of business in Sunnyvale, California.
  • Core Dispute: Plaintiff alleges that Defendant’s aftermarket automobile tail lights, compatible with certain Ford Ranger models, infringe a U.S. design patent covering the ornamental design for an automobile tail light.
  • Technical Context: The dispute is in the automotive aftermarket parts sector, where the ornamental appearance of components like tail lights is a key element for product differentiation and consumer appeal.
  • Key Procedural History: The complaint notes that Plaintiff acquired all rights to the patent-in-suit as of December 16, 2025, approximately six months after the patent issued. No other significant procedural events are mentioned.

Case Timeline

Date Event
2020-11-23 ’991 Patent Priority Date
2025-06-17 ’991 Patent Issue Date
2025-11-28 Plaintiff's purchase of Accused Product
2025-12-16 Plaintiff acquires rights to the ’991 Patent
2026-01-25 Complaint Filing Date

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

U.S. Design Patent No. D1,079,991 S - *"Automobile Tail Light"*

  • Patent Identification: U.S. Design Patent No. D1,079,991 S, "Automobile Tail Light," issued June 17, 2025 (’991 Patent).

The Invention Explained

  • Problem Addressed: Design patents do not articulate a technical problem in the manner of utility patents; rather, they protect a "new, original, and ornamental design for an article of manufacture" (35 U.S.C. § 171). The goal is to protect a unique aesthetic appearance.
  • The Patented Solution: The ’991 Patent claims the specific ornamental design for an automobile tail light as depicted in its seven figures (’991 Patent, CLAIM). Key visual features of the design include a generally rectangular housing with rounded corners, a prominent C-shaped light guide that frames two internal rectangular light arrays, and a specific three-dimensional contour when viewed from the side and top profiles (’991 Patent, FIG. 1-7). The patent explicitly notes that broken lines in the drawings depict environmental structure and do not form part of the claimed design (’991 Patent, DESCRIPTION).
  • Technical Importance: The complaint alleges that Defendants copied the patented design, which suggests the design has perceived value in the automotive aftermarket parts market (Compl. ¶16).

Key Claims at a Glance

  • The ’991 Patent contains a single claim for "The ornamental design for an automobile tail light, as shown and described" (’991 Patent, CLAIM).
  • The essential visual elements of this single claim, as shown in the patent figures, include:
    • A primary C-shaped light element.
    • Two distinct, horizontally-oriented light arrays positioned inside the C-shape.
    • A lower rectangular reflector or light element.
    • The overall external shape and surface contour of the tail light housing.

III. The Accused Instrumentality

Product Identification

  • The accused products are the "HECASA Tail Lights Compatible with 2001-2011 Ford Ranger C-Type LED Tube Rear Brake Tail Lamps Assembly Driver and Passenger Side (Clear Lens Black Housing)" sold on Amazon.com (Compl. ¶9-10).

Functionality and Market Context

  • The accused products are aftermarket tail light assemblies designed to replace the original equipment manufacturer (OEM) lights on 2001-2011 Ford Ranger trucks (Compl. ¶9-10). The complaint focuses entirely on the ornamental appearance of these products rather than their functional lighting performance. The complaint presents a side-by-side visual comparison to argue that the accused product's design is substantially the same as the patented design (Compl. p. 7). This comparison chart includes a photograph of the accused product's front view, juxtaposed with FIG. 2 of the '991 Patent, to highlight the alleged similarities in the C-shaped light tube and internal lamp configuration (Compl. p. 7).

IV. Analysis of Infringement Allegations

The complaint does not provide a traditional claim chart but instead relies on a visual side-by-side comparison and narrative allegations that the accused design is "the same or substantially the same" as the patented design (Compl. ¶17). The core of the infringement allegation is that an ordinary observer would be deceived by the similarity.

  • Identified Points of Contention:
    • Scope Questions: A central question will be how the "ordinary observer" test applies. The analysis will depend on whether an ordinary purchaser of aftermarket tail lights, giving the attention such a purchaser usually gives, would be deceived into thinking the accused product is the same as the patented design. The complaint alleges the designs are "so similar as to be nearly identical" (Compl. ¶17).
    • Technical Questions: The dispute is not technical in a functional sense, but visual. A key question will be whether any differences between the accused product and the patent drawings are significant enough to be perceived by the ordinary observer and to defeat the infringement claim. The court will compare the overall visual impression of the two designs, not just dissect individual features.

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is understood to be the design itself as shown in the drawings. Formal claim 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 patent figures.
  • Context and Importance: The infringement analysis must be limited to the ornamental features shown in solid lines, as the patent explicitly disclaims matter shown in broken lines. Practitioners may focus on this distinction because the comparison for infringement must exclude any unclaimed "environmental structure" (’991 Patent, DESCRIPTION). The outcome of the case may turn on whether the alleged similarities reside in the claimed (solid line) portions of the design.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim covers the "design for an automobile tail light, as shown and described," which suggests the overall visual impression is paramount. A party could argue that minor variations should be ignored if the overall aesthetic is captured.
    • Evidence for a Narrower Interpretation: The patent’s DESCRIPTION section states, "Any broken lines are included to show environmental structure and form no part of the claimed design" (’991 Patent, DESCRIPTION). For instance, the internal composition of the light arrays is depicted with broken lines, suggesting the specific arrangement of LEDs may not be part of the claimed design, only their general placement within the solid-line rectangular boundaries (’991 Patent, FIG. 2). A party could argue that the claim is limited to the exact contours and features shown in solid lines.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain allegations supporting claims for induced or contributory infringement.
  • Willful Infringement: The complaint alleges Defendants have knowledge of infringement "since at least the filing of this complaint," which would support a claim for post-suit willfulness (Compl. ¶15). It also makes a conclusory allegation that Defendants "intentionally sell, ship, or otherwise deliver the Accused Products... with knowledge that the Accused Products are designed to and do practice the infringing features" (Compl. ¶23). Further, the allegation that Defendants "copied the design of the Accused Products from the tail light design of the ’991 Patent" may be used to support a finding of willfulness if proven (Compl. ¶16).

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

The resolution of this dispute will likely depend on the court's answers to the following key questions:

  • Visual Deception: From the perspective of an ordinary observer of aftermarket automotive parts, is the overall ornamental design of the accused HECASA tail light substantially the same as the design claimed in the ’991 Patent? The side-by-side comparison provided in the complaint will be central to this factual determination (Compl. pp. 7-9).
  • Impact of Prior Art: While not addressed in the complaint, a core issue in any design patent case is the scope of the prior art. The degree of similarity required for infringement is viewed in the context of prior designs, and the existence of similar, older tail light designs could narrow the scope of the ’991 Patent’s protection.
  • Evidence of Copying: A key evidentiary question will be whether Plaintiff can substantiate its allegation of direct copying (Compl. ¶16). Proof of copying is not required to find infringement, but it can be persuasive evidence on the issue of substantial similarity and is critical for establishing willfulness.