DCT

1:25-cv-25694

Lander Enterprisessssss LLC v. Yiwushi Yiquan Dianzishangwu Youxiangongsi

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-25694, S.D. Fla., 12/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign entity that regularly conducts business in the district, including targeting and selling the accused products to Florida residents through a commercial Amazon storefront.
  • Core Dispute: Plaintiff alleges that Defendant’s U-shaped electric toothbrush heads infringe a design patent covering the ornamental design of a double-sided toothbrush head.
  • Technical Context: The dispute centers on the ornamental appearance of U-shaped, mouthguard-style electric toothbrush heads, a product category aimed at cleaning multiple surfaces of the teeth simultaneously.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

Date Event
2020-12-29 ’544 Patent Priority Date
2022-07-26 ’544 Patent Issued
2025-12-05 Complaint Filed

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

U.S. Design Patent No. D958,544 - "Double-Sided Toothbrush Head"

  • Patent Identification: U.S. Design Patent No. D958,544, "Double-Sided Toothbrush Head," issued July 26, 2022 (the "’544 Patent").

The Invention Explained

  • The Patented Design: The ’544 Patent claims the specific ornamental design for a double-sided toothbrush head. The claimed design features a U-shaped body with distinct visual characteristics, including the arrangement, pattern, and orientation of bristle-like elements on both its upper and lower interior surfaces ('544 Patent, FIG. 1, FIG. 3). The design also includes specific configurations on the front and rear faces of the U-shaped channel, creating a particular overall visual impression ('544 Patent, FIG. 6, FIG. 7). The scope of the design patent is defined by the solid lines in the drawings, which depict the claimed ornamental features.
  • Technical Importance: The complaint alleges that the product embodying the patented design has been a "success in the market" and achieved "substantial sales" (Compl. ¶16).

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is for: "The ornamental design for a double-sided toothbrush head, as shown and described" (’544 Patent, Claim).

III. The Accused Instrumentality

Product Identification

  • Product Identification: Defendant’s "U Shaped Electric Toothbrush" products and associated toothbrush heads (Compl. ¶18).

Functionality and Market Context

The complaint alleges that Defendant sells electronic toothbrush products that include toothbrush heads embodying copies of Plaintiff's patented design (Compl. ¶¶17-18). These products are allegedly sold to consumers in the United States, including within the Southern District of Florida, through online retail outlets such as Amazon.com (Compl. ¶¶ 5, 12). The complaint provides a side-by-side visual comparison of the patented design and a photograph of the accused Dycrol toothbrush head. The visual comparison shows the accused product, a translucent U-shaped brush head with multiple rows of bristles (Compl. p. 5).

IV. Analysis of Infringement Allegations

The central test for design patent infringement is whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that the accused products are "remarkably similar" to the design claimed in the ’544 Patent (Compl. ¶19).

Visual Feature Comparison: ’544 Patent

Claimed Visual Feature (from ’544 Patent) Alleged Infringing Feature (from Accused Product) Complaint Citation Patent Citation
The overall U-shaped configuration of the toothbrush head. The accused product is a U-shaped toothbrush head of a similar overall shape and proportion. p. 5 FIG. 3
The specific pattern, density, and layout of bristle elements on the bottom surface of the U-shaped channel. The accused product features a pattern of bristle elements on its bottom surface that is alleged to be a copy of the patented design. p. 5 FIG. 3
The specific ornamental design of the rear view, including the arrangement of bristle rows and central channel features. The accused product's rear view is alleged to be a copy of the patented design, showing a similar bristle layout and central channel structure. p. 6 FIG. 6

Identified Points of Contention

  • Scope Questions: The primary question is one of visual scope: Are the differences between the patented design and the accused product minor enough that an ordinary observer would find the designs substantially the same? The complaint presents the designs as nearly identical, but a defense may focus on any subtle distinctions in bristle shape, spacing, or surface texturing not immediately apparent from the complaint's photographic evidence.
  • Technical Questions: A factual question for the litigation will be how the overall visual impression of the two designs compares. The analysis will depend on comparing the "design as a whole," not just dissecting individual features.

V. Key Claim Terms for Construction

This section is not applicable. Design patent claims are defined by the drawings rather than textual limitations, and claim construction is generally not a central issue in the same way it is for utility patents. The analysis is a visual comparison of the claimed design and the accused product.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a passing allegation of indirect infringement (Compl. ¶20), but it does not plead specific facts to support a claim for either induced or contributory infringement, such as detailing how Defendant instructs others to infringe.
  • Willful Infringement: Willfulness is alleged based on Defendant’s "unauthorized copying" and conduct constituting "an objectively reckless disregard of the high likelihood of infringement" (Compl. ¶¶ 21, 29). The factual basis for this allegation appears to be the asserted "remarkably similar" appearance of the accused product to the patented design (Compl. ¶19).

VII. 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 design of Dycrol's "U Shaped Electric Toothbrush" head substantially the same as the design claimed in the ’544 Patent, such that a purchaser would be deceived?
  • A key evidentiary question will relate to intent and damages: Can the plaintiff produce sufficient evidence to support its claim of "willful" copying, which could lead to enhanced damages, or will the defendant be able to argue independent creation or that any visual similarities are dictated by function?