Jun Lu v. Device X

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jun Lu (Guangdong, China)
  • Defendant: Device X and DreaMall (Amazon storefronts believed to be operating from China)
  • Plaintiff’s Counsel: Direction IP Law (with Ni, Wang & Massand, PLLC as Of Counsel)
• Case Identification: 1:23-cv-04282, N.D. Ill., 07/05/2023
• Venue Allegations: Venue is alleged to be proper as Defendants are believed to be foreign entities based in China, making venue appropriate in any U.S. judicial district. The complaint further alleges personal jurisdiction based on Defendants’ operation of interactive Amazon storefronts that target and have completed sales to residents of Illinois.
• Core Dispute: Plaintiff alleges that electronic doorknobs sold by Defendants through Amazon storefronts infringe a U.S. design patent covering the ornamental appearance of an electronic doorknob.
• Technical Context: The dispute concerns the ornamental design, or non-functional aesthetic appearance, of electronic doorknobs, a consumer product category for residential and commercial security.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Design Patent No. D981,205 - "ELECTRONIC DOOR KNOB"

• Patent Identification: U.S. Design Patent No. D981,205, "ELECTRONIC DOOR KNOB," issued March 21, 2023.

The Invention Explained

• Problem Addressed: Design patents do not solve technical or functional problems; rather, they protect the novel, non-functional, ornamental appearance of an article of manufacture. The D'205 Patent seeks to protect a specific aesthetic design for an electronic doorknob (D’205 Patent, Claim 1).
• The Patented Solution: The patent claims the ornamental design for an electronic doorknob as depicted in its figures (D’205 Patent, Claim 1). The claimed design, shown in solid lines, consists of a cylindrical door knob with a circular face featuring a numeric keypad arranged in a circle, a central lock/unlock button, and a checkmark-shaped "enter" button (D’205 Patent, FIG. 3). The patent explicitly disclaims the internal mechanics and latch assembly by rendering them in broken lines, stating they "form no part of the claimed design" (D’205 Patent, col. 1:63-68).
• Technical Importance: The complaint alleges that the Plaintiff sells its own electronic doorknobs under the "iulock Direct" brand which embody the patented design and are "well established on Amazon and enjoy quality customer reviews and high ratings" (Compl. ¶9).

Key Claims at a Glance

• The single claim of the D'205 Patent is for "The ornamental design for an electronic door knob, as shown and described" (D’205 Patent, col. 1:58-60).
• In a design patent, the "elements" of the claim are the visual features of the design as depicted in the patent's drawings. The scope is defined by what is shown in solid lines.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "electronic doorknobs" sold by Defendants Device X and DreaMall through their respective Amazon storefronts (Compl. ¶1).

Functionality and Market Context

• The complaint alleges that the accused products are electronic doorknobs that infringe the ornamental design claimed in the D'205 Patent (Compl. ¶20). The complaint includes a side-by-side visual comparison, showing an accused product with a circular keypad on a cylindrical knob, which is alleged to be sold by Defendants to consumers in the United States, including Illinois (Compl. ¶1, ¶16, ¶20). The complaint provides a photograph of an exemplary accused product, which appears to be a keyless entry doorknob with a numeric keypad. (Compl. ¶20, p. 6).
• The complaint alleges Defendants operate as "foreign design patent infringers" who use tactics to conceal their identities, such as using multiple fictitious names and creating new Amazon storefronts to evade enforcement (Compl. ¶1, ¶12).

IV. Analysis of Infringement Allegations

The infringement test for a design patent 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 presents its infringement allegation through a side-by-side comparison. The complaint provides a side-by-side comparison image showing the claimed design from the patent’s FIG. 1 next to a photograph of an accused product. (Compl. ¶20, p. 6).

D'205 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The primary legal and factual question will be whether an ordinary observer, giving such attention as a purchaser usually gives, would find the accused doorknob's design substantially the same as the design claimed in the D'205 patent. The analysis will focus only on the elements shown in solid lines in the patent drawings.
  • Technical Questions: A point of contention may arise regarding the visual effect of differences between the designs. For example, the accused product in the complaint's photograph bears the brand name "ZINCKER" on its face, which is not present in the claimed design (Compl. ¶20). The court may need to consider whether such differences are minor and do not detract from the overall similarity of the designs, or if they are significant enough to distinguish the products in the mind of an ordinary observer.

V. Key Claim Terms for Construction

In a design patent case, claim construction focuses on the scope of the claimed design as a whole, rather than on interpreting specific text-based terms. The central issue is defining the visual impression protected by the patent.

• The "Term": The scope of the claimed ornamental design.
• Context and Importance: The scope of the design is critical because it defines what the accused product is compared against for infringement. The distinction between features shown in solid lines (part of the claim) and those in broken lines (environmental and not part of the claim) is dispositive.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent claims the design "as shown and described," focusing on the overall visual impression created by the combination of claimed features (the cylindrical knob, circular keypad, button shapes, etc.). Plaintiff may argue that minor differences in proportion or surface detail on the accused product do not change the overall visual identity, which is what the patent protects.
  • Evidence for a Narrower Interpretation: The patent contains an explicit statement that "The broken lines shown in the drawings... form no part of the claimed design" (D’205 Patent, col. 1:63-68). This definitively limits the scope to the solid-line features. A defendant could argue that the specific shapes, arrangement, and relative proportions of the solid-line features (e.g., the precise curvature of the knob, the shape of the checkmark button) are what define the unique design, and that any deviation in the accused product is therefore significant.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants are an "interrelated group of infringers working in active concert" to sell products that "directly and/or indirectly" infringe the D'205 patent (Compl. ¶11). The prayer for relief also seeks to enjoin "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" the patent (Compl. p. 7, ¶1(b)).
• Willful Infringement: The complaint alleges that "Defendants' infringement of the D'205 Patent... is willful" (Compl. ¶17). This allegation is based on the assertion that Defendants acted "knowingly and willfully" and without any license or authorization from the Plaintiff (Compl. ¶16).

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

1. A core issue will be one of visual comparison: applying the ordinary observer test, are the differences between the accused doorknobs and the patented design—such as the "ZINCKER" branding on the accused product—sufficient to prevent an ordinary purchaser from being deceived into thinking the accused product is the patented design?

2. A second key question will relate to damages and scope of relief: given the allegations that Defendants are foreign entities operating through ephemeral online storefronts, a central practical challenge for the Plaintiff will be identifying the defendants, establishing the full scope of their sales, and enforcing any potential monetary or injunctive relief.

3. Finally, the willfulness allegation will raise an evidentiary question: what evidence can Plaintiff produce to demonstrate that Defendants had pre-suit knowledge of the D'205 patent and its asserted design, and that they deliberately copied it, as opposed to independently arriving at a similar design?