Dongguan Juyuan Precision Technology Co Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Juyuan Precision Technology Co., Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified in Schedule A (Jurisdictions not specified; identities under seal)
  • Plaintiff’s Counsel: DeWitty and Associates
• Case Identification: 1:24-cv-11301, N.D. Ill., 11/01/2024
• Venue Allegations: Venue is asserted based on Defendants targeting business activities toward consumers in the United States, including Illinois, through interactive commercial internet stores.
• Core Dispute: Plaintiff alleges that Defendants, a group of online sellers, are infringing a design patent for a "Folding Wireless Charging Stand" by marketing, selling, and distributing unlicensed "knock-off" products.
• Technical Context: The dispute is in the consumer electronics accessories market, specifically focusing on the ornamental design of multi-device wireless charging stands.
• Key Procedural History: The complaint does not mention any prior litigation, administrative proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. D1,019,552 S, "FOLDING WIRELESS CHARGING STAND", issued March 26, 2024 (the "'552 Patent").

The Invention Explained

• Problem Addressed: Design patents address the creation of a new, original, and ornamental design for an article of manufacture. The implicit problem is the lack of a particular aesthetic for a folding wireless charger.
• The Patented Solution: The '552 Patent claims the specific ornamental design of a folding wireless charging stand. Key visual features depicted in the patent's figures include a flat, rectangular base from which a hinged, multi-part arm extends upwards. This arm supports a tilting, squared charging pad for a phone and incorporates a secondary, recessed circular charging area for a watch-like device. The overall aesthetic is characterized by its clean lines, specific hinge configuration, and the geometric relationship between the base, arm, and charging surfaces, both in its extended and folded states (D'552 Patent, Figs. 1, 9).
• Technical Importance: The design provides a distinct visual appearance for a multi-device charger, combining foldable functionality with a specific minimalist aesthetic for the consumer electronics market.

Key Claims at a Glance

• The '552 Patent contains a single claim: "The ornamental design for a folding wireless charging stand, as shown and described." (D'552 Patent, p. 3).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "unlicensed product[s]" and "knock-off product[s]" sold by Defendants through various online storefronts ("Defendant Internet Stores") (Compl. ¶3). The complaint states these products are shown in Exhibit B, which was not publicly filed with the complaint.

Functionality and Market Context

• The complaint alleges the accused products are the "same product as the claimed design" (Compl. ¶3). The complaint provides an image of the patented design ("Image 1") and alleges it is representative of both Plaintiff's product and the infringing products (Compl. ¶5, p. 4). This image depicts a multi-surface, foldable wireless charger capable of recharging devices like mobile phones and watches through surface contact (Compl. ¶5; Compl. p. 4, Image 1).
• Plaintiff alleges that Defendants' online stores are designed to appear as if they are selling licensed products and that they operate as an "interrelated group of infringers" (Compl. ¶¶3, 9).

IV. Analysis of Infringement Allegations

The standard for design patent infringement is whether an "ordinary observer," familiar with the prior art designs, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that Defendants' products are not merely similar but are the "same product as the claimed design" (Compl. ¶3).

D1,019,552 Infringement Allegations

• Identified Points of Contention:
  • Visual Similarity: The central question will be one of visual identity. The complaint's primary allegation is that the accused products are direct "knock-off[s]" embodying a design identical to the patented design. The dispute will likely center on evidence (such as the images in the sealed Exhibit B) demonstrating that the products sold by Defendants are, from the perspective of an ordinary observer, substantially the same as the design shown in the '552 Patent.
  • Evidentiary Questions: A key challenge for the Plaintiff may be proving that each of the numerous, anonymous online entities listed in the sealed Schedule A sold products that infringed the '552 Patent within the jurisdiction. The complaint alleges a "logical relationship" and "series of occurrences" to support joinder of the various defendants (Compl. ¶3).

V. Other Allegations

Indirect Infringement

• The complaint does not advance specific factual allegations to support claims of induced or contributory infringement, focusing instead on allegations of direct infringement through Defendants' offers for sale, sales, and importation of the accused products (Compl. ¶20).

Willful Infringement

• The complaint alleges that Defendants "knowingly and willfully" infringed the '552 Patent (Compl. ¶16). The basis for this allegation appears to be that Defendants operated with the knowledge they were selling "knock-off product[s]" and took active measures to conceal their identities, suggesting an awareness of the infringing nature of their activities (Compl. ¶¶3, 9, 11).

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

• A core issue will be one of visual identity: Assuming the Plaintiff can produce the accused products for inspection, will an ordinary observer conclude that their overall ornamental design is substantially the same as the design claimed in the '552 Patent, thereby supporting the complaint's allegation of "knock-off" copying?
• A key procedural question will be one of liability and joinder: Can the Plaintiff present sufficient evidence to establish that the numerous, allegedly distinct online sellers are part of a single, interrelated operation and that each defendant is individually responsible for infringing sales, particularly given the alleged use of aliases and other tactics to conceal their identities?