Shenzhen Quanxindi Technology Co Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Quanxindi Technology Co. Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule "A"
  • Plaintiff’s Counsel: The Law Offices of Konrad Sherinian, LLC
• Case Identification: 1:24-cv-11671, N.D. Ill., 11/13/2024
• Venue Allegations: Venue is alleged to be proper based on Defendants targeting business activities toward consumers in Illinois, including offering for sale, selling, and shipping products to Illinois residents through interactive e-commerce stores.
• Core Dispute: Plaintiff alleges that numerous online e-commerce operators are infringing its U.S. design patent for a broom apparatus.
• Technical Context: The dispute is in the consumer cleaning products sector, focusing on the ornamental design of brooms sold through online marketplaces.
• Key Procedural History: The complaint notes that the case is related to an earlier filed case, 2024-cv-10193, which involves some of the same intellectual property. This suggests a potential pattern of enforcement by the Plaintiff against different groups of sellers.

Case Timeline

Date	Event
2022-06-30	D991,607 Patent Application Filing Date
2023-07-04	D991,607 Patent Issue Date
2024-11-13	Complaint Filing Date

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

U.S. Patent No. D991,607, “Broom,” Issued July 4, 2023 (’607 Patent)

• The Invention Explained:

  • Problem Addressed: Design patents do not solve a technical problem but instead protect the novel, non-functional, ornamental appearance of an article of manufacture.
  • The Patented Solution: The ’607 Patent claims the specific ornamental design for a broom. Key visual features shown in the patent's figures include a long, slender handle composed of multiple cylindrical segments, a hanging loop at the top end, and a wide, flat head with a straight top edge and a slightly curved bottom edge containing a squeegee-like blade (D991,607 Patent, FIGS. 1, 6, 7). The design creates a distinct overall visual impression for the broom.
  • Technical Importance: The patent protects a specific aesthetic for a broom, which the complaint alleges is distinctive and associated with the "quality and innovation" of Plaintiff's products (Compl. ¶8).

• Key Claims at a Glance:

  • Design patents contain a single claim. The asserted claim is: "The ornamental design for a broom, as shown and described." (D991,607 Patent, CLAIM).

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are "broom apparatus" products, referred to as the "Infringing Products" (Compl. ¶5).
• Functionality and Market Context: The complaint alleges that Defendants, a group of e-commerce store operators, are "making, using, offering for sale, selling and/or importing" products that embody the patented design (Compl. ¶5). These products are sold through various online marketplace platforms, including Amazon, eBay, AliExpress, and others, to consumers in the United States and specifically in Illinois (Compl. ¶¶12, 14). The complaint alleges Defendants operate under multiple "Seller Aliases" to conceal their identities and interconnections (Compl. ¶¶11, 18). The complaint includes an image of the patented design, identifying it as the "Quanxindi Design" that Defendants are accused of infringing (Compl. p. 4). This image from the complaint shows a multi-segmented broom with a top loop and a flat squeegee-like head (Compl. p. 4).

IV. Analysis of Infringement Allegations

The complaint does not contain a formal claim chart. The infringement theory for a design patent rests on the "ordinary observer" test, which asks whether an ordinary observer, giving such attention as a purchaser usually gives, would be deceived into purchasing the accused article thinking it was the patented one.

The complaint alleges that the "Infringing Products" directly and/or indirectly infringe the ornamental design claimed in the ’607 Patent (Compl. ¶25). The central allegation is that the visual appearance of the products sold by Defendants is substantially the same as the design claimed in the patent.

V. Key Claim Terms for Construction

This section is not applicable. Design patent claims are defined by the drawings, and there are no textual claim terms that require construction in the manner of a utility patent.

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation of both direct and indirect infringement (Compl. ¶25). The prayer for relief requests an injunction against "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing the patent (Prayer for Relief ¶1.b). The allegations that Defendants work in "active concert" and operate as interrelated entities may support a theory of joint or contributory infringement (Compl. ¶¶18, 21).
• Willful Infringement: Willfulness is explicitly alleged, stating that "Defendants’ infringement of the Quanxindi Design...was willful" (Compl. ¶22). The basis for this allegation appears to be the claim that Defendants knowingly and willfully manufacture, import, and sell the infringing products as part of a coordinated effort (Compl. ¶21).

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

1. Infringement Standard: A central issue will be one of visual identity: does the ornamental design of the various accused products sold by the "Schedule A" Defendants create substantially the same visual impression as the ’607 Patent in the eyes of an ordinary observer? The outcome will depend on a side-by-side comparison of the accused products with the patent’s drawings.
2. Liability and Jurisdiction: A key practical and legal question will be one of enforceability: can the Plaintiff successfully establish that the numerous, anonymous "Partnerships and Unincorporated Associations" are a single, coordinated enterprise and that the court has personal jurisdiction over these foreign-based sellers? The complaint dedicates significant attention to alleging common tactics and shared identifiers to overcome this challenge (Compl. ¶¶16-20).
3. Proof of Infringement: A primary evidentiary question will be whether the Plaintiff can present sufficient proof linking each of the named defendant storefronts to the sale of products that meet the "ordinary observer" test for infringement, a task complicated by the alleged use of multiple aliases and concealment tactics (Compl. ¶11).