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 (People's Republic of China)
  • Defendant: The Partnerships, and Unincorporated Associations Identified on Schedule “A” (Jurisdictions not specified, but alleged to be operating from the People's Republic of China)
  • Plaintiff’s Counsel: Alioth Law Group
• Case Identification: 1:24-cv-12703, N.D. Ill., 12/10/2024
• Venue Allegations: Venue is alleged to be proper based on Defendants targeting business activities and making sales to consumers in the United States, including Illinois, through interactive e-commerce stores on platforms such as Amazon and Temu.
• Core Dispute: Plaintiff alleges that Defendants’ foldable phone holders and wireless charging stands, sold online under the "KU XIU" brand and other aliases, infringe two of its U.S. design patents.
• Technical Context: The case concerns the ornamental design of accessories in the consumer electronics market, specifically multi-device, foldable wireless charging stands.
• Key Procedural History: The complaint presents this as a new action. It frames the case as one against a network of online sellers operating under various aliases, alleging they are linked and controlled by the same entities, a common fact pattern in e-commerce enforcement actions aimed at combating what the complaint describes as a "Wack-A-Mole" game of infringement.

Case Timeline

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

U.S. Patent No. D1,019,552 S - "Folding Wireless Charging Stand"

The Invention Explained

• Problem Addressed: Design patents protect ornamental appearance rather than functional utility. The ’552 Patent sought to protect a new, original, and ornamental design for an article of manufacture (Compl., Ex. 1, p. 17).
• The Patented Solution: The patent claims the specific ornamental design for a folding wireless charging stand as depicted in its figures ('552 Patent, CLAIM; FIGS. 1-9). The design features a flat, rectangular base supporting a multi-jointed, articulated arm that terminates in a primary, angled charging surface. A secondary charging element appears integrated into the arm structure. The design's overall aesthetic is characterized by its segmented, foldable construction and the arrangement of its charging surfaces ('552 Patent, FIG. 1). The use of broken lines in the drawings indicates that certain underlying features are not part of the claimed design ('552 Patent, DESCRIPTION).
• Technical Importance: The design provides a specific aesthetic and form factor for a multi-device charger, addressing a market for compact and portable charging solutions for consumer electronics.

Key Claims at a Glance

• Design patents contain a single claim for the ornamental design as shown in the drawings. The claim of the '552 Patent is for "The ornamental design for a folding wireless charging stand, as shown and described" ('552 Patent, CLAIM).
• The scope of this claim is defined by the visual appearance of the article in the patent's drawings, with solid lines representing the claimed design and broken lines indicating unclaimed subject matter ('552 Patent, DESCRIPTION).

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U.S. Patent No. D1,038,108 S - "Foldable Phone Holder"

The Invention Explained

• Problem Addressed: The ’108 Patent sought protection for a new, original, and ornamental design for a foldable phone holder (Compl., Ex. 2, p. 31).
• The Patented Solution: The patent claims the ornamental design for a phone holder consisting of three hinged, rectangular panels that can fold into different configurations ('108 Patent, CLAIM; FIGS. 1-9). In its primary configuration, the design forms a stand with a base, a middle support section, and an upper holder section ('108 Patent, FIG. 1). The design is distinct from the '552 Patent, appearing as a more streamlined, three-panel device without the prominent secondary charging element shown in the '552 Patent.
• Technical Importance: This design offers a particular aesthetic for a portable and adjustable stand, a common accessory for mobile phones.

Key Claims at a Glance

• The '108 Patent asserts a single claim for "The ornamental design for a foldable phone holder, as shown and described" ('108 Patent, CLAIM).
• The protection afforded by this claim is determined by the overall visual appearance of the holder as depicted in the solid lines of the patent's nine figures ('108 Patent, DESCRIPTION; FIGS. 1-9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "foldable phone holders and foldable wireless charging stands for phones" sold by Defendants on e-commerce platforms like Amazon.com and Temu.com (Compl. ¶4). The complaint specifically identifies products sold under the "KU XIU" brand (Compl. ¶7).

Functionality and Market Context

• The complaint alleges that Defendants sell "foldable phone chargers almost identical to Plaintiff's Design Patents" (Compl. ¶8). Visual evidence provided in the complaint shows products marketed as "Magnetic Foldable 3 in 1 Charging Station[s]" designed to simultaneously charge devices such as iPhones, Apple Watches, and AirPods (Compl., Ex. 3, p. 45). For example, a screenshot from an Amazon product listing for a "KU XIU" product depicts a multi-segment, foldable charging stand with a base, an articulated arm, and multiple charging surfaces (Compl., Ex. 3, p. 45). The complaint alleges these products are sold to consumers throughout the United States, including in Illinois (Compl. ¶8).

IV. Analysis of Infringement Allegations

The complaint does not contain a formal claim chart. The infringement theory for design patents rests on the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design.

The complaint alleges that the accused products have a "similar design to Plaintiff's Design Patents" and that it would be "impossible" for a consumer to differentiate the accused products from products embodying the patented designs (Compl. ¶10). The infringement allegation appears to be based on the overall visual similarity between the accused "KU XIU" products and the drawings in the '552 and '108 patents. A visual comparison between the accused product shown in an Amazon listing (Compl., Ex. 3, p. 45) and Figure 1 of the '552 Patent suggests potential similarities in the multi-part foldable structure, the rectangular base, the articulated support arm, and the angled surface for the primary device.

• Identified Points of Contention:
  • Scope Questions: A central issue will be whether the overall visual impression of the accused products is substantially the same as the claimed designs. The analysis will depend on comparing the accused products to the patented designs as a whole, as depicted in the patent figures.
  • Technical Questions: A factual dispute may arise over the significance of any differences between the accused products and the patent drawings. The court may need to consider whether variations in proportion, curvature, hinge appearance, or surface texture between the accused products and the claimed designs are minor enough that an ordinary observer would find the designs substantially the same.

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is understood to be the design itself as depicted in the drawings, and traditional claim construction of written terms is less common than in utility patent cases. However, the interpretation of what is claimed versus what is disclaimed is a critical analysis.

• The "Term": The scope of the claimed design as defined by the solid vs. broken lines in the drawings.
• Context and Importance: The '552 Patent explicitly states that "The broken lines in the drawings illustrate the portions of the folding wireless charging stand, which form no part of the claimed design" ('552 Patent, DESCRIPTION). This disclaimer is crucial. Practitioners may focus on this distinction because infringement is assessed based only on the elements shown in solid lines. The defendants may argue that any similarity resides in the unclaimed portions, while the plaintiff may argue that the similarity in the claimed portions creates a deceptive overall appearance.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that the design should be viewed holistically and that the claimed portions (solid lines) create an overall visual impression that is dominant, making differences in unclaimed portions (broken lines) irrelevant to the ordinary observer.
  • Evidence for a Narrower Interpretation: A party could argue for a narrow interpretation by emphasizing that only the exact features shown in solid lines are protected. Any deviation in the accused product from these specific solid-line features, or similarities that exist only in the disclaimed broken-line features, could support a finding of no infringement.

VI. Other Allegations

• Indirect Infringement: The complaint does not include a specific count for indirect infringement. However, the prayer for relief seeks to enjoin Defendants from "aiding, abetting, contributing to, or otherwise assisting anyone in infringing upon the Design Patents" (Compl., p. 7, ¶(1)(b)).
• Willful Infringement: The complaint alleges that Defendants' infringement was willful (Compl. ¶14). The basis for this allegation is the assertion that Defendants acted "knowingly and willfully" in concert to manufacture and sell the infringing products, which are described as "almost identical" to Plaintiff's patented designs (Compl. ¶¶ 8, 13).

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

1. The Core Infringement Question: From the perspective of an ordinary observer, is the overall ornamental design of the accused "KU XIU" products substantially the same as the specific designs claimed in the '552 and '108 patents, considering the prior art?
2. Scope of Protection: How will the court interpret the scope of the claimed designs, particularly the distinction between the features shown in solid lines (claimed) and those in broken lines (unclaimed)? The outcome of the infringement analysis may depend heavily on which specific visual elements are considered part of the protected design.
3. Enforcement and Jurisdiction: As a case filed against a schedule of e-commerce aliases, a key practical issue will be whether Plaintiff can successfully establish the true identities of the Defendants, prove they operate in concert, and effectively enforce any potential judgment against entities that are allegedly designed to be difficult to trace (Compl. ¶¶ 11-12).