DCT

1:25-cv-03321

Pranash Tianjin Technology Development Co Ltd v. Individuals Corps Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-03321, N.D. Ill., 03/27/2025
  • Venue Allegations: Venue is alleged based on Defendants structuring their business to target consumers in the United States, including Illinois, through interactive e-commerce stores that offer shipping to the state and accept payment in U.S. dollars.
  • Core Dispute: Plaintiff alleges that numerous e-commerce store operators infringe a design patent covering the ornamental appearance of a posture support device.
  • Technical Context: The technology resides in the field of wearable health and wellness products, specifically devices designed to correct or support posture.
  • Key Procedural History: The complaint is structured as an action against a group of unidentified online sellers, referred to as "Seller Aliases," who are alleged to be part of a coordinated infringing operation. Plaintiff notes it provides notice of its patent rights by including the patent number in its own online product descriptions.

Case Timeline

Date Event
2020-11-10 U.S. Design Patent No. D948,061 Priority Date
2022-04-05 U.S. Design Patent No. D948,061 Issue Date
2025-03-27 Complaint Filing Date

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

U.S. Design Patent No. D948,061 - "Posture support device"

  • Patent Identification: U.S. Design Patent No. D948,061, "Posture support device", issued April 5, 2022.

The Invention Explained

  • Problem Addressed: The complaint asserts the patent covers a "new ornamental design for spinal correctional straps" (Compl. ¶8). In the context of a design patent, the implicit problem is the creation of a novel, non-obvious, and ornamental appearance for such a device.
  • The Patented Solution: The patent claims the specific visual appearance of a posture support device, not its functional characteristics (’061 Patent, Claim). The ornamental design is defined by the solid lines in the patent’s figures, which depict a vest-like garment featuring a distinct combination of shoulder straps, under-arm straps, a waist belt, and a prominent criss-cross strap pattern on the back (’061 Patent, Fig. 3, Fig. 8).
  • Technical Importance: The design provides a specific aesthetic for a consumer product in the competitive health and wellness market, which the plaintiff markets and sells through various online channels (Compl. ¶¶9-10).

Key Claims at a Glance

  • The single claim asserted is for "the ornamental design for a posture support device, as shown and described" (’061 Patent, Claim).
  • The scope of a design patent claim is defined by the visual representations in its drawings. Key ornamental features of the asserted design include:
    • A front view showing shoulder straps and under-arm support elements.
    • A back view dominated by a woven or criss-cross pattern of straps.
    • The overall configuration of the device as a wearable, vest-like support garment.

III. The Accused Instrumentality

Product Identification

  • The "Unauthorized Products" are identified as spinal adjustment and posture correcting straps sold by the Defendants (Compl. ¶¶2, 8).

Functionality and Market Context

  • The accused products are wearable posture correctors sold through numerous e-commerce stores operating under "Seller Aliases" on platforms such as Amazon, Alibaba, and AliExpress (Compl. ¶¶3, 13). The complaint alleges these products are sold by a network of anonymous sellers who use common tactics and may obtain products from a common source (Compl. ¶¶21-22). The core of the infringement allegation relates to the products' ornamental appearance rather than their function (Compl. ¶28). The complaint includes a screenshot of Plaintiff's own product listing, which it states embodies the patented design. (Compl. ¶10, Fig. 1). Figure 1 of the complaint displays Plaintiff's VOKOKOYA brand posture corrector on a model, illustrating the overall look of the patented design as sold in the market. (Compl. ¶10, Fig. 1).

IV. Analysis of Infringement Allegations

The complaint states that a detailed claim chart is provided as Exhibit 6; however, this exhibit was not available for review. The infringement analysis is therefore based on the narrative allegations in the complaint body.

The complaint alleges that the "Unauthorized Products" sold by Defendants infringe the D'061 patent because their overall ornamental appearance is substantially the same as the design claimed in the patent in the eye of an ordinary observer (Compl. ¶28). The infringement test for a design patent is 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's theory is that Defendants have sold, offered for sale, and imported products that copy the specific visual features depicted in the solid lines of the D'061 patent's figures (Compl. ¶¶27-29).

  • Identified Points of Contention:
    • Scope Questions: The central legal and factual question for design patent infringement will be whether the overall visual impression of the Defendants' "Unauthorized Products" is substantially the same as the claimed design in the ’061 Patent from the perspective of an ordinary observer.
    • Technical Questions: A primary evidentiary question will be what proof Plaintiff can offer to demonstrate that the specific designs of the products sold by each of the numerous, anonymous Defendants are, in fact, substantially similar to the patented design.

V. Key Claim Terms for Construction

As this case involves a design patent, the "claim" is understood to be the visual design depicted in the drawings (’061 Patent, Claim). Formal claim construction of specific textual terms is generally not a central issue; instead, the analysis focuses on comparing the overall visual appearance of the claimed design to the accused products.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants are "working in active concert" and "jointly and severally" infringe the patent (Compl. ¶24, ¶27). The prayer for relief also seeks to enjoin those "aiding, abetting, contributing to, or otherwise assisting" infringement, suggesting a potential theory of coordinated action among the various online sellers (Prayer for Relief, ¶1.b).
  • Willful Infringement: Willfulness is alleged based on Defendants "knowingly and willfully" manufacturing and selling the infringing products (Compl. ¶24, ¶31). To support this, the complaint alleges that Plaintiff provides notice of its patent rights by including the patent number in its own online product descriptions (Compl. ¶11). Figure 4 of the complaint shows a screenshot of a product description for a posture corrector that explicitly states "US Patent Number: D948061S," which Plaintiff may use to argue that its rights were publicly known. (Compl. ¶11, Fig. 4).

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

  • A core issue will be one of visual comparison: Does the ornamental design of the various "Unauthorized Products," when viewed as a whole, create a visual impression that is substantially the same as the design claimed in the D'061 patent, as assessed through the eyes of an ordinary observer?
  • A significant procedural and evidentiary question will be whether Plaintiff can successfully link the numerous anonymous "Seller Aliases" to a coordinated infringing enterprise and provide sufficient evidence of infringement for each distinct product offered across these disparate online storefronts.
  • The viability of the willfulness claim may depend on whether Plaintiff can establish that Defendants had pre-suit knowledge of the D'061 patent. The court will need to determine if Plaintiff's alleged public notice through its own product listings is sufficient to establish such knowledge for the purposes of enhanced damages or recovering Defendants' profits.