Shenzhen Weidali Technology Co Ltd v. Supa Ant LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Weidali Technology Co., Ltd. (China)
  • Defendant: Supa Ant LLC (Wyoming), Yasi Herbich, and Daniel Mirfani
  • Plaintiff’s Counsel: Alioth Law
• Case Identification: 1:25-cv-05060, N.D. Ill., 05/29/2025
• Venue Allegations: Venue is based on Defendants' business activities, which are allegedly directed toward consumers in the United States, including Illinois, through interactive e-commerce platforms.
• Core Dispute: Plaintiff seeks a declaratory judgment that Defendant's design patent for a metal tray is invalid and not infringed by Plaintiff's product, and further alleges tortious interference and deceptive trade practices based on Defendants' allegedly baseless infringement complaints on Amazon.
• Technical Context: The dispute centers on the ornamental design of wire-form metal racks, a common component in kitchenware products such as canning pot kits.
• Key Procedural History: The complaint alleges that Defendants filed multiple intellectual property complaints with Amazon against Plaintiff's products starting in June 2024, resulting in product delistings. Plaintiff asserts that the patent-in-suit is invalid in view of publicly sold, "substantially identical" designs that predate the patent's filing by more than one year.

Case Timeline

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

U.S. Design Patent No. D1,026,564 S - "Metal Tray"

• Patent Identification: U.S. Design Patent No. D1,026,564 S ("Metal Tray"), issued May 14, 2024 (the "'564 Patent").

The Invention Explained

• Problem Addressed: As a design patent, the '564 Patent does not describe or solve a technical problem. Instead, it seeks to protect a new, original, and ornamental design for an article of manufacture ('564 Patent, p. 1).
• The Patented Solution: The patent claims the specific ornamental appearance of a metal tray ('564 Patent, Claim). The claimed design, shown in solid lines in the patent's figures, consists of a circular wire-form basket constructed from several concentric wire rings intersected by multiple radial wires, supported by feet. A significant feature of the patent is its use of broken lines to illustrate handles, which explicitly indicates that the handles themselves are not part of the claimed design and are shown only for illustrative context ('564 Patent, DESCRIPTION).
• Technical Importance: The design provides a specific aesthetic for a common kitchenware item, intended to distinguish its appearance in the marketplace (Compl. ¶1).

Key Claims at a Glance

• The patent asserts a single claim: "The ornamental design for a metal tray, as shown and described." ('564 Patent, Claim).
• The visual elements of the claimed design are defined by the solid-line drawings in Figures 1-3, which depict:
  • A circular wire-form basket.
  • A construction of concentric and radial wires forming the base.
  • A circular wire rim.
  • Supporting feet formed from the wire structure.

III. The Accused Instrumentality

Product Identification

• Plaintiff's "canning pot kit, which includes a metal rack" sold on its Amazon storefront under the brand name "Vigamimn" (Compl. ¶1, ¶20). Specific Amazon Standard Identification Numbers (ASINs) targeted by Defendants' complaints include B0CFQP6X8K and B0D3M7BM41 (Compl. ¶12, ¶16).

Functionality and Market Context

• The complaint describes the product as a "key product" for the Plaintiff (Compl. ¶1). While its specific function is not detailed, its inclusion in a "canning pot kit" suggests it is used for holding items during food preservation processes (Compl. ¶1). The complaint alleges the product was part of a business with "substantial daily sales" and a "loyal customer base" prior to Defendants' actions (Compl. ¶20, ¶22).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

This is a declaratory judgment action where the Plaintiff alleges non-infringement. The complaint does not contain a formal claim chart but rather describes a dispute initiated by the Defendants through Amazon's IP complaint system (Compl. ¶10, ¶12). Plaintiff's position is that its product does not infringe the '564 Patent, a conclusion it alleges is supported by independent legal analyses from two U.S. patent attorneys (Compl. ¶13).

• Identified Points of Contention:
  • Scope Questions: A central legal issue for infringement will be the proper application of the "ordinary observer" test. The analysis will compare the overall ornamental appearance of Plaintiff's accused rack with the claimed design in the '564 Patent. Crucially, this comparison must be limited to the elements shown in solid lines in the patent drawings—the wire basket itself. The appearance of any handles on the Plaintiff's product is legally irrelevant to the infringement determination because the patent explicitly disclaims the handles ('564 Patent, DESCRIPTION).
  • Technical Questions: The complaint's primary focus is on invalidity, alleging that "substantially identical rack designs have been publicly sold in the U.S. marketplace by third parties since at least 2015" (Compl. ¶9). This suggests the designs may be very similar, raising the question of whether the infringement case hinges almost entirely on the patent's validity.

V. Key Claim Terms for Construction

Claim construction for design patents focuses on the overall visual impression of the drawings rather than the interpretation of textual terms.

• The Term: "The ornamental design for a metal tray, as shown and described."
• Context and Importance: The core of the dispute is the scope of the claimed design. Practitioners may focus on the visual scope defined by the patent's drawings, particularly the distinction between what is claimed (solid lines) and what is disclaimed (broken lines). The court's interpretation of this visual scope will define the boundaries of the patent protection and will be dispositive for the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The design is for a general "metal tray," not one limited to a specific use like canning. The three figures show the disclaimed handles in different orientations (vertical, diagonal, horizontal), which may be argued to reinforce that the claimed basket design is independent of any particular handle configuration ('564 Patent, Figs. 1-3).
  • Evidence for a Narrower Interpretation: The precise arrangement, number, and curvature of the concentric and radial wires as depicted in the solid-line drawings define the specific ornamental design. Any significant deviation in these features in an accused product could support a finding of non-infringement. The patent describes the claim simply as the design "as shown and described," tying the scope directly to the visual details of the drawings ('564 Patent, Claim).

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

• A core issue will be one of validity: Does the alleged prior art, specifically the "substantially identical rack designs" that Plaintiff claims have been on sale since 2015, anticipate or render obvious the specific ornamental design claimed in the '564 Patent, thereby invalidating it under 35 U.S.C. § 102? (Compl. ¶9).
• A key infringement question will be the scope of the claimed design: In applying the ordinary observer test, the court must determine if Plaintiff's product is substantially the same as the '564 Patent's design, which is legally defined only by the wire basket shown in solid lines and explicitly excludes the handles shown in broken lines.
• A dispositive issue for the business tort claims will be one of bad faith: Can the Plaintiff prove that Defendants' enforcement actions on Amazon were not just incorrect but were undertaken "maliciously" and with knowledge of the patent's invalidity or non-infringement, thereby constituting tortious interference? (Compl. ¶10, ¶21).