DCT
1:25-cv-06464
Shenzhen Jiyou Supply Chain Co Ltd v. Individuals Corps Ltd
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Jiyou Supply Chain Co. Ltd. (People's Republic of China)
- Defendant: The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A
- Plaintiff’s Counsel: LW Legal LLC
- Case Identification: 1:25-cv-06464, N.D. Ill., 06/26/2025
- Venue Allegations: Venue is alleged to be proper because the Defendants are not residents of the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that numerous e-commerce store operators are selling watch bands that infringe its U.S. design patent.
- Technical Context: The case concerns the ornamental design of replacement watch bands, a large consumer market for accessories compatible with popular smartwatches.
- Key Procedural History: The filing is an Amended Complaint. Plaintiff alleges that its own products are marked in compliance with 35 U.S.C. § 287(a), providing constructive notice of the patent. The asserted patent claims foreign priority to three applications filed in the European Union.
Case Timeline
| Date | Event |
|---|---|
| 2022-11-15 | '089 Patent Foreign Priority Date |
| 2022-11-22 | '089 Patent Application Filing Date |
| 2023-05-16 | '089 Patent Issue Date |
| April 2024 | Date of screenshot evidence capture |
| 2025-06-11 | Date of Schedule A product URL capture |
| 2025-06-26 | Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D986,089 S - "Watch Band"
- Issued: May 16, 2023
The Invention Explained
- Problem Addressed: The complaint does not articulate a specific technical problem, but rather seeks to protect a "distinctive ornamental design" that it alleges is "unique to Plaintiff" and widely associated with it by consumers (Compl. ¶10).
- The Patented Solution: The patent protects the specific visual appearance of a watch band. The claimed design, shown in solid lines in the patent figures, features a wide, layered band with a central section containing a series of transverse loops. A cord is woven through these loops in a crisscross pattern, creating a distinctive "tactical" aesthetic ('089 Patent, FIG. 1, FIG. 3). The design also includes specific shapes for the end connectors that attach to a watch case. The patent explicitly disclaims the portions of the watch band shown in broken lines as not being part of the protected design ('089 Patent, p. 2, col. 1:25-27).
- Technical Importance: The complaint alleges that the patented design is a significant commercial asset, having become "widely recognized and exclusively associated with Plaintiff by consumers, the public and the trade" (Compl. ¶10).
Key Claims at a Glance
- The patent contains a single claim for "The ornamental design for a watch band, as shown and described" ('089 Patent, col. 2:57-59).
- The scope of this claim is defined by the visual appearance of the watch band as depicted in the solid-line drawings of the patent's figures ('089 Patent, FIGS. 1-24).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "watch bands" sold by the Defendants through various e-commerce storefronts on platforms including Amazon, Walmart, Ebay, Alibaba, and Aliexpress (Compl. ¶¶4, 13).
Functionality and Market Context
- The accused products are replacement watch bands marketed as being compatible with various models of the Apple Watch (Compl. p. 3, screenshot). The complaint alleges that all Defendants sell the "same product," using identical product photos, names, and descriptions (Compl. ¶¶16, 18). A screenshot provided in the complaint shows one such product listing, describing the bands as "rugged" and "Inspired by Tactical Backpacks" (Compl. ¶9). A screenshot from an Amazon.com product listing shows the accused watch band and includes a highlighted reference to the asserted '089 Patent (Compl. ¶9).
IV. Analysis of Infringement Allegations
The complaint alleges that the Defendants' products infringe the single claim of the '089 Patent. In design patent cases, infringement is determined by 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's theory is that the accused products are visually indistinguishable from the patented design.
- D986,089 S Infringement Allegations
| Claim Element (from the single design claim) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a watch band, as shown and described. | The complaint alleges that the accused "Infringing Products has the same design as the patented design." The visual evidence provided shows a watch band with a wide strap, a central section with transverse loops, and a crisscross cord pattern that appears to be substantially the same as that shown in the patent's figures. | ¶17; ¶9 | '089 Patent, FIGS. 1-24 |
- Identified Points of Contention:
- Visual Similarity: The central question for the court will be a direct visual comparison between the ornamental features of the accused products and the solid-line drawings in the ’089 Patent. A potential dispute may arise over whether any minor differences between the products and the patent figures are sufficient to create a different overall visual impression for an ordinary observer.
- Scope of Protection: The infringement analysis must be limited to the features shown in solid lines in the patent drawings. The effect of the unclaimed elements (shown in broken lines) on the overall appearance could be a point of discussion, though legally they do not form part of the protected design.
V. Key Claim Terms for Construction
In design patent litigation, claim construction focuses on the scope of the design as depicted in the drawings, rather than on interpreting textual terms.
- The Term: "The ornamental design for a watch band, as shown and described"
- Context and Importance: The scope of this claim is defined entirely by the patent's drawings. The most critical interpretive issue is the distinction between what is claimed (solid lines) and what is not (broken lines). Practitioners may focus on this distinction to define the precise boundaries of the protected design.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the "overall visual impression" of the design should be considered holistically, focusing on the combination of claimed elements that create its unique aesthetic.
- Evidence for a Narrower Interpretation: The patent specification provides an explicit limitation on scope, stating: "The broken lines depict portions of the watch band that form no part of the claimed design" ('089 Patent, p. 2, col. 1:25-27). This statement strictly confines the protected design to the features rendered in solid lines.
VI. Other Allegations
- Indirect Infringement: The complaint includes a general allegation of indirect infringement and requests injunctive relief against "aiding, abetting, [or] contributing to" infringement (Compl. ¶22; Prayer for Relief ¶1(b)). However, the complaint does not plead specific facts to support the requisite elements of knowledge and intent for either induced or contributory infringement, such as allegations that Defendants instruct third parties on how to infringe.
- Willful Infringement: The complaint alleges that Defendants’ infringement has been willful and intentional (Compl. ¶20). While this is pleaded "on information and belief," the complaint provides a product screenshot from an Amazon listing that explicitly references "US Patent Nos. US D986089" (Compl. ¶9). This evidence may be used to argue that at least one seller had actual knowledge of the patent, which could support a willfulness finding.
VII. Analyst’s Conclusion: Key Questions for the Case
- The Core Infringement Question: From the perspective of an ordinary observer, is the overall ornamental appearance of the Defendants' watch bands substantially the same as the design claimed in the '089 Patent's solid-line drawings?
- The Willfulness Question: Does the explicit reference to the '089 patent number in an online product listing constitute sufficient evidence of pre-suit knowledge to support a claim for willful infringement, and can such knowledge be imputed to the other anonymous "Schedule A" defendants based on the allegation that they all sell the "same product"?
- The Enforcement Question: Given that the defendants are unnamed foreign entities identified only in a sealed "Schedule A," a key practical issue will be the Plaintiff's ability to prove a sufficient link between them to justify a broad injunction and to effectively enforce any resulting judgment against disparate online sellers.