DCT

1:25-cv-06601

Dongguan Naquan E Commerce Co Ltd v. Sanbo Wang

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I. Executive Summary and Procedural Information

  • Parties & Counsel:

  • Case Identification: 1:25-cv-06601, N.D. Ill., 06/26/2025

  • Venue Allegations: Plaintiffs allege venue is proper because Defendant availed herself of the United States by obtaining a U.S. patent and filing infringement complaints with Amazon, which affected Plaintiffs' sales in Illinois.

  • Core Dispute: Plaintiffs seek a declaratory judgment that U.S. Patent No. 1,058,875 is invalid and unenforceable, alleging the patent covers an ornamental design for a camping light that was anticipated by prior art, and that Defendant engaged in inequitable conduct by not disclosing this art to the U.S. Patent and Trademark Office.

  • Technical Context: The dispute centers on the ornamental design of portable, rechargeable LED string lights used for camping and outdoor activities, a competitive segment of the consumer electronics market.

  • Key Procedural History: The action was precipitated by infringement reports Defendant submitted to Amazon against Plaintiffs. The complaint also references a separate Chinese patent litigation where a court found that Defendant's product infringed a Chinese design patent, which Plaintiffs now assert as prior art against the U.S. patent-in-suit.

Case Timeline

Date Event
1912-06-14 U.S. Patent No. 1,058,875 Application Date
1913-04-15 U.S. Patent No. 1,058,875 Issue Date
2022-11-15 Chinese Patent No. 307861226 Filing Date
2023-02-24 Chinese Patent No. 307861226 Issue Date
2023-06-24 Alleged first public sale of "Hiromeco Camping String Lights" on Amazon
2024-03-05 Chinese patent infringement lawsuit filed against Defendant's company
2024-03-26 Alleged Filing Date of U.S. Patent No. 1,058,875 (per complaint)
2024-06-26 Chinese court finds infringement by Defendant's product (per complaint)
2025-01-21 Alleged Issue Date of U.S. Patent No. 1,058,875 (per complaint)
2025-06-13 Plaintiffs receive infringement notice emails from Amazon
2025-06-26 Complaint for Declaratory Judgment Filed

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

A notable discrepancy exists within the provided documents. The complaint repeatedly identifies the patent-in-suit as U.S. Patent No. 1,058,875 and makes factual allegations regarding a design patent for a "camping light" allegedly issued in 2025 (Compl. ¶¶1, 17-18). However, the provided patent document for U.S. Patent No. 1,058,875 is a utility patent titled "Rail Joint," issued in 1913. This analysis proceeds by examining the patent document provided, as required.

U.S. Patent No. 1,058,875 - "Rail Joint"

  • Patent Identification: U.S. Patent No. 1,058,875, "Rail Joint," issued April 15, 1913 (’875 Patent).

The Invention Explained

  • Problem Addressed: The patent addresses the need for a simple, strong, and efficient means of joining the ends of railroad rails, particularly for laying temporary tracks where speed and ease of connection are important (’875 Patent, col. 1:10-18). The invention aims to avoid the need for separate bolts, fish plates, and other conventional fasteners (’875 Patent, col. 1:10-18, 62-65).
  • The Patented Solution: The invention provides two interlocking members that are secured, such as by welding, to the ends of abutting rails (’875 Patent, col. 2:41-43). One member features a tenon with locking fingers, while the other features a corresponding mortise, or recess, to receive those fingers (’875 Patent, col. 2:6-13, 23-28). The members also include co-acting wedge-shaped arms that serve as centering guides, allowing the rails to be quickly and securely aligned and locked together with a simple sliding motion (’875 Patent, col. 2:51-56). The overall structure is designed to create a rigid joint that resists both vertical and lateral movement (’875 Patent, col. 2:60-65).
  • Technical Importance: This solution offered a method for rapidly deploying and connecting rail sections without requiring the complex and time-consuming process of bolting separate joint bars, a significant advantage for temporary or military railway construction (’875 Patent, col. 1:66-76).

Key Claims at a Glance

  • The complaint does not assert specific claims, as its allegations are directed at an ornamental design. The following analysis is of the first independent claim of the provided ’875 Patent.
  • Independent Claim 1:
    • A rail joint including members adapted to be secured upon abutting rail ends
    • one of said members being formed with a wedge-shaped locking arm forming a centering member
    • and with tenons or locking fingers at right angles to each other
    • the other of said members being recessed to provide a wedge-shaped locking arm coacting with that of the first member
    • and a wall spaced therefrom and having an interiorly formed shoulder
    • said member being further recessed to form mortises at right angles to each other for the reception of the locking fingers of the first member
    • the wedge-shaped member of the first locking member being formed with an exteriorly formed shoulder adapted to engage with the interiorly formed shoulder of the spaced wall of the second member

III. The Accused Instrumentality

Product Identification

  • Plaintiffs' "Camping String Lights" sold on Amazon under the OGERY brand (ASIN: B0D5HTW1NB) (Compl. ¶¶11, 14).

Functionality and Market Context

  • The accused product is a portable, rechargeable lighting device for camping and outdoor use (Compl. p. 4). It consists of a circular housing from which a 32.8-foot string of LED lights can be unwound and retracted (Compl. p. 4).
  • The housing itself also functions as a lamp, and the product offers multiple lighting modes (e.g., "Warm string lights," "Camping glare light") and brightness levels (Compl. p. 4). The complaint includes a screenshot from the Amazon product page depicting these features. (Compl. p. 4).
  • Plaintiffs allege their product is commercially successful, having been designated as "Amazon's Choice" and ranking as a best seller in its category (Compl. ¶¶12-13).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement and invalidity of the '875 Patent but does not contain allegations mapping the accused "Camping String Lights" to the claims of the '875 Patent for a "Rail Joint." Instead, the complaint's substantive allegations concern the patent's claimed ornamental design for a camping light, arguing that this design is invalid in light of prior art. A side-by-side visual in the complaint compares the design allegedly claimed in the '875 Patent to a prior art Chinese design patent. (Compl. p. 6). Because the complaint's factual theory of the case is entirely disconnected from the claims of the patent identified by number and provided in the record, a traditional claim chart analysis is not possible.

The core of the Plaintiffs' case, as pleaded, is an invalidity challenge under 35 U.S.C. §§ 102 and 103 (Compl. ¶24). The complaint alleges that the ornamental design claimed in the '875 patent is anticipated or rendered obvious by at least two pieces of prior art:

  1. Chinese Patent No. 307861226: This design patent, filed in November 2022, allegedly "discloses a design identical or at least substantially similar" to the design claimed in the '875 Patent (Compl. ¶25).
  2. "Hiromeco Camping String Lights": This product was allegedly offered for sale and sold on Amazon "at least since June 24, 2023," prior to the '875 Patent's alleged filing date of March 26, 2024 (Compl. ¶¶27, 28). The complaint includes a customer review image dated June 24, 2023, showing the Hiromeco product. (Compl. p. 8).

V. Key Claim Terms for Construction

The complaint provides no basis for claim construction analysis, as its allegations are focused on the overall ornamental appearance of a design, not the specific limitations of a utility patent claim. However, were the '875 Patent for a "Rail Joint" to be litigated, the following term from its independent claim 1 would likely be central to the dispute.

  • The Term: "wedge-shaped locking arm"
  • Context and Importance: This term appears repeatedly and is fundamental to the invention's dual function of centering and locking the rail members. The precise geometry and functional requirements of the "wedge-shape" would be critical to determining the scope of the claim and whether an accused device that uses a different guiding mechanism would infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself describes the arm's function as "forming a centering member," suggesting the term could cover any tapered or inclined structure that guides the two parts into alignment during assembly (’875 Patent, col. 2:81-82).
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the wedge member (20) co-acts with a recessed wedge-shaped member (29) and includes specific shoulders (22, 31) that engage to relieve downward pressure (’875 Patent, Fig. 2; col. 2:13-22, 56-60). This could support a narrower construction limited to structures that include these specific interlocking features and perform this pressure-relief function.

VI. Other Allegations

  • Inequitable Conduct: The complaint includes a count for a declaration of unenforceability due to inequitable conduct (Compl. ¶¶32-40). It alleges that the Defendant knew of the material prior art, specifically the Chinese '226 Patent, before or during prosecution of the '875 Patent (Compl. ¶¶35-36). The basis for this alleged knowledge is a Chinese patent infringement lawsuit where a court found Defendant's product infringed the '226 Patent (Compl. ¶36). Plaintiffs allege that Defendant intentionally withheld this material prior art from the PTO with the intent to deceive, and that the patent would not have issued had the art been disclosed (Compl. ¶¶37-39).

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

  • A primary threshold issue will be one of identity: The case cannot proceed until the profound discrepancy between the patent number cited in the complaint (U.S. 1,058,875 for a "Rail Joint" issued in 1913) and the substantive allegations concerning a modern design patent for a "camping light" is resolved. This likely represents a typographical error in the complaint that will require amendment.
  • Assuming the complaint is amended to identify the correct design patent, a central question will be one of validity: Do the asserted prior art references—the Chinese '226 patent and the "Hiromeco" product sold on Amazon—disclose a design that is "substantially the same" as the claimed ornamental design, thereby invalidating it under the "ordinary observer" test for design patent anticipation?
  • A third key issue will be one of patentee conduct: Can Plaintiffs produce sufficient evidence to establish, by clear and convincing evidence, that the Defendant (1) had knowledge of the asserted prior art during prosecution, (2) knew it was material to patentability, and (3) made a deliberate decision to withhold it from the PTO with the specific intent to deceive?