DCT

1:25-cv-07581

Guangzhou Youlan Technology Co Ltd v. Partnerships Unincorp Associations In Schedule A

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-07581, N.D. Ill., 07/07/2025
  • Venue Allegations: Venue is based on allegations that Defendants operate interactive commercial internet stores that directly target business activities toward consumers in Illinois, have offered products for sale, and have completed sales to residents of Illinois.
  • Core Dispute: Plaintiff alleges that Defendants’ online stores sell "knock-off" outdoor chaise lounges that infringe its U.S. design patent.
  • Technical Context: The dispute is in the field of outdoor furniture, where the ornamental and aesthetic appearance of a product is a key driver of consumer choice and market value.
  • Key Procedural History: This action has been filed against a "Schedule A" list of defendants, a common procedure used to combat anonymous or pseudonymous online sellers of allegedly infringing goods. The complaint indicates that the identities of the defendants are concealed and that Plaintiff anticipates needing to amend the complaint as more information becomes available.

Case Timeline

Date Event
2023-08-25 U.S. Patent No. D1,075,331 Application Filed
2025-05-20 U.S. Patent No. D1,075,331 Issued
2025-07-07 Complaint Filed

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

U.S. Design Patent No. D1,075,331 - "OUTDOOR CHAISE LOUNGE"

  • Patent Identification: U.S. Design Patent No. D1,075,331, "OUTDOOR CHAISE LOUNGE," issued May 20, 2025 (’331 Patent).

The Invention Explained

  • Problem Addressed: The complaint does not explicitly state a problem addressed, but implies a need for new and distinctive ornamental designs for outdoor furniture to achieve aesthetic appeal and commercial success (Compl. ¶¶ 5-6).
  • The Patented Solution: The patent protects the specific ornamental design for an outdoor chaise lounge as depicted in its figures (’331 Patent, CLAIM, FIGS. 1-8). The complaint highlights the design’s "leg linking mechanism" as a notable feature contributing to its "distinctive and aesthetically appealing design," which combines portability, comfort, and functionality (Compl. ¶5). The overall visual impression is that of a two-section, foldable lounge chair with a specific arrangement of legs and support structures.
  • Technical Importance: The complaint alleges the design was "first to market" and achieved commercial success, as evidenced by the "proliferation of imitation products" (Compl. ¶¶ 5, 7).

Key Claims at a Glance

  • The single claim of the ’331 Patent is for "The ornamental design for an outdoor chaise lounge, as shown and described" (’331 Patent, p. 3, CLAIM).
  • The essential elements of the design are the visual characteristics shown in solid lines in the patent's eight figures, including the overall shape and configuration of the lounge, the proportions of its sections, and the specific appearance of the frame and leg structures (’331 Patent, FIGS. 1-8).
  • The patent explicitly disclaims subject matter shown in broken lines, stating they "depict portions of the outdoor chaise lounge that form no part of the claimed design" (’331 Patent, p. 3, DESCRIPTION).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "knock-off product[s]" described as outdoor chaise lounges (Compl. ¶¶ 3, 5). These products are allegedly sold through various online marketplace accounts operated by the Defendants (Compl. ¶¶ 2, 10).

Functionality and Market Context

  • The complaint alleges the accused products are "the same product that infringes" the patented design and that Defendants have "copied this leg linking design" (Compl. ¶¶ 5, 11). The complaint references an Exhibit C, which is not included in the provided filing, as showing the "knock-off products" (Compl. ¶10). Without this exhibit, the specific appearance of the accused products cannot be analyzed. The complaint alleges these products are sold through stores designed to appear as if they are selling licensed products (Compl. ¶3). The complaint includes a perspective view of the patented design to illustrate the claimed features (Compl. ¶7, p. 3).

IV. Analysis of Infringement Allegations

The complaint does not contain a detailed claim chart comparing the patented design to the accused products. The infringement theory is presented narratively.

The core of the infringement allegation is that the Defendants are selling products that are visually indistinguishable from the patented design to an ordinary observer (Compl. ¶¶ 3, 11, 22). Plaintiff states that Defendants have "copied this leg linking design, and thus the overall design of the claimed design in the **331 patent" (Compl. ¶5). The infringement test for a design patent is whether, in the eye of an ordinary observer, the resemblance is such as to deceive such an observer, inducing them to purchase one supposing it to be the other. The complaint alleges that Defendants sell the "same knock-off product" that infringes the design, suggesting a belief that the accused products are identical copies (Compl. ¶3). The complaint presents an image of the patented design, which corresponds to Figure 1 of the ’331 Patent, as the basis for the infringement claim (Compl. ¶7, p. 3).

  • Identified Points of Contention:
    • Visual Similarity: The central question will be whether the accused products, once identified, are "substantially the same" as the claimed design. The analysis will depend on a side-by-side comparison of the overall ornamental appearance of the accused products and the design claimed in the ’331 Patent.
    • Scope Questions: A key issue will be the scope of the claimed design in light of the prior art. The comparison must focus on the novel ornamental features of the design as a whole, not just on functional elements. The significance of the "leg linking mechanism" (Compl. ¶5) to the overall visual impression will be a point of focus.

V. Key Claim Terms for Construction

In design patent cases, there are typically no "terms" to construe as in utility patent litigation. The "claim" is defined by the drawings as a whole. The analysis focuses on the scope of the claimed design.

  • The "Term": The overall ornamental design for an outdoor chaise lounge.
  • Context and Importance: The scope of the design patent is the core of the case. The court will need to determine what specific visual elements are protected by the patent, considering the drawings from all perspectives. The disclaimed portions, shown in broken lines, will be critical in limiting the scope of protection to only the ornamental features shown in solid lines (’331 Patent, p. 3, DESCRIPTION).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim covers the overall design "as shown and described" (’331 Patent, p. 3, CLAIM), suggesting that the general visual impression is protected, not merely a specific feature in isolation. The various views (top, bottom, side, front, rear, perspective) collectively define the protected three-dimensional appearance (’331 Patent, FIGS. 1-8).
    • Evidence for a Narrower Interpretation: The patent explicitly disclaims the portions shown in broken lines, narrowing the scope of the protected design (’331 Patent, p. 3, DESCRIPTION). Furthermore, the scope of any design patent is limited by the prior art. The design's novelty may lie in the specific combination and arrangement of otherwise known elements, such as a folding frame or rectangular lounge surfaces, which could narrow the scope of what constitutes an infringing design.

VI. Other Allegations

Indirect Infringement

  • The complaint does not contain a formal count for indirect infringement. However, the prayer for relief requests an injunction against those "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl. Prayer for Relief, ¶1(b)), which may suggest an intent to pursue such theories.

Willful Infringement

  • The complaint alleges that Defendants' infringement was and is "knowingly and willfully" committed (Compl. ¶11). The basis for this allegation is the assertion that Defendants are selling "knock-off products" and have "copied" the Plaintiff's patented design (Compl. ¶¶3, 5, 18). Plaintiff further alleges that Defendants use tactics like operating under fictitious names to conceal their identity and evade enforcement, which could be argued as evidence of willfulness (Compl. ¶¶13-14).

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

  1. Procedural Efficacy: A primary issue is procedural: can the Plaintiff successfully identify the anonymous Defendants through discovery from online marketplaces and payment processors, and subsequently enforce any judgment against foreign entities who allegedly use evasive tactics to avoid jurisdiction?
  2. Infringement via Visual Comparison: The case will hinge on a visual test: is the ornamental design of the accused products "substantially the same" as the design claimed in the ’331 Patent, such that an ordinary observer would be deceived? The outcome will depend entirely on the specific appearance of the accused products, which are not depicted in the complaint.
  3. Scope and Validity: A potential underlying question, should the case proceed, will concern the scope and validity of the design patent itself. The analysis will consider whether the claimed design, particularly the "leg linking mechanism" and overall configuration, is merely functional or is sufficiently ornamental and non-obvious over prior chaise lounge designs.