DCT
1:25-cv-08314
Dongguan Fangde Network Technology Co Ltd v. Individuals Corps Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Fangde Network Technology Co., Ltd. (People's Republic of China)
- Defendant: Numerous individuals and entities operating online storefronts, identified in a sealed Schedule A.
- Plaintiff’s Counsel: Whitewood Law PLLC
- Case Identification: 1:25-cv-08314, N.D. Ill., 08/08/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants target and sell products to consumers in Illinois through interactive e-commerce stores, constituting acts of infringement within the district. For foreign defendants not residing in any U.S. district, venue is asserted based on personal jurisdiction.
- Core Dispute: Plaintiff alleges that numerous online retailers operating on platforms such as Temu.com are manufacturing, offering for sale, and selling hooks that infringe its U.S. design patent.
- Technical Context: The dispute centers on the ornamental design of a consumer product—a metal hook—in the competitive e-commerce market for household goods.
- Key Procedural History: The complaint does not mention prior litigation, IPR proceedings, or licensing history relevant to the asserted patent. The action is brought against a large group of unidentified sellers, a common strategy in anti-counterfeiting enforcement on e-commerce platforms.
Case Timeline
| Date | Event |
|---|---|
| 2022-09-28 | U.S. Patent No. D984,249 S Priority Date |
| 2023-04-25 | U.S. Patent No. D984,249 S Issued |
| 2025-08-08 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. D984,249 S, titled “Hook,” issued April 25, 2023 (the “’249 Patent”).
The Invention Explained
- Problem Addressed: The complaint suggests the patented design represents a "novel approach to metal hooks, distinguished from prior art by its unique design" (Compl. ¶5). Design patents, by nature, address the problem of creating a new, original, and ornamental appearance for an article of manufacture.
- The Patented Solution: The ’249 Patent claims the specific ornamental design for a hook as depicted in its seven figures (’249 Patent, Description). The design features a flat, circular mounting base from which a body descends. The body is formed by two parallel vertical arms connected by an upper bridge, creating a central opening. Below this opening, the arms curve outward and then upward, forming two distinct, symmetrical hooks (’249 Patent, FIG. 1, FIG. 3). The side profile shows a single, continuous piece of material forming the hook shape (’249 Patent, FIG. 5).
- Technical Importance: The complaint asserts that the patented designs are "distinctive," "broadly recognized by consumers," and "highly sought after" (Compl. ¶14).
Key Claims at a Glance
- The single claim of the ’249 Patent is for "The ornamental design for a hook, as shown and described" (’249 Patent, Claim).
III. The Accused Instrumentality
- Product Identification: "Infringing Products" are identified as "hooks that closely mimic the invention patented by Plaintiff, including the same overall shape, dimensions, and aesthetic features" (Compl. ¶26).
- Functionality and Market Context: The accused products are hooks offered for sale and sold by Defendants through online commerce platforms like Temu.com (Compl. ¶1). The complaint alleges these products are of "demonstrably inferior quality and durability" compared to Plaintiff's genuine products (Compl. ¶9). Plaintiff provides a side-by-side visual comparison of its product with an accused "Infringing Listing" to illustrate the alleged copying (Compl. ¶31). This visual shows an online product listing for a hook that appears visually identical to the design shown in the ’249 Patent (Compl. ¶31).
IV. Analysis of Infringement Allegations
Claim Chart Summary:
D984,249 S Infringement Allegations
| Claim Element (from the single claim) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a hook, as shown and described. | Defendants are accused of making, using, selling, and/or importing hooks that "closely mimic" and "demonstrate a verbatim reproduction of the specific patented design elements" of the ’249 Patent. The complaint alleges the accused products are "substantially the same" as the patented design. | ¶¶26, 30, 50 | ’249 Patent, FIGS. 1-7 |
- Identified Points of Contention:
- Scope Questions: The central question in a design patent case is whether an "ordinary observer," familiar with the prior art designs, would be deceived into believing the accused product is the same as the patented design. The dispute will focus on the overall visual appearance and whether any differences between the accused hooks and the ’249 Patent design are minor enough that they do not alter the "substantially the same" impression.
- Technical Questions: The complaint alleges that images of the accused products "demonstrate a verbatim reproduction" of the patented design (Compl. ¶30). A key question will be whether the physical products, once produced in discovery, conform to the online images and possess the same ornamental features as claimed in the ’249 Patent from all claimed perspectives (front, back, side, top, and bottom).
V. Other Allegations
- Indirect Infringement: The complaint does not advance specific factual allegations for indirect infringement, focusing instead on direct infringement by the named online sellers (Compl. ¶49).
- Willful Infringement: Willfulness is alleged based on Defendants' "continued sale of infringing products despite actual knowledge of Plaintiff's patent rights" and their "deliberate copying of the patented design's distinctive features" (Compl. ¶55). The complaint alleges constructive notice via patent marking on Plaintiff's products and packaging pursuant to 35 U.S.C. § 287 (Compl. ¶54).
VI. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual identity: Under the "ordinary observer" test, are the accused hooks sold by the various defendants "substantially the same" in overall ornamental appearance as the design claimed in the ’249 Patent, or are there sufficient visual differences to distinguish them?
- A key procedural question will be one of jurisdiction and enforcement: Can the Plaintiff successfully establish personal jurisdiction over the numerous, potentially anonymous, foreign-based sellers and effectively enforce any resulting judgment against them?
- A central evidentiary question will be one of proof: What evidence, beyond the online storefront screenshots provided, will demonstrate that each of the numerous, distinct defendant entities manufactured, imported, or sold products that embody the patented design within the United States?