Ren v. Ailunus

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Quan Ren and Kui Cao (People's Republic of China)
  • Defendant: The Individuals and Entities Operating [Redacted] (various, primarily People's Republic of China)
  • Plaintiff’s Counsel: Whitewood Law PLLC
• Case Identification: 1:25-cv-09278, N.D. Ill., 08/14/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants target and sell products to consumers in the United States, including Illinois, through interactive e-commerce stores, thereby committing acts of infringement in the district.
• Core Dispute: Plaintiffs allege that Defendants’ online sales of protective watch cases infringe an ornamental design patent for a watch case.
• Technical Context: The dispute is in the high-volume consumer market for smartwatch accessories, where aesthetic design is a significant driver of consumer choice.
• Key Procedural History: The complaint alleges that Plaintiffs have licensed the patent-in-suit to various businesses, including Tauri and Spigen. No prior litigation or administrative proceedings are mentioned.

Case Timeline

Date	Event
2022-07-22	’405 Patent Priority Date
2024-09-24	’405 Patent Issue Date
2025-08-14	Complaint Filing Date

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

U.S. Patent No. D1,043,405 - "Protective case for a watch"

• Patent Identification: U.S. Patent No. D1,043,405, "Protective case for a watch," issued September 24, 2024 (’405 Patent).

The Invention Explained

• Problem Addressed: Design patents do not articulate a technical problem and solution in the manner of utility patents. The implicit goal is to create a new, original, and ornamental design for an article of manufacture—in this instance, a protective case for a watch.
• The Patented Solution: The patent claims the specific ornamental appearance of a watch case. The design, as depicted in the patent’s figures, features a generally rectangular case with rounded corners, a prominent raised bezel surrounding the screen area, and a distinct side piece that appears to cover the watch's crown and buttons (’405 Patent, Figs. 1-8). The overall visual impression is created by the specific proportions, surface contours, and arrangement of these features (’405 Patent, Claim).
• Technical Importance: The complaint asserts that these designs are "highly sought after watch covers, with demonstrated commercial success in the smartwatch accessory market" (Compl. ¶14).

Key Claims at a Glance

• Design patents contain a single claim. The asserted claim is: "The ornamental design for a protective case for a watch, as shown and described." (’405 Patent, Claim).
• The essential visual elements of this claim are the specific aesthetic features depicted in Figures 1 through 8, including:
  • The overall shape and proportions of the case body.
  • The specific contours of the side piece designed to accommodate watch controls.
  • The configuration of openings for speakers or sensors.
  • The relationship between the raised bezel and the main body of the case.

III. The Accused Instrumentality

Product Identification

• "Infringing Products" are identified as "watch covers" sold by Defendants on various "Third Party Platforms" such as Amazon.com (Compl. ¶1, ¶11, ¶22).

Functionality and Market Context

• The accused products are alleged to be watch covers that "closely mimic the invention patented by Plaintiffs, including the same overall shape, dimensions, and aesthetic features" (Compl. ¶22). The complaint alleges these products are designed to fit around a specific type of smartwatch and have a curved face and a "snap closed feature" (Compl. ¶23). The complaint presents images purporting to show the infringing products, which it claims demonstrate a "verbatim reproduction" of the patented design elements (Compl. ¶26). The complaint includes a table referencing "select screenshots" as exemplary evidence of Defendants offering these products for sale in the forum (Compl. ¶24).

IV. Analysis of Infringement Allegations

Design patent 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 outlines its infringement theory by identifying specific features it alleges are copied.

’405 Patent Infringement Allegations

Claim Element (from the ornamental design as shown and described)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a protective case for a watch	The accused watch covers allegedly embody a design that is "substantially the same" as the patented design.	¶50	Figs. 1-8
The exact curved geometrical shape that allows precise fitting around a smartwatch	The Infringing Products allegedly reproduce this specific shape.	¶51	Figs. 1, 2, 8
The identical snap-closure mechanism that provides secure attachment	The Infringing Products allegedly implement the same mechanism.	¶51	Figs. 4, 5, 6
The precise surface contours and proportional relationships that distinguish the original design	The Infringing Products allegedly mimic these aesthetic features.	¶51	Figs. 1-8

Identified Points of Contention

• Scope Questions: A central question will be whether the complaint's characterization of functional features, such as a "snap-closure mechanism" and a shape that allows "precise fitting" (Compl. ¶51), improperly expands the scope of an ornamental design patent. Design patents protect non-functional aesthetic appearance, raising the question of how these alleged functional similarities should be weighed in the infringement analysis.
• Technical Questions: The infringement test will turn on a visual comparison. The key question for the court will be whether an ordinary observer would find the accused products and the patented design substantially the same in their overall ornamental appearance, or if there are sufficient visual differences to distinguish them. The complaint’s assertion of a "verbatim reproduction" suggests it views any differences as trivial (Compl. ¶26).

V. Key Claim Terms for Construction

In design patent cases, the single claim is typically not subject to extensive construction, as the figures themselves define the scope. However, the interplay between the claim language and the complaint’s characterizations may create focal points.

• The Term: "The ornamental design... as shown and described."
• Context and Importance: This is the entirety of the claim. Its construction defines the scope of protection. The dispute will likely center on what aspects of the depicted article are purely "ornamental" versus functional. Practitioners may focus on this issue because the complaint explicitly points to allegedly copied functional aspects like a "snap-closure mechanism" and a shape for "precise fitting" (Compl. ¶51), which may be excluded from the scope of a design patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim covers the overall visual impression of the design shown in the figures. A party might argue that the design as a whole creates a distinct aesthetic that the accused products copy, even if some individual elements have functional aspects.
  • Evidence for a Narrower Interpretation: The claim is limited to the specific ornamental features shown. A party could argue that any features dictated by the function of the watch case (e.g., the general shape required to fit a watch, the openings for buttons) must be filtered out of the infringement comparison, leaving a narrower scope of protectable design elements. The broken lines in the patent figures explicitly "form no part of the claimed design," disclaiming those specific portions from the patent's scope (’405 Patent, Description).

VI. Other Allegations

• Indirect Infringement: While not pleaded as a separate count, the prayer for relief seeks to enjoin Defendants from "inducing others" to infringe (Compl. p. 20). The complaint alleges that Defendants are part of a "coordinated scheme" or "conspiracy" to manufacture and distribute the accused products (Compl. ¶6).
• Willful Infringement: Plaintiffs allege that infringement has been willful and deliberate (Compl. ¶55). The basis for this allegation is Defendants' purported "actual knowledge of Plaintiffs' patent rights," which Plaintiffs assert arises from their products being marked with the patent number in compliance with 35 U.S.C. § 287 (Compl. ¶54).

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

This case appears to be a straightforward design patent enforcement action against online sellers, but it presents classic issues inherent in design patent litigation. The central questions for the court will likely be:

• A core issue will be one of visual comparison: Under the "ordinary observer" test, is the overall ornamental appearance of the accused watch cases substantially the same as the specific design claimed in the ’405 Patent, or are there visual differences significant enough to avoid a finding of infringement?
• A key legal question will be the ornamental/functional distinction: To what degree should the court filter out functional aspects of the watch case design—such as those related to its "snap-closure" or "precise fitting," as alleged by Plaintiffs—when comparing the accused products to the claimed ornamental design? The resolution of this issue will directly impact the scope of the patent and the infringement analysis.