DCT

1:25-cv-09284

Yuting Chen v. =

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Yuting Chen (People's Republic of China)
    • Defendant: The Defendant Identified on Schedule "A" (Foreign Jurisdictions)
    • Plaintiff’s Counsel: Alioth Law
  • Case Identification: 1:25-cv-09284, N.D. Ill., 09/08/2025
  • Venue Allegations: Venue is asserted on the basis that the defendants are foreign entities who do not reside in the United States and are therefore subject to venue in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendants’ sale of wrenches on online marketplaces infringes a U.S. design patent covering the ornamental appearance of a wrench.
  • Technical Context: The dispute concerns the ornamental design of a hand tool, specifically a wrench used for adjusting the hinges of doors.
  • Key Procedural History: The complaint is an amended complaint. It joins multiple defendants, alleging they are selling substantially identical products believed to be sourced from the same foreign manufacturer.

Case Timeline

Date Event
2024-08-01 Plaintiff allegedly began selling its product
2024-09-19 D1,068,419 S Patent Priority Date
2024-10-01 Defendants allegedly began selling infringing products
2025-04-01 U.S. Patent No. D1,068,419 S Issued
2025-09-08 Amended Complaint Filed

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

U.S. Patent No. D1,068,419 S - "WRENCH"

  • Patent Identification: U.S. Patent No. D1,068,419 S, "WRENCH," issued April 1, 2025 (the "'’419 Patent").

The Invention Explained

  • Problem Addressed: The complaint describes a market for tools used to adjust door hinges to correct misalignment or swing resistance (Compl. ¶10). The plaintiff allegedly sought to improve upon existing products by creating an "upgraded design" (Compl. ¶11).
  • The Patented Solution: The ’419 Patent does not claim a functional solution but rather protects the specific ornamental appearance of a wrench (D1,068,419 S, Claim). The claimed design, depicted across eight figures, consists of a tool with a long, rectangular shaft, a T-shaped head assembly, and a cylindrical handle featuring a prominent grid-like, checkered grip pattern (D1,068,419 S, Figs. 1, 3, 5).
  • Technical Importance: The complaint alleges the plaintiff's design was an improvement that included adding "stripes on the handle to provide friction" and a "modular design on the wrench to fit for different doors" (Compl. ¶11).

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is: "The ornamental design for a wrench, as shown and described" (’419 Patent, Claim).
  • The scope of this claim is defined by the visual representations in the patent's drawings. Key ornamental features include:
    • A T-shaped head element.
    • An elongated, straight shaft with a generally rectangular cross-section.
    • A cylindrical handle at the end of the shaft.
    • A textured grip pattern on the handle consisting of a grid of small squares or rectangles.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "Infringing Products," identified as wrenches sold by Defendants through online e-commerce stores (Compl. ¶1, 5).

Functionality and Market Context

  • The complaint alleges the Defendants' products copy the design of the ’419 Patent and are sold in direct competition with the Plaintiff's product (Compl. ¶1). The complaint further alleges that the Defendants' products are "substantially identical to each other and the same as the design of the Asserted Patent" (Compl. ¶16). The complaint provides a side-by-side visual comparison of product pages for the Plaintiff's product and an example of a Defendant's product, both showing a red-handled wrench tool with a set of four black interchangeable T-shaped heads (Compl. ¶15).

IV. Analysis of Infringement Allegations

The standard for design patent infringement is whether an "ordinary observer," familiar with the prior art designs, would be deceived into purchasing the accused product believing it to be the patented design. The complaint alleges that the Defendants' products are "substantially identical" to the patented design (Compl. ¶16).

D1,068,419 S Infringement Allegations

Claimed Ornamental Feature (from ’419 Patent) Corresponding Feature in Accused Product (as depicted in Complaint) Complaint Citation Patent Citation
The overall visual impression of a wrench with a T-shaped head, long shaft, and cylindrical handle. The accused product is depicted as a wrench with a T-shaped head, long shaft, and cylindrical handle. ¶15 Fig. 1
A cylindrical handle having a textured grip pattern comprised of a grid of incised lines forming squares or rectangles. The accused product is shown with a cylindrical handle that appears to have a similar grid-like textured grip pattern. ¶15 Fig. 1
An elongated shaft with a generally rectangular cross-section connecting the head and the handle. The accused product is shown with an elongated shaft that appears to have a similar rectangular cross-section. ¶15 Fig. 3

Identified Points of Contention

  • Scope Questions: As the complaint provides only a single product page image, a key question will be whether minor differences between the patented design drawings and the various accused products sold by the multiple defendants are significant enough to avoid infringement in the eyes of an ordinary observer.
  • Technical Questions: A potential issue may arise concerning which features of the patented design are ornamental, and thus protected, versus purely functional. For example, the complaint mentions the "stripes on the handle to provide friction" (Compl. ¶11), which could raise the question of whether this feature is primarily functional and therefore outside the scope of design patent protection.

V. Key Claim Terms for Construction

In design patent litigation, claim construction is typically not a central issue, as the claim is defined by the drawings as a whole rather than by textual terms. The analysis focuses on a visual comparison between the claimed design and the accused product. The complaint does not provide sufficient detail for analysis of any specific definitional disputes.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement (Compl. ¶14) but does not plead specific facts to support the knowledge and intent elements required for such a claim (e.g., providing instructions or encouragement to others to infringe).
  • Willful Infringement: The complaint alleges that Defendants' conduct was "willful, intentional, purposeful, and in disregard of and indifferent to the rights of Plaintiff" (Compl. ¶30). It further alleges Defendants are acting "knowingly and intentionally or at least with reckless disregard" (Compl. ¶25). The complaint does not specify whether this allegation is based on pre-suit or post-suit knowledge of the ’419 Patent.

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

  1. A central issue will be one of visual identity: applying the "ordinary observer" test, are the accused wrenches sold by the various online defendants "substantially the same" as the design claimed in the '419 Patent, or do sufficient ornamental differences exist to avoid a finding of infringement?
  2. A key procedural question will be one of proper joinder: the complaint joins numerous defendants based on the allegation that they are selling "substantially the same" product from a common, unknown manufacturer (Compl. ¶16, 20). The case may turn on whether the accused products are similar enough to meet the "same accused product" requirement for joinder under 35 U.S.C. § 299.