DCT

1:25-cv-09434

Dongguan Fangde Network Technology Co Ltd v. Individuals Corps Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-09434, N.D. Ill., 08/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of infringement in the district by offering for sale and selling infringing products to consumers in Illinois through online platforms. Plaintiff further alleges that because Defendants are foreign entities not resident in any U.S. district, venue is proper in any district where they are subject to personal jurisdiction.
  • Core Dispute: Plaintiff alleges that Defendant’s online sales of magnetic hooks infringe the single claim of Plaintiff's design patent covering the ornamental design for a hook.
  • Technical Context: The dispute centers on the ornamental design of a consumer good—a metal hook—sold through high-volume e-commerce platforms like Temu.com.
  • Key Procedural History: The filing is an Amended Complaint. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent-in-suit, are mentioned in the complaint.

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
2025-08-13 Complaint Filed

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

U.S. Patent No. D984,249 S - "Hook"

  • Patent Identification: U.S. Patent No. D984,249 S, “Hook,” issued April 25, 2023 (the “’249 Patent”).

The Invention Explained

  • Problem Addressed: The complaint asserts that the patented design represents a "novel approach to metal hooks, distinguished from prior art by its unique design" (Compl. ¶5).
  • The Patented Solution: The ’249 Patent protects the specific ornamental appearance of a hook. The design features a circular magnetic base from which a bent metal wire form extends (D984,249 S, FIG. 1). The wire forms a central U-shaped arch, and its two ends terminate in opposing, outwardly-angled hooks (D984,249 S, FIGS. 1, 3). The overall visual impression is one of a symmetrical, dual-hook structure suspended from a flat, circular base (D984,249 S, FIG. 3).
  • Technical Importance: The complaint alleges the design is distinctive and introduces "innovative features not found in existing designs that were not previously available in the market" (Compl. ¶5).

Key Claims at a Glance

  • The ’249 Patent contains a single claim: “The ornamental design for a hook, as shown and described” (D984,249 S, Claim).
  • This claim protects the overall visual appearance of the hook as depicted in the patent’s seven figures.

III. The Accused Instrumentality

Product Identification

  • The accused products are identified as “Magnetic Hooks 304 Stainless Steel Hooks Heavy Duty Magnets Hanging Ho...” offered for sale by the seller “ZestGrove” on the e-commerce platform Temu.com (Compl. ¶¶1, 28-29; Compl. at 7).

Functionality and Market Context

  • The complaint describes the accused products as hooks that are sold through online storefronts directly to consumers in the United States, including Illinois (Compl. ¶¶14, 23). A screenshot in the complaint shows the product is offered for sale with shipping to a Chicago, IL address (Compl. at 7, ¶29). Plaintiff alleges that Defendants are “sophisticated sellers” who operate on platforms like Temu.com to sell products in wholesale quantities at below-market prices (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart. Instead, it alleges infringement based on a direct visual comparison between Plaintiff's product embodying the patented design and the Defendant's accused product. The legal standard for design patent infringement is 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 alleges that the accused products "closely mimic the invention patented by Plaintiff, including the same overall shape, dimensions, and aesthetic features" (Compl. ¶23). It further alleges that images of the accused products "demonstrate a verbatim reproduction of the specific patented design elements contained in the Asserted Patent" (Compl. ¶27). To support this, the complaint provides a side-by-side visual comparison of an image of "Plaintiff's Genuine Patented Design" and an image of the "Infringing Listing" from the ZestGrove storefront on Temu.com (Compl. at 14, ¶28). This visual evidence shows an accused product that, like the patented design, features a circular base with a symmetrical, dual-hook wire form extending below it.

  • Identified Points of Contention:
    • Visual Similarity: The central question for the court will be whether the accused ZestGrove hooks are "substantially the same" as the design claimed in the ’249 Patent from the perspective of an ordinary observer. The analysis will depend on a comparison of the overall visual effect of the two designs, not on a feature-by-feature dissection.
    • Role of Prior Art: While the complaint does not identify any specific prior art, the scope of a design patent is viewed in the context of what was known at the time. The infringement analysis may raise the question of whether any differences between the patented design and the accused product are significant in light of the relevant prior art for hooks.

V. Other Allegations

  • Indirect Infringement: The complaint does not contain a separate count for indirect infringement. However, the prayer for relief requests an injunction against "inducing others to do the same" and "aiding abetting, contributing to, or otherwise assisting anyone in infringing" the patent (Compl., Prayer ¶1(b)-(c)). The factual basis for these requests is not explicitly developed in the body of the complaint.
  • Willful Infringement: The complaint alleges that Defendants' infringement has been "willful and deliberate" (Compl. ¶55). The asserted basis includes "actual knowledge of Plaintiff's patent rights," "deliberate copying of the patented design's distinctive features," and "attempts to conceal their infringing activities through multiple seller aliases" (Compl. ¶55). The complaint alleges Defendants had constructive notice because Plaintiff's products are marked with the patent number 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 comparison: Will an ordinary observer, giving such attention as a purchaser usually gives, find the overall ornamental design of the accused ZestGrove magnetic hook to be substantially the same as the design claimed in the ’249 Patent, causing the observer to purchase the former thinking it is the latter?
  • A second key question will be one of intent and knowledge: What evidence exists to support the allegation that Defendants had pre-suit knowledge of the ’249 Patent and deliberately copied the patented design, which would be central to the claim for willful infringement and enhanced damages?