Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: HOMEBATTERY and the INDIVIDUALS and ENTITIES OPERATING HOMEBATTERY (People's Republic of China or other foreign jurisdictions)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:25-cv-09844, N.D. Ill., 08/21/2025
• Venue Allegations: Venue is alleged based on Defendants targeting business activities toward U.S. consumers, including residents of Illinois, through interactive e-commerce stores.
• Core Dispute: Plaintiff alleges that Defendants’ e-commerce stores sell battery packs that infringe a U.S. design patent owned by Plaintiff.
• Technical Context: The dispute concerns the ornamental design of battery packs used in consumer electronics, such as cordless vacuum cleaners.
• Key Procedural History: The complaint does not mention any prior litigation, administrative proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Design Patent No. D710,299, “BATTERY PACK,” issued August 5, 2014. (Compl. ¶9; ’D299 Patent, cover).

The Invention Explained

• Problem Addressed: Design patents do not solve technical problems but instead protect the novel, non-obvious, and ornamental appearance of an article of manufacture. The ’D299 Patent seeks to protect a particular aesthetic design for a battery pack.
• The Patented Solution: The patent claims the specific ornamental design for a battery pack as depicted in its seven figures. (’D299 Patent, Claim, Figs. 1-7). Key features of the design include a generally rectangular base with rounded ends, from which a central, multi-faceted tower structure rises to facilitate connection with a device. (’D299 Patent, Fig. 1). The design is defined by the specific proportions, contours, and arrangement of surfaces shown in solid lines in the patent drawings. (’D299 Patent, Description).
• Technical Importance: The complaint alleges that Dyson products are known for their "distinctive patented designs," which consumers associate with quality and innovation. (Compl. ¶8).

Key Claims at a Glance

• Design patents have a single claim, which is directed to the design as a whole. The asserted claim is: "The ornamental design for a battery pack, as shown and described." (’D299 Patent, Claim).
• The essential elements of the claim are the visual characteristics of the battery pack illustrated in solid lines in Figures 1-7 of the patent, including:
  • The overall configuration and shape of the battery pack.
  • The specific contours of the base unit and the centrally-located, raised connection tower.
  • The arrangement and appearance of surface details on the tower and base.

III. The Accused Instrumentality

Product Identification

• The accused products are battery packs referred to as the "Infringing Products." (Compl. ¶3). The complaint states these are shown in Exhibit 1, though the exhibit itself was not included with the provided document. (Compl. ¶3).

Functionality and Market Context

• The accused products are battery packs allegedly sold by Defendants through various e-commerce stores operating under multiple "Seller Aliases" on platforms such as Amazon, eBay, Temu, and Walmart. (Compl. ¶¶11, 12).
• The complaint alleges these e-commerce stores are designed to appear as authorized retailers to "unknowing consumers" and that they target sales to U.S. residents, including those in Illinois. (Compl. ¶¶2, 15).

IV. Analysis of Infringement Allegations

Design patent infringement analysis does not use a traditional claim chart. Instead, infringement is determined by the "ordinary observer" test: whether an ordinary observer, familiar with the prior art designs, would be deceived into believing the accused design is the same as the patented design.

The complaint alleges that Defendants are making, using, selling, or importing "the same unauthorized and unlicensed product... that infringes Dyson's patented design." (Compl. ¶3). The infringement allegation rests on the assertion that the visual appearance of the accused battery packs is substantially the same as the ornamental design claimed in the ’D299 Patent. The complaint includes multiple figures from the patent to illustrate the claimed design, such as the perspective view in Figure 1, which depicts the overall configuration of the battery pack. (Compl. ¶8, p. 4).

Identified Points of Contention

• Visual Similarity: The central question for the court will be whether the overall visual impression of the accused battery packs is substantially the same as the design claimed in the ’D299 Patent. This will require a side-by-side comparison of the products and the patent figures.
• Scope Questions: The analysis may raise questions regarding which specific features of the design are ornamental and protected, versus those that are purely functional and thus not protected by the design patent.

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is defined by the drawings rather than words. The primary focus is on the visual scope of the design as a whole.

• The Term: "The ornamental design for a battery pack, as shown and described."
• Context and Importance: The entire infringement analysis depends on the scope of this "term," which is understood through the patent’s drawings. The key determination is what visual elements are included within the scope of the claimed design.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim covers the overall visual impression created by the combination of all features shown in solid lines, not just isolated details. A court may find infringement even if minor differences exist, so long as the overall aesthetic is the same.
  • Evidence for a Narrower Interpretation: The patent explicitly states, "The broken lines shown in the drawings are included for the purpose of illustrating environmental structure and form no part of the claimed design." (’D299 Patent, Description). This language expressly limits the scope of protection to only the elements depicted in solid lines, excluding any features of an attached device or internal components shown in broken lines.

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation that Defendants' products "infringe directly and/or indirectly" and the prayer for relief seeks to enjoin "aiding, abetting, [or] contributing to" infringement. (Compl. ¶24; p. 13). However, the complaint does not plead specific facts to support a claim for either induced or contributory infringement, such as allegations that Defendants instructed third parties on how to infringe.
• Willful Infringement: The complaint alleges that Defendants have "knowingly and willfully" infringed and that the infringement "was willful." (Compl. ¶¶20, 21). These allegations are based on the assertion that Defendants offered for sale the "same product that infringes... the Dyson Design." (Compl. ¶20). The complaint does not provide specific facts regarding when or how Defendants allegedly became aware of the ’D299 Patent.

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

• A core issue will be one of visual comparison: From the perspective of an ordinary observer, is the overall ornamental appearance of the accused battery packs substantially the same as the design claimed in the ’D299 Patent, or are there sufficient visual differences to distinguish them?
• A key evidentiary question will be one of product identification: Given the allegations that Defendants operate under numerous concealed aliases, Plaintiff will first need to establish that the specific products sourced from the Defendants are, in fact, the products that embody the allegedly infringing design.
• A secondary issue may concern the distinction between ornamental and functional features: The court may need to consider whether Defendants can argue that any similarities between their product and the patented design are dictated by function, which could limit the scope of the ’D299 Patent’s protection.