DCT
1:25-cv-09869
Dongguan Guardian Technology Co Ltd v. Corps Partnerships Unincorp Associations
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Guardian Technology Co., Ltd. (China)
- Defendant: The Corporations, Partnerships, and Unincorporated Associations Identified on Schedule "A" (Jurisdictions Unknown)
- Plaintiff’s Counsel: Valley Summit Law
- Case Identification: 1:25-cv-09869, N.D. Ill., 09/04/2025
- Venue Allegations: Venue is based on allegations that Defendants operate interactive e-commerce stores that target and make sales to consumers in Illinois.
- Core Dispute: Plaintiff alleges that Defendants’ e-commerce stores are manufacturing, offering for sale, and selling unauthorized watch cases that infringe Plaintiff's registered design patent.
- Technical Context: The dispute concerns the ornamental design of protective cases for smartwatches, a large and competitive segment of the consumer electronics accessory market.
- Key Procedural History: The complaint is brought against a group of unidentified defendants, listed on a sealed "Schedule A," who allegedly operate online stores under various aliases. This procedural posture is common in actions targeting online sellers of allegedly counterfeit or infringing goods, where plaintiffs seek to overcome defendants' use of anonymity to evade enforcement.
Case Timeline
| Date | Event |
|---|---|
| 2022-01-25 | ’391 Patent Filing Date |
| 2023-10-24 | ’391 Patent Issue Date |
| 2025-09-04 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,002,391 - "Watch Case"
The Invention Explained
- Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture, not a technical problem. The implicit goal is to create a protective watch case with a unique and aesthetically pleasing appearance that distinguishes it from other products in the market (Compl. ¶13).
- The Patented Solution: The patent discloses a specific ornamental design for a watch case. Key visual features depicted in the figures include a generally rectangular frame with rounded corners, beveled edges, and an asymmetrical profile on one side that accommodates cutouts for a watch's crown and button controls (’391 Patent, FIGS. 1, 3, 5). The design creates a distinct visual impression through its particular combination of curves, cutouts, and overall form (’391 Patent, FIGS. 1-8).
- Technical Importance: In the market for consumer electronics accessories, a distinctive ornamental design can be a significant driver of consumer choice and brand identity (Compl. ¶14).
Key Claims at a Glance
- The complaint asserts the single claim of the patent (Compl. ¶33).
- The claim is for: "The ornamental design for a watch case, as shown and described" (’391 Patent, Claim). The scope of this claim is defined by the visual appearance of the watch case as illustrated in the patent's eight figures.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "unauthorized and unlicensed products," specifically watch cases that allegedly look "almost identical to the products sold by Plaintiff" (Compl. ¶1). The complaint refers to these as "Counterfeit Products" (Compl. ¶11).
Functionality and Market Context
- The complaint alleges that the accused products are "similar and substandard copies" of Plaintiff's commercial products that embody the patented design (Compl. ¶11). These products are allegedly marketed and sold to U.S. consumers, including those in Illinois, through various e-commerce stores operated by the unidentified Defendants under aliases on third-party platforms (Compl. ¶6, ¶10, ¶17).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The legal standard for design patent infringement is 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 one. The complaint's allegations are based on the visual similarity of the accused products to the patented design.
D1,002,391 Infringement Allegations
| Claim Element (from Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a watch case, as shown and described. | The accused watch cases are alleged to be "almost identical" to Plaintiff's products embodying the patented design and to infringe the ornamental design claimed in the patent. | ¶1, ¶33 | ’391 Patent, FIGS. 1-8 |
- Identified Points of Contention:
- Visual Comparison: The central question will be a direct visual comparison between the design shown in the ’391 Patent and the accused products (which are identified in the sealed Exhibit 2). The dispute will hinge on whether the accused designs are "substantially the same" as the patented design from the perspective of an ordinary observer.
- Scope Questions: A potential issue is whether certain visual features of the patented design are primarily functional rather than ornamental. A court would filter out any such functional elements from the infringement analysis, which could narrow the scope of the protected design and impact the outcome of the ordinary observer test. For example, the necessity of cutouts for watch controls may be raised as a functional constraint.
V. Key Claim Terms for Construction
In a design patent case, the "claim construction" process focuses on the overall visual impression of the design as a whole, rather than on specific text.
- The Term: "The ornamental design for a watch case, as shown and described."
- Context and Importance: The scope of the patented design is the central issue. The court's interpretation of what constitutes the "ornamental design" will define the boundaries for the infringement analysis. Practitioners may focus on this "term" because separating the claimed ornamental features from any un-claimed functional aspects is critical to applying the ordinary observer test correctly.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the claim covers the overall visual impression created by the combination of all features shown in solid lines in the drawings, and that minor differences in the accused products do not alter this overall impression (’391 Patent, FIGS. 1-8).
- Evidence for a Narrower Interpretation: Defendants may argue that the scope of protection is limited to the exact design depicted, including its specific proportions and contours. They may also contend that elements essential to the watch case's function—such as the general shape required to fit the watch and the placement of cutouts for buttons—are not part of the protected "ornamental" design and should be disregarded in the infringement analysis.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing reference to indirect infringement ("infringed directly and/or indirectly") but does not plead specific facts to support a claim for either induced or contributory infringement (Compl. ¶33). The allegations focus on Defendants' direct infringement through their own offers for sale and sales.
- Willful Infringement: The complaint alleges that Defendants' infringement was willful and deliberate (Compl. ¶35). It supports this by pleading that Defendants had "full knowledge of Plaintiff's ownership of the Asserted Patent" and that the infringement was "obvious, notorious, purposeful, and in disregard of" Plaintiff's rights (Compl. ¶16, ¶35).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual identity: Once the accused products are produced in discovery, will an ordinary observer, giving such attention as a purchaser usually gives, find their design to be substantially the same as the ornamental design claimed in the ’391 Patent, such that the observer would be induced to purchase one supposing it to be the other?
- A key legal question will be one of functionality: To what extent are the visual similarities between the patented design and the accused products dictated by the functional requirements of a watch case? The court's determination of which design elements are ornamental versus functional will be critical in defining the scope of the patent for the infringement analysis.