Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: SQTKDS and the Individuals and Entities Operating SQTKDS (People's Republic of China or other foreign jurisdictions)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:25-cv-10060, N.D. Ill., 08/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants target business activities toward U.S. consumers, including those in Illinois, through interactive e-commerce stores.
• Core Dispute: Plaintiff alleges that Defendants’ e-commerce sales of battery packs infringe a design patent covering the ornamental appearance of Plaintiff's battery pack for cordless vacuums.
• Technical Context: The dispute is in the consumer electronics accessories market, where distinctive product design can serve as a significant indicator of source and quality.
• Key Procedural History: The complaint does not reference prior litigation between the parties or administrative challenges to the patent-in-suit. It frames the action as part of a broader effort to combat a network of online sellers who allegedly use aliases to conceal their identities and evade intellectual property enforcement.

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.

U.S. Design Patent No. D710,299 - "BATTERY PACK"

The Invention Explained

• Problem Addressed: The complaint suggests that in the consumer products space, a key challenge is creating a visually distinct product identity that consumers associate with quality and innovation (Compl. ¶5, ¶8). The patent addresses the need for a unique, non-functional, ornamental 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 (D’299 Patent, Figs. 1-7). The design is characterized by the overall visual impression created by its combination of features, including a main rectangular body with rounded edges and an integrated vertical connector element with a distinct shape and surface detailing (D’299 Patent, Fig. 1).
• Technical Importance: The complaint alleges that distinctive product designs, such as the one patented, become "instantly recognizable" and "iconic," serving as a key market differentiator associated with the Dyson brand (Compl. ¶5).

Key Claims at a Glance

• The patent contains a single claim for "the ornamental design for a battery pack, as shown and described" (D’299 Patent, Claim).
• The scope of this claim is defined by the overall visual appearance of the battery pack as illustrated in Figures 1 through 7 of the patent.

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are battery packs, referred to as the "Infringing Products," allegedly sold by Defendants through numerous e-commerce stores operating under various "Seller Aliases" (Compl. ¶3).
• Functionality and Market Context: The accused products are battery packs, presumably for consumer electronics such as cordless vacuums (Compl. ¶5). They are allegedly marketed and sold to U.S. consumers through online marketplace platforms including Amazon, eBay, Temu, and Walmart (Compl. ¶12). The complaint alleges that the Defendants' e-commerce stores are designed to appear as authorized retailers, making it difficult for consumers to distinguish them from legitimate sellers (Compl. ¶15).

IV. Analysis of Infringement Allegations

Design patent infringement is assessed from the perspective of an "ordinary observer." Infringement occurs if the accused design is substantially the same as the patented design, such that an ordinary observer would be deceived into purchasing the accused product believing it was the patented one. The complaint does not provide a side-by-side visual comparison or a detailed breakdown of similarities, which is common at the pleading stage for design patent cases.

The complaint alleges that Defendants are "making, using, offering for sale, selling, and/or importing" products that "infringe directly and/or indirectly the ornamental design claimed in the Dyson Design" (’299 Patent) (Compl. ¶24). To establish the patented design at issue, the complaint reproduces figures from the patent, including a perspective view of the battery pack. The table at paragraph 8 of the complaint reproduces Figure 1 from the patent, establishing the overall ornamental design that is the subject of the infringement claim (Compl. ¶8). The infringement allegation rests on the assertion that the accused products embody this patented design or a colorable imitation of it (Compl. ¶3).

• Identified Points of Contention:
  • Scope Questions: As the complaint does not contain images of the accused products, a central question will be whether the Defendants’ products are, in fact, "substantially the same" in overall visual appearance as the design claimed in the ’299 Patent in the eyes of an ordinary observer.
  • Technical Questions: The dispute will likely depend on a direct visual comparison of the accused products against the seven figures of the ’299 Patent. Any differences in shape, proportion, or surface ornamentation between the accused products and the patent drawings will be critical to the infringement analysis.

V. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of direct "and/or indirectly" infringing conduct (Compl. ¶24), and the prayer for relief requests an injunction against "aiding, abetting, contributing to, or otherwise assisting" infringement (Prayer for Relief ¶1(b)). The factual allegations, however, focus on the Defendants' own alleged acts of making, offering for sale, and selling the accused products (Compl. ¶3, ¶20).
• Willful Infringement: The complaint alleges Defendants' infringement was "willful" (Compl. ¶21). The stated basis for this claim appears to be the allegation that Defendants operate as a coordinated network using aliases and other tactics to conceal their identities, which may suggest an awareness of the infringing nature of their conduct and an intent to evade enforcement (Compl. ¶11, ¶17, ¶19).

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

• A core issue will be one of visual comparison: will an ordinary observer, upon comparing the accused battery packs with the figures of the ’299 Patent, find the two designs to be substantially the same in overall ornamental appearance? The case will turn on the visual evidence presented.
• A significant practical question will be one of enforcement and identity: can the Plaintiff effectively identify, serve, and obtain discovery from the Defendants, who are alleged to operate as a diffuse network of foreign e-commerce entities using multiple aliases to shield their operations from legal action?