1:25-cv-10148
Dyson Technology Ltd v. Partnerships Unincorp Associations
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dyson Technology Limited (United Kingdom)
- Defendant: YFHLSEVEN and the Individuals and Entities Operating YFHLSEVEN (Jurisdiction(s) Unknown)
- Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
- Case Identification: 1:25-cv-10148, N.D. Ill., 08/26/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants target business activities toward consumers in the United States, including Illinois, through interactive e-commerce stores and have allegedly sold products to Illinois residents.
- Core Dispute: Plaintiff alleges that Defendants’ e-commerce stores sell battery packs that infringe a design patent covering the ornamental appearance of a Dyson battery pack.
- Technical Context: The dispute is in the field of consumer electronics accessories, where distinctive product design and appearance can be a significant source of brand identity and market value.
- Key Procedural History: The complaint frames the defendants as a network of online sellers operating under various aliases to conceal their identities and evade enforcement, a common fact pattern in cases filed against unidentified "Schedule A" e-commerce operators. No prior litigation or administrative patent challenges are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2013-02-18 | ’299 Patent - Priority Date |
| 2014-08-05 | ’299 Patent - Issue Date |
| 2025-08-26 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D710,299 - Battery pack
- Patent Identification: U.S. Design Patent No. D710,299, titled “Battery pack,” issued August 5, 2014 (the “’299 Patent”).
The Invention Explained
- Problem Addressed: Design patents do not solve a functional problem but instead protect the novel, non-obvious, and ornamental appearance of an article of manufacture. The goal is to create a visually distinct and aesthetically pleasing product design that can be protected from imitation (’299 Patent, CLAIM).
- The Patented Solution: The ’299 Patent claims the specific ornamental design for a battery pack as depicted in its seven figures (’299 Patent, FIGS. 1-7). The design consists of a lower, elongated rectangular base with rounded ends, and an upper, centrally-located structure with more complex geometry that appears to serve as a connection or mounting point. Key visual features include the specific proportions, contours, and surface details shown in solid lines throughout the various perspective, side, top, and bottom views (’299 Patent, DESCRIPTION).
- Technical Importance: In the consumer products sector, a unique ornamental design can serve as a strong brand identifier, making products instantly recognizable to consumers and distinguishing them from competitors (Compl. ¶5, ¶8).
Key Claims at a Glance
- Design patents have a single claim, which is for the design as shown in the drawings. The ’299 Patent claims "the ornamental design for a battery pack, as shown and described" (’299 Patent, CLAIM).
- The "elements" of this claim are the visual features of the article as depicted in solid lines in the patent's figures. The complaint reproduces several of these figures (Compl. pp. 4-7).
III. The Accused Instrumentality
Product Identification
The accused products are battery packs, referred to as the "Infringing Products," sold by Defendants through various e-commerce stores operating under the "Seller Aliases" (Compl. ¶3, ¶12). The complaint states that the accused product is shown in its Exhibit 1, though this exhibit was not attached to the filed complaint document (Compl. ¶3).
Functionality and Market Context
The complaint alleges that Defendants operate numerous e-commerce stores on platforms such as Amazon, eBay, Temu, and Walmart to offer for sale and sell the Infringing Products to consumers in the United States, including Illinois (Compl. ¶12, ¶14). The complaint further alleges that these stores are designed to appear as if they are authorized retailers, using content and images that make it difficult for consumers to distinguish them from legitimate channels (Compl. ¶15).
IV. Analysis of Infringement Allegations
The complaint alleges that the Defendants’ battery packs infringe the ornamental design claimed in the ’299 Patent (Compl. ¶24). The legal test for design patent infringement is whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design.
Because the complaint asserts a design patent, a traditional element-by-element claim chart is not applicable. The core of the infringement allegation is a comparison of the overall visual appearance. The complaint asserts that Defendants are "making, using, offering for sale, selling, and/or importing" products that "infringe directly and/or indirectly the ornamental design claimed" (Compl. ¶24). To illustrate the patented design, the complaint includes a table reproducing Figure 1 of the ’299 Patent, which provides a perspective view of the claimed battery pack design (Compl. p. 4, FIG. 1). However, the complaint does not provide any images of the accused products for a side-by-side comparison, instead referencing a missing exhibit (Compl. ¶3).
Identified Points of Contention
- Visual Similarity: The central question will be whether the overall visual impression of the accused products is substantially the same as that of the ’299 Patent's drawings. This will require a visual comparison focusing on the claimed ornamental features.
- Evidentiary Questions: A threshold issue for the court will be establishing what the accused products look like. The infringement analysis will depend entirely on the evidence presented showing the specific design of the products sold by the Defendants.
V. Key Claim Terms for Construction
Claim construction is generally not a central issue in design patent litigation, as the single claim consists of the drawings themselves rather than textual limitations. The scope of the claim is defined by the visual appearance of the design as shown in the patent's figures.
VI. Other Allegations
Indirect Infringement
The complaint makes a conclusory allegation of indirect infringement (Compl. ¶24) and requests an injunction against "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing (Compl. p. 13). However, the complaint does not plead specific facts to support the knowledge and intent elements required for a claim of induced or contributory infringement, focusing instead on the Defendants' own direct sales activities.
Willful Infringement
The complaint alleges that Defendants' infringement was willful (Compl. ¶21). The basis for this allegation is the assertion that Defendants are "working to knowingly and willfully import, distribute, offer for sale, and sell Infringing Products" (Compl. ¶20).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual comparison: Does the overall ornamental design of the accused battery packs create a visual impression that is substantially the same as the design claimed in the ’299 Patent in the eyes of an ordinary observer? The outcome will depend entirely on a visual assessment of the accused products once evidence of their appearance is presented.
- A key procedural question will be one of enforcement and identity: Given that the defendants are alleged to be a network of unknown e-commerce operators using multiple aliases, a significant practical challenge for the plaintiff will be successfully identifying the responsible parties, establishing personal jurisdiction, and enforcing any judgment that may be obtained.