DCT
1:25-cv-11051
Guangzhou Youlan Technology Co Ltd v. Onbrill World
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangzhou Youlan Technology Co., Ltd. (China)
- Defendant: Onbrill World (and associated Partnerships and Unincorporated Associations)
- Plaintiff’s Counsel: D&A|R.M. DeWitty, U.S. Pat. Atty., LLC
- Case Identification: 1:25-cv-11051, N.D. Ill., 09/12/2025
- Venue Allegations: Venue is based on allegations that Defendant operates interactive commercial internet stores that directly target and sell products to consumers in Illinois.
- Core Dispute: Plaintiff alleges that Defendant’s online storefronts sell outdoor chaise lounges that infringe a U.S. design patent.
- Technical Context: The dispute concerns the ornamental design of outdoor furniture, a consumer product category where visual appearance is a key market differentiator.
- Key Procedural History: The complaint indicates this action is part of a broader strategy to "combat the online sellers who sell the same knock-off product," suggesting an effort to enforce patent rights against diffuse and potentially anonymous online infringers.
Case Timeline
| Date | Event |
|---|---|
| 2023-08-25 | ’331 Patent Priority Date (Application Filing) |
| 2025-05-20 | ’331 Patent Issue Date |
| 2025-09-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D1,075,331 S - "OUTDOOR CHAISE LOUNGE"
The Invention Explained
- Problem Addressed: The complaint asserts that the patented design is notable for creating a "distinctive and aesthetically appealing design that combines portability, comfort, and functionality tailored for outdoor use" (Compl. ¶6).
- The Patented Solution: The patent protects the specific ornamental appearance of an outdoor chaise lounge as depicted in its eight drawing figures (D1,075,331 S, FIGS. 1-8). The design’s visual characteristics include a two-section rectangular body, a visible frame, and a distinct "leg linking mechanism" that creates a particular aesthetic when the lounge is set up (Compl. ¶6; D1,075,331 S, FIG. 1). The claim covers the overall visual impression of the article of manufacture, not its functional attributes.
- Technical Importance: The complaint alleges that the commercial success and appeal of the design are evidenced by the "proliferation of imitation products in the market" (Compl. ¶6).
Key Claims at a Glance
- The complaint asserts the single claim of the patent: "The ornamental design for an outdoor chaise lounge, as shown and described" (D1,075,331 S, Claim 1).
- This claim protects the overall, non-functional, visual appearance of the chaise lounge as illustrated in the patent’s drawings.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "knock-off" outdoor chaise lounge products (Compl. ¶3). Specific examples of the accused products are allegedly shown in Exhibit B to the complaint, which was filed under seal (Compl. ¶10).
Functionality and Market Context
The products are allegedly sold through multiple "fully interactive, commercial Internet stores" operated by the Defendant (Compl. ¶2). The complaint alleges these online stores collectively sell "the same knock-off products" and are designed to conceal the operator's identity while targeting consumers throughout the United States (Compl. ¶4, ¶10).
IV. Analysis of Infringement Allegations
Design patent infringement is determined by the "ordinary observer" test, which assesses whether an ordinary observer would find the patented and accused designs to be substantially the same.
D1,075,331 S Infringement Allegations
| Claim Element (from Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for an outdoor chaise lounge, as shown and described. | Defendant is alleged to offer for sale, sell, and import "knock-off products" that have "copied this leg linking design, and thus the overall design of the claimed design." The complaint includes a perspective view of the patented design, highlighting its overall form and leg structure (Compl. p. 4, image). | ¶6, ¶20 | Claim 1; FIGS. 1-8 |
Identified Points of Contention
- Scope Questions: The central legal question for design patent infringement is the application of the "ordinary observer" test. The dispute will likely focus on whether an ordinary purchaser, familiar with prior art chaise lounges, would be deceived into purchasing Defendant's product believing it to be Plaintiff's patented design.
- Technical Questions: A key evidentiary question will be whether the accused products, which are identified in a sealed exhibit, are visually substantially the same as the design depicted in the figures of the ’331 Patent. Any differences between the designs will be assessed for their impact on the overall visual impression.
V. Key Claim Terms for Construction
Claim construction in design patent cases is atypical, as the claim is defined by the drawings rather than textual limitations. The court's analysis focuses on the visual impression of the design as a whole.
- The Term: "The ornamental design ... as shown and described"
- Context and Importance: The interpretation of this claim, which incorporates the patent's eight figures by reference, defines the scope of protection. The case will hinge on how closely an accused product must resemble the drawings to be considered infringing.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the claim's scope is defined by the overall visual impression and novel configuration of the lounge, particularly the "distinctive" leg structure mentioned in the complaint (Compl. ¶6), and should not be confined to minor, trivial details in the drawings.
- Evidence for a Narrower Interpretation: A defense position may focus on specific, detailed features shown in the drawings, such as the precise shapes of the joints or the exact proportions of the frame elements (D1,075,331 S, FIGS. 1-8), arguing that the claim's scope is limited to this exact depiction and that any noticeable deviation avoids infringement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant sells products that infringe "directly and/or indirectly" (Compl. ¶20). The prayer for relief also seeks to enjoin any "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl., Prayer for Relief ¶1(b)). The alleged factual basis is the operation of online stores that facilitate the sale of infringing products to consumers.
- Willful Infringement: The complaint alleges that Defendant's infringement was "knowing[] and willful[]" (Compl. ¶11, ¶16, ¶17). The basis for this allegation is the assertion that Defendant "copied" the patented design and knowingly marketed and sold "the same knock-off products" through its online stores (Compl. ¶4, ¶6).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual comparison: applying the "ordinary observer" test, is the overall ornamental design of the accused chaise lounges, as sold by Defendant’s online stores, substantially the same as the design claimed in the '331 Patent?
- A key procedural challenge will be one of enforcement against diffuse actors: can Plaintiff successfully establish that the various online storefronts listed in the sealed Schedule A constitute a single, coordinated "Defendant" (Compl. ¶4), and can any resulting injunction effectively halt the alleged infringement by entities that are allegedly designed to be anonymous and transient (Compl. ¶13-15)?