Jinlong Holding Trading Co Ltd v. Schedule A

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jinlong Holding Trading Co., Ltd. (China)
  • Defendant: The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule “A,” (Jurisdictions Undisclosed)
  • Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:25-cv-12461, N.D. Ill., 10/11/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants operate interactive e-commerce storefronts that purposefully direct business to Illinois by offering, selling, and shipping accused products to residents within the district.
• Core Dispute: Plaintiff alleges that numerous e-commerce storefront operators infringe a design patent covering the ornamental design of a tripod easel stand.
• Technical Context: The dispute is in the consumer goods sector, specifically art and display equipment sold through major online marketplaces.
• Key Procedural History: The complaint indicates Plaintiff initiated an "anti-infringement program" involving internet sweeps and test purchases prior to filing suit. It does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2024-09-11	'223 Patent Priority Date (Filing)
2025-05-13	'223 Patent Issue Date
2025-10-11	Complaint Filing Date

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

U.S. Design Patent No. D1,074,223 - “Tripod Easel Stand”

• Patent Identification: U.S. Design Patent No. D1,074,223, titled “Tripod Easel Stand,” issued May 13, 2025 (the “’223 Patent”).

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its utilitarian features. The complaint asserts rights in a "new, original, and ornamental design for a tripod easel stand" (Compl. ¶7).
• The Patented Solution: The ’223 Patent claims the specific visual appearance of a tripod easel stand as depicted in its fourteen figures (’223 Patent, Figs. 1-14). The design features three telescoping legs with clasps, a horizontal support tray, and a top clamp assembly, all contributing to a distinct overall visual impression (’223 Patent, Fig. 1). The design also includes an ornamental appearance for the stand in a folded configuration (’223 Patent, Fig. 8).
• Technical Importance: The complaint alleges that the success of Plaintiff's commercial products embodying the patented design has led to significant infringement (Compl. ¶15).

Key Claims at a Glance

• The single claim of the ’223 Patent is for "The ornamental design for a tripod easel stand, as shown and described" (’223 Patent, Claim).
• The essential ornamental features "as shown" in the patent's solid-line drawings include:
  • A three-legged telescoping tripod structure.
  • A horizontal tray for supporting an object.
  • A top spring-loaded clamp assembly.
  • The specific shape and arrangement of the leg clasps, feet, and central hub.
  • The visual appearance of the stand when collapsed.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Unauthorized Products," identified as tripod easel stands sold by the "Schedule A Defendants" through e-commerce storefronts on platforms such as Amazon.com (Compl. ¶1, ¶10).

Functionality and Market Context

The complaint alleges that the accused products are sold on interactive online storefronts accessible to U.S. consumers (Compl. ¶10, ¶17). Plaintiff asserts that these products are "materially indistinguishable from the design claimed in the '223 Patent" (Compl. ¶18). The complaint includes an image of Plaintiff's authorized product, noting that the patent number is included in its online product listings (Compl. ¶9, Figure 1). Another image illustrates an adjustment mechanism on the authorized product, a feature contributing to its overall design (Compl. Figure 3).

IV. Analysis of Infringement Allegations

The complaint references a claim chart attached as Exhibit D, which was not provided with the filed complaint document (Compl. ¶24). The narrative infringement theory is based on the "ordinary observer" test for design patent infringement. Plaintiff alleges that Defendants manufacture, import, offer for sale, and sell products that "embodying the ornamental design claimed" in the '223 Patent (Compl. ¶24). The core of the allegation is that the accused products are "materially indistinguishable" from the patented design, such that they would deceive an ordinary observer (Compl. ¶18). This assertion is supported by Plaintiff's "test purchases" of the accused products (Compl. ¶18).

Identified Points of Contention

• Scope Questions: The primary question will be whether the overall ornamental design of each accused product is "substantially the same" as the design claimed in the ’223 Patent. Any differences in proportion, surface ornamentation, or configuration between the accused products and the patent figures will be central to this analysis.
• Technical Questions: An evidentiary question will be whether the products sold by the numerous, separately-named "Schedule A Defendants" are all identical and whether the products depicted in online listings (referenced in Exhibit B, not provided) are the same as the products received by Plaintiff during its test purchases (referenced in Exhibit C, not provided) (Compl. ¶15, ¶18).

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings, and traditional claim construction of written terms is rare. The analysis focuses on the scope of the claimed design as a whole.

• The Term: "The ornamental design for a tripod easel stand, as shown and described."
• Context and Importance: The scope of the design is the central issue. The analysis will involve comparing the accused products to the overall visual appearance of the design depicted in the patent's drawings, not to any particular feature in isolation. Practitioners may focus on the portions of the design depicted in broken lines.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim covers the overall design, suggesting that minor differences in individual components might not defeat an infringement claim if the overall visual impression is the same.
  • Evidence for a Narrower Interpretation: The patent explicitly disclaims matter shown in broken lines, stating, "The broken lines depict portions of the tripod easel stand that form no part of the claimed design" ('223 Patent, Description). This language definitively limits the scope of the claimed design to only the features shown in solid lines, and any ornamentation related to the disclaimed portions cannot be the basis for an infringement finding.

VI. Other Allegations

Indirect Infringement

The complaint makes a passing reference to products that "directly and/or indirectly infringe," and the prayer for relief requests an injunction against "aiding, abetting, contributing to, or otherwise assisting anyone" in infringement (Compl. ¶25; Prayer for Relief ¶1.b). However, the complaint pleads no specific facts to support the knowledge or intent elements required for claims of induced or contributory infringement. The factual allegations focus on direct infringement by the defendants through their own sales.

Willful Infringement

Plaintiff alleges that Defendants’ infringement was and is "knowingly and willfully" committed (Compl. ¶24, ¶29). The complaint alleges that Plaintiff provides notice of its patent rights by including the patent number in the product title of its own online listings (Compl. ¶9, Figure 1). This fact may be used to argue that Defendants had pre-suit knowledge of the ’223 Patent.

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

1. A core issue will be one of visual comparison: Applying the "ordinary observer" test, is the overall ornamental appearance of the various accused products substantially the same as the design claimed in the ’223 Patent, such that a purchaser would be deceived into believing they were buying the patented product?
2. A key evidentiary question will be one of proof: Can the Plaintiff demonstrate, on a defendant-by-defendant basis, that each of the numerous accused online sellers sold a product that infringes? This will depend on the evidence gathered from the test purchases and the ability to link specific products to specific "Schedule A" storefronts.