Zhang v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: JJ Zhang (an individual)
  • Defendant: POPFAN MALL and the Individual and/or Entity Operating POPFAN MALL
  • Plaintiff’s Counsel: YK Law LLP
• Case Identification: 1:25-cv-12597, N.D. Ill., 10/30/2025
• Venue Allegations: Venue is alleged to be proper on the basis that Defendant is a foreign entity engaged in infringing activities directed at the U.S., including the Northern District of Illinois.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce sales of ceiling fans infringe a U.S. design patent for an ornamental fan design.
• Technical Context: The dispute is in the home appliance sector, specifically for enclosed ceiling fans where ornamental design is a significant differentiator and driver of consumer purchasing decisions.
• Key Procedural History: This filing is an Amended Complaint. Plaintiff alleges Defendant operates through multiple "Seller Aliases" on e-commerce platforms like Temu, Amazon, and Walmart to conceal its identity and business operations. Plaintiff also alleges its own products sold on Amazon are marked with the patent number.

Case Timeline

Date	Event
2022-09-22	U.S. Patent No. D1,004,815 Priority Date
2023-11-14	U.S. Patent No. D1,004,815 Issued
2025-10-30	Amended Complaint Filed

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

U.S. Patent No. D1,004,815 - "FAN WITH LIGHT"

The Invention Explained

• Problem Addressed: Design patents do not solve a technical problem in the manner of utility patents; rather, they protect a new, original, and ornamental design for an article of manufacture (Compl. ¶6; ’815 Patent, Title). The goal is to provide a unique aesthetic appearance for a product, in this case, a ceiling fan.
• The Patented Solution: The ’815 Patent claims the specific ornamental design for a "fan with light" as depicted in its eight figures (’815 Patent, Claim). The design features a circular, enclosed fan with a cage-like outer structure composed of a repeating crisscross or woven pattern. Inside the cage, a set of angled fan blades surrounds a central lighting element. The overall visual impression, illustrated in the perspective view of FIG. 1, is that of a compact, integrated, and stylized fan and light combination (’815 Patent, FIG. 1).
• Technical Importance: The complaint alleges that the "popularity of the Design Patent has resulted in significant infringement," suggesting the design's aesthetic qualities have achieved recognition and commercial value in the market (Compl. ¶16).

Key Claims at a Glance

• The patent asserts a single claim: "The ornamental design for a fan with light, as shown and described" (’815 Patent, Claim).
• The scope of this claim is defined by the visual representations in the patent's drawings, specifically the elements shown in solid lines.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "Infringing Products," identified as ceiling fans sold by Defendant through e-commerce stores on platforms including Amazon, Walmart, and Temu (Compl. ¶¶1, 16).

Functionality and Market Context

• The complaint alleges these are "unauthorized and unlicensed products" that embody the design protected by the ’815 Patent (Compl. ¶1). The Defendant is alleged to be an e-commerce store operator targeting consumers in the U.S. and using multiple "Seller Aliases" to conduct its business and conceal its identity (Compl. ¶¶1, 11, 16). The complaint does not provide specific model numbers or visual evidence of the accused products. The patent figures, such as FIG. 1, represent the patented design that the accused products are alleged to copy (’815 Patent, FIG. 1; Compl. ¶29).

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed breakdown of infringing features or a claim chart. Instead, its infringement theory relies on the Federal Circuit's "ordinary observer" test for design patent infringement. The complaint alleges that the accused products "resemble Plaintiff's products so closely that they infringe" and that this resemblance is sufficient to deceive an ordinary observer into purchasing the accused product believing it to be the patented one (Compl. ¶¶28-29).

• Identified Points of Contention:
  • Visual Comparison: The central question will be whether the accused product's design and the patented design are "substantially the same" in the eyes of an ordinary observer. This analysis will require a side-by-side comparison of the accused product with the drawings of the ’815 Patent.
  • Scope of Protection: The analysis will also consider the scope of the claimed design in view of any prior art. The overall appearance, rather than minor differences, will be the focus of the inquiry. The court's evaluation may depend on which specific visual features of the design are deemed to create its overall ornamental impression.

V. Key Claim Terms for Construction

In design patent litigation, there are no textual claim terms to construe in the traditional sense. The "claim" is the design itself, as depicted in the drawings. The analysis therefore focuses on the scope of the claimed design as a whole and the visual features that define it.

• The "Term": The overall ornamental design for a "fan with light."
• Context and Importance: Infringement analysis hinges on the overall visual impression created by the design, not on a checklist of features. Practitioners may focus on identifying the prominent visual elements that an ordinary observer would notice and which distinguish the design from the prior art.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The overall visual impression created by the combination of a circular cage with a woven pattern, interior blades, and a central light, as shown in the patent's figures, could support a finding of infringement even if an accused product has minor differences in specific details.
  • Evidence for a Narrower Interpretation: The claim is limited to the specific design "as shown and described" (’815 Patent, Claim). The precise crisscross pattern of the cage, the number and curvature of the fan blades, and the proportions of the components as depicted in the solid lines of the drawings define the boundaries of the claimed design. Further, the patent's description explicitly notes that "The broken lines shown in the drawings...show portions of the fan with light that form no part of the claimed design," which expressly limits the scope of protection to the solid-line features (’815 Patent, Description).

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific factual allegations to support claims of induced or contributory infringement. However, the prayer for relief seeks to enjoin Defendant from "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl., Prayer for Relief ¶1(b)).
• Willful Infringement: The complaint alleges that Defendant has "knowingly, and willfully infringed the Design Patent" (Compl. ¶23). This allegation appears to be based on the assertion that Defendant is part of an "interrelated group of e-commerce sellers" that intentionally uses tactics like seller aliases to evade detection while misappropriating intellectual property (Compl. ¶¶21, 23).

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

• A core issue will be one of visual identity: Applying the "ordinary observer" test, is the overall ornamental design of the accused ceiling fans substantially the same as the design claimed in the ’815 Patent's figures? The outcome will depend on a holistic visual comparison rather than an analysis of discrete features.
• A key evidentiary question will be establishing what product design was actually sold by the Defendant. Given the complaint's lack of visual evidence for the accused product and its allegations of concealed identities and multiple seller aliases, proving that a specific infringing design is attributable to this particular Defendant will be a critical threshold issue.