Pranash Tianjin Technology Development Co Ltd v. Individuals Corps Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pranash (Tianjin) Technology Development Co., Ltd. (China)
  • Defendant: The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule “A”
  • Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:25-cv-13023, N.D. Ill., 10/24/2025
• Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the infringing activities occurred in the district, many defendants are non-U.S. residents, and defendants have committed acts of infringement in the district, including shipping accused products to Illinois.
• Core Dispute: Plaintiff alleges that numerous online retailers are selling posture correctors that infringe its design patent for a "Posture Support Device."
• Technical Context: The dispute concerns wearable consumer health products, specifically posture-correcting braces, a market segment characterized by high-volume online sales.
• Key Procedural History: The complaint alleges that Plaintiff provides notice of its patent rights by including the patent number in the product descriptions on its own online marketplace listings. This allegation may beused to support claims of pre-suit knowledge for willfulness.

Case Timeline

Date	Event
2020-11-10	’061 Patent Priority Date (Application Filing)
2022-04-05	’061 Patent Issued
2025-10-24	Complaint Filed

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

U.S. Design Patent No. D948,061 - "Posture Support Device"

• Patent Identification: U.S. Design Patent No. D948,061, titled "Posture Support Device", issued on April 5, 2022.

The Invention Explained

• Problem Addressed: The complaint states the patent discloses and claims an ornamental design for "spinal correction straps" intended to address issues like poor posture (Compl. ¶¶ 6-7).
• The Patented Solution: The patent protects the specific ornamental appearance of a posture support device, not its functional aspects (’061 Patent, Claim). The design features straps that go over the shoulders, cross in the back in a distinctive woven or latticed pattern between the shoulder blades, and wrap around the torso (’061 Patent, FIG. 3). The front of the device includes shaped panels below the bust that secure around the midsection (’061 Patent, FIG. 2).
• Technical Importance: The design provides a specific aesthetic for a common wellness product, which can be a key differentiator in a crowded consumer market (Compl. ¶¶ 7-8).

Key Claims at a Glance

• The complaint asserts the single claim of the D948,061 S patent (Compl. ¶¶ 23-24).
• Design patents contain a single claim, which is for the ornamental design as shown in the drawings. The essential visual elements of the claimed design include:
  • The overall configuration of shoulder, back, and torso straps.
  • A prominent, intersecting latticework of straps on the upper back.
  • The specific shape and arrangement of the front panels and straps.
  • The visual relationship between all component parts as depicted in the patent figures.

III. The Accused Instrumentality

Product Identification

The accused products are "spinal adjustment and posture-correcting straps" sold by the defendant entities through online storefronts on platforms including Amazon (Compl. ¶¶ 7, 10-11).

Functionality and Market Context

• The accused products are alleged to be "materially indistinguishable" posture correctors that "embody the ornamental features claimed in the '061 Patent" (Compl. ¶¶ 21, 24).
• The complaint alleges Defendants operate "fully interactive storefronts on major e-commerce platforms," target U.S. consumers, and offer shipment to Illinois (Compl. ¶ 11). It further alleges that similarities across listings in design, advertising, and formatting suggest a "unified commercial approach" or a common source of manufacture (Compl. ¶¶ 11, 15). The complaint includes an online marketplace listing for a posture corrector showing the product on male and female models as representative of the products at issue (Compl. Fig. 1).

IV. Analysis of Infringement Allegations

The complaint references a claim comparison chart (Exhibit C) that was not publicly filed with the initial pleading (Compl. ¶ 24). Therefore, the infringement theory is summarized below in prose.

The core of the infringement allegation is that the accused posture correctors are visually identical or substantially similar to the design claimed in the ’061 Patent. The legal test for design patent infringement is whether an "ordinary observer," familiar with the prior art designs, would be deceived into believing the accused product is the patented design. Plaintiff avers that "the accused products embody the ornamental features claimed in the '061 Patent" and that test purchases confirmed the accused products display these features (Compl. ¶¶ 13, 24). The complaint alleges the defendants sell "materially indistinguishable products" using "substantially similar product designs" (Compl. ¶¶ 11, 21).

• Identified Points of Contention:
  • Scope Questions: The primary dispute will concern the scope of the patented design in light of prior art. The degree of similarity required for an ordinary observer to be deceived will depend on how novel and non-obvious the claimed design is when compared to other posture correctors on the market at the time of invention.
  • Technical Questions: A central factual question will be whether the visual appearance of the defendants' products, taken as a whole, is substantially the same as the specific design shown in the figures of the ’061 Patent. Any perceptible differences in the shape, proportion, or arrangement of the straps and panels between the patented design and the accused products may become focal points of the dispute.

V. Key Claim Terms for Construction

Claim construction for design patents does not focus on interpreting textual terms, but rather on determining the scope of the claimed design as a whole, as depicted in the patent drawings. The analysis is visual and is performed in light of the prior art. Therefore, traditional claim term construction is not applicable. The court's analysis will center on the overall visual impression created by the design, rather than the definition of any particular word.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific factual allegations supporting induced or contributory infringement in its substantive counts, which focus on direct infringement under 35 U.S.C. § 271(a) (Compl. ¶ 23). However, the prayer for relief seeks to enjoin "aiding, abetting, inducing, encouraging, or otherwise facilitating infringement" (Prayer for Relief ¶ 1.b).
• Willful Infringement: The complaint alleges that Defendants’ infringement is willful (Compl. ¶ 27). This allegation is based on "continued infringement, despite the public availability of the '061 Patent and notice provided by this action," suggesting a theory of post-suit willfulness (Compl. ¶ 27). The complaint also asserts that Plaintiff marks its own product listings with the patent number, which may be used to argue that Defendants had pre-suit knowledge of the patent (Compl. ¶ 9). A screenshot of an online product description explicitly listing "US Patent Number: D948061S" is provided as evidence of this practice (Compl. Fig. 4).

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

• A core issue will be one of visual comparison: Will an ordinary observer, taking into account the prior art, find the designs of the numerous accused products to be substantially the same as the specific ornamental design claimed in the ’061 Patent? The outcome will depend on a holistic comparison of the products' aesthetics.
• A key evidentiary question will be the impact of prior art: The scope of protection afforded to the ’061 Patent's design will be defined by its novelty and non-obviousness over earlier posture corrector designs. The prior art landscape will be critical in determining whether subtle differences between the accused products and the patented design are sufficient to avoid infringement.
• A significant procedural hurdle will be one of enforcement: The case targets a large, unidentified group of online sellers listed on a sealed schedule. A primary challenge for the Plaintiff will be effectively identifying, serving, and obtaining discovery from these disparate and potentially anonymous international entities to pursue its claims.