DCT

1:25-cv-14027

Netvue Tech Co Ltd v. Nafnti Official

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-14027, N.D. Ill., 11/14/2025
  • Venue Allegations: Plaintiff alleges venue is proper because the defendants are foreign entities not resident in the United States and may therefore be sued in any judicial district. The complaint also alleges defendants target sales to consumers in Illinois through interactive commercial websites on Amazon.com.
  • Core Dispute: Plaintiff alleges that smart bird feeders sold by Defendants on Amazon.com infringe a U.S. reissue design patent covering the ornamental design of a "Combined Bird Feeder with Camera."
  • Technical Context: The dispute is in the consumer electronics and smart home market, specifically concerning devices that integrate wildlife observation (bird feeding) with camera technology for remote viewing.
  • Key Procedural History: The patent-in-suit is a reissue of U.S. Design Patent No. D983,859. Reissue proceedings can be used to correct errors in an original patent, which may be relevant to the scope and enforceability of the asserted claim.

Case Timeline

Date Event
2022-05-18 Earliest Patent Priority Date
2023-04-18 Original U.S. Design Patent D983,859 Issued
2025-09-30 Reissue Patent RE50,605 Issued
2025-11-14 Complaint Filed

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

U.S. Reissue Design Patent No. RE50,605 - “Combined Bird Feeder with Camera”

  • Patent Identification: U.S. Reissue Design Patent No. RE50,605, “Combined Bird Feeder with Camera,” issued September 30, 2025 (’605 Patent).

The Invention Explained

  • Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its functional utility. The ’605 Patent does not describe a technical problem but instead claims a specific aesthetic design for a bird feeder that incorporates a camera.
  • The Patented Solution: The patent claims the ornamental design for the article as depicted in its figures (’605 Patent, Claim). The claimed design features a combination of elements including a conical, radially-slatted roof; a main cylindrical body that houses a camera module; a forward-projecting perch; and a seed tray integrated into the base (’605 Patent, FIG. 1, FIG. 3, FIG. 5). The overall visual impression is created by the specific proportions, shapes, and arrangement of these components.

Key Claims at a Glance

  • The ’605 Patent asserts a single claim: "The ornamental design for a combined bird feeder with camera, as shown and described." (’605 Patent, Claim).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Infringing Products" as bird feeders with cameras sold by Defendants on Amazon.com under various Amazon Standard Identification Numbers (ASINs), including B0FSPMHWTX and B0DTKDYJ8J, among others (Compl. ¶22).

Functionality and Market Context

The complaint alleges the accused products are bird feeders integrated with cameras, sold through commercial storefronts on Amazon.com (Compl. ¶¶21-22). The products are alleged to be "the same or substantially identical" across the different defendant storefronts (Compl. ¶5). A representative image of an accused product shows a bird feeder with a conical roof, a central body housing a camera, and a perch with a seed tray, designed to attract and allow for observation of birds (Compl. p. 6).

IV. Analysis of Infringement Allegations

The complaint references an "Exemplary Claim Chart" in its Exhibit 3, which was not provided with the filed complaint (Compl. ¶28). The infringement allegation is therefore based on the narrative theory presented in the complaint.

The central allegation is that the design of the Infringing Products is "substantially similar to the claimed design of the '605 Patent to the eye of an ordinary observer" (Compl. ¶29). This language directly invokes the legal standard for design patent infringement established in Egyptian Goddess, Inc. v. Swisa, Inc. The complaint supports this by presenting images of the patented design and an accused product, inviting a visual comparison (Compl. pp. 5-6). For example, the image of an accused product on page 6 of the complaint depicts a smart bird feeder with a camera that a fact-finder could compare to the patented design shown in Figure 1 on page 5 (Compl. p. 5, p. 6).

  • Identified Points of Contention:
    • Scope Questions: The primary question in a design patent case is whether the accused design and the patented design are substantially similar in their overall appearance, such that an ordinary observer would be deceived. The dispute will focus on a side-by-side comparison of the products' overall visual impression, rather than on the construction of written claim terms.
    • Technical Questions: The analysis will raise the question of whether alleged similarities in the conical roof, camera placement, perch design, and overall proportions between the accused products and the patented drawings are significant enough to create a virtually identical visual impression, and conversely, whether any visual differences are minor enough to be overlooked by the ordinary observer.

V. Other Allegations

  • Indirect Infringement: The complaint does not contain specific factual allegations to support claims for induced or contributory infringement. It focuses on direct infringement by Defendants for offering to sell, selling, and importing the accused products (Compl. ¶28). The prayer for relief includes a request to enjoin "aiding, abetting, [or] contributing to" infringement, which is standard language but is not supported by a separate count for indirect infringement (Compl. p. 8).
  • Willful Infringement: The complaint alleges that Defendants' infringement is willful "at least as of the filing of this...complaint, if not earlier" (Compl. ¶25). This pleading suggests that, at a minimum, Defendants have been on notice of the patent since the lawsuit was filed, potentially exposing them to enhanced damages for any post-filing infringement.

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

The resolution of this case will likely depend on the answers to two central questions:

  1. A core issue will be one of visual comparison: Applying the "ordinary observer" test, is the overall ornamental appearance of the Defendants' bird feeders substantially the same as the specific design claimed in the drawings of the ’605 Patent? The outcome will depend on the trier of fact's perception of similarity, considering the design as a whole.
  2. A key evidentiary question will be one of distinction: What, if any, visual differences exist between the accused products and the patented design, and are those differences sufficient to inform an ordinary observer that the accused product is not the patented design, particularly in light of any prior art that may be introduced during the case?