Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule “A” (Jurisdictions Unknown, Allegedly China or other foreign jurisdictions)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:25-cv-14683, N.D. Ill., 12/03/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants target business activities and sales to consumers in Illinois through interactive e-commerce stores.
• Core Dispute: Plaintiff alleges that Defendants’ e-commerce stores sell hair dryers that infringe a Dyson design patent.
• Technical Context: The dispute is in the high-end consumer appliance market, where distinctive product design is a significant driver of brand recognition and commercial value.
• Key Procedural History: The complaint is filed against a list of unidentified partnerships and associations, alleging they operate under various seller aliases to conceal their identities and sell infringing goods online. No prior litigation or administrative proceedings are mentioned.

Case Timeline

Date	Event
2013-09-26	D'996 Patent Priority Date
2014-10-21	U.S. Patent No. D715,996 Issued
2025-12-03	Complaint Filed

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

U.S. Patent No. D715,996 - "Hair Dryer"

• Patent Identification: U.S. Patent No. D715,996, “Hair Dryer,” issued October 21, 2014 (the “D’996 Patent”).

The Invention Explained

• Problem Addressed: Design patents do not solve a technical problem but rather protect the novel, non-obvious, and ornamental appearance of a manufactured article. The D’996 Patent protects a specific ornamental design for a hair dryer.
• The Patented Solution: The patent claims the ornamental design for a hair dryer as depicted in its figures (D’996 Patent, Figs. 1-7). Key visual features of the design include a hollow, cylindrical head positioned perpendicularly atop a straight, cylindrical handle, creating a distinctive T-shape. The design features a prominent circular aperture at the front of the head and a textured band at the base of the handle (D’996 Patent, Figs. 2, 4). The complaint alleges that Dyson products are known for their “unique and innovative design” (Compl. ¶5).
• Design Importance: The complaint asserts that these distinctive designs are broadly recognized by consumers and are associated with the quality and innovation expected from the Dyson brand (Compl. ¶8).

Key Claims at a Glance

• The D’996 Patent contains a single claim: "The ornamental design for a hair dryer, as shown and described" (D’996 Patent, Claim).
• The scope of a design patent claim is defined by the solid lines in the patent drawings. The essential visual elements of the claimed design include:
  • The overall T-shaped configuration of the head and handle.
  • The specific proportions of the cylindrical head relative to the cylindrical handle.
  • The appearance of the front and rear circular openings on the head.
  • The visual effect of the textured surface at the bottom of the handle.

III. The Accused Instrumentality

Product Identification

• The accused products are hair dryers, referred to as the “Infringing Products,” which are allegedly unauthorized and unlicensed (Compl. ¶3). The complaint states these products are shown in its Exhibit 1, which was not included in the provided filing (Compl. ¶3).

Functionality and Market Context

• The complaint alleges Defendants operate numerous interactive e-commerce stores under various "Seller Aliases" on platforms like Alibaba and Walmart to sell the Infringing Products to U.S. consumers (Compl. ¶12).
• The complaint further alleges that these e-commerce stores are designed to appear as authorized retailers to unknowing consumers and that Defendants use tactics like operating multiple aliases to conceal their identities and evade enforcement (Compl. ¶¶11, 15, 17).

IV. Analysis of Infringement Allegations

Design patent infringement analysis is governed by the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that the Infringing Products directly and/or indirectly infringe the ornamental design claimed in the D’996 Patent (Compl. ¶25). As the complaint does not contain a traditional claim chart, the following table summarizes the alleged correspondence between the patented design's features and the accused products. The complaint contains several images from the D’996 patent, such as the one labeled Figure 1, which shows a rear perspective view of the hair dryer design (Compl. p. 4).

D'996 Patent Infringement Allegations

Ornamental Feature (from D'996 Patent)	Alleged Infringing Feature	Complaint Citation	Patent Citation
The overall ornamental appearance of the hair dryer design	The complaint alleges the "Infringing Products" feature Dyson's patented design, creating a product that infringes directly and/or indirectly.	¶¶3, 25	Figs. 1-7
The T-shaped configuration comprising a cylindrical head atop a cylindrical handle	The Infringing Products are alleged to be the "same unauthorized and unlicensed product" shown in Exhibit 1 which infringes the patented design.	¶3	Figs. 1-2, 5
The hollow, ring-like appearance of the head with front and rear apertures	The complaint alleges Defendants are selling products that infringe the "ornamental design claimed in the Dyson Design."	¶25	Figs. 3-4
The specific proportions and smooth surfaces of the head and handle	The complaint alleges that the Infringing Products embody the patented design, which is depicted with specific proportions.	¶¶8, 25	Figs. 1-7

• Identified Points of Contention:
  • Visual Similarity: The central question for the court will be whether the accused products are "substantially the same" as the patented design from the perspective of an ordinary observer. The analysis will depend on a side-by-side visual comparison of the accused products (once identified) and the D’996 Patent figures.
  • Identification of Products and Defendants: A primary procedural hurdle suggested by the complaint is the identification of the specific accused products and the anonymous Defendants. The complaint alleges Defendants use concealment tactics, which may create an evidentiary challenge in linking specific sales to specific infringing articles and responsible parties (Compl. ¶¶11, 17).

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings, and traditional claim term construction is generally not the central issue. The analysis focuses on the overall visual appearance of the claimed design rather than the interpretation of specific text. The scope of the D'996 Patent's claim is defined by the visual features shown in solid lines in Figures 1-7. Therefore, the dispute is unlikely to turn on the construction of any particular term.

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation that Defendants' products infringe "directly and/or indirectly" (Compl. ¶25). The prayer for relief also seeks to enjoin "aiding, abetting, contributing to, or otherwise assisting anyone in making, using, offering for sale, selling, and/or importing" the Infringing Products (Prayer for Relief ¶1(b)). The factual basis for indirect infringement appears to rest on the collective operation of online stores by the defendant entities (Compl. ¶18).
• Willful Infringement: Plaintiff alleges that Defendants' infringement was willful (Compl. ¶22). The complaint supports this by alleging Defendants are "working to knowingly and willfully import, distribute, offer for sale, and sell Infringing Products" without authorization from Dyson (Compl. ¶21).

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

• A core issue will be one of visual comparison: in the eyes of an ordinary observer, is the overall ornamental design of the accused hair dryers substantially the same as the design claimed in the D'996 Patent? The outcome will depend entirely on the visual evidence presented at trial.
• A key procedural and evidentiary question will be the identification of the defendants and their products. Can the Plaintiff successfully pierce the alleged anonymity of the e-commerce operators listed in Schedule A and tie them to the manufacture, importation, or sale of specific, identified products that infringe the D'996 Patent?