DCT
1:25-cv-14874
Chen v. Ukeetap Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Xu'e Chen (China)
- Defendant: Ukeetap Limited (Foreign)
- Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
- Case Identification: Chen v. Ukeetap Limited, 1:25-cv-14874, N.D. Ill., 12/15/2025
- Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign party who may be sued in any judicial district and because a substantial part of the events, including targeted sales and shipment of accused products to consumers in Illinois, occurred in the district.
- Core Dispute: Plaintiff alleges that Defendant’s meat grinder product, sold online, infringes a U.S. design patent covering the ornamental appearance of a meat grinder.
- Technical Context: The dispute concerns the ornamental design of a consumer kitchen utensil, a product category where visual appearance can be a significant driver of consumer choice in a competitive online marketplace.
- Key Procedural History: The complaint does not reference prior litigation or administrative proceedings. It does allege that Plaintiff provides notice of its patent rights by marking its product packaging and that it identified the accused product through an internal anti-infringement program that included conducting test purchases.
Case Timeline
| Date | Event |
|---|---|
| 2023-06-15 | Priority Date for U.S. Patent No. D1,081,246 |
| 2025-07-01 | U.S. Patent No. D1,081,246 Issues |
| 2025-12-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,081,246 - "Meat Grinder"
- Patent Identification: U.S. Design Patent No. D1,081,246, "Meat Grinder," issued July 1, 2025.
The Invention Explained
- Problem Addressed: Design patents protect the novel ornamental appearance of an article of manufacture rather than a functional solution to a technical problem. The patent protects a new, original, and ornamental design for a meat grinder (Compl. ¶7).
- The Patented Solution: The patent claims the specific visual appearance of a meat grinder as depicted in its figures (’246 Patent, Claim). The design consists of a circular base and a transparent or translucent lid, both featuring arrays of interlocking pyramidal teeth. Key ornamental features include the arrangement of these teeth in concentric circles, the shape of the two integrated handles on the lid, and the overall profile and proportions of the device when assembled (’246 Patent, Figs. 1, 7, 12). The design creates a distinct visual impression through the combination of these elements.
- Technical Importance: In the market for consumer kitchen goods, a unique and recognizable ornamental design can serve as a key product differentiator and source of brand identity (Compl. ¶8).
Key Claims at a Glance
- The patent asserts a single claim: "The ornamental design for a meat grinder as shown and described."
- The essential visual elements of this design claim include:
- A circular body with a base and a corresponding lid.
- Two opposing, outwardly extending handles integrated into the lid.
- A series of sharp, tooth-like protrusions arranged in concentric circles on both the interior of the lid and the top surface of the base.
- The specific pyramidal shape and spacing of the individual protrusions.
III. The Accused Instrumentality
Product Identification
The "Accused Product" is a meat grinder marketed and sold by Defendant through an Amazon storefront operating under the seller name "UKEETAP LIMITED" (Compl. ¶11, 15).
Functionality and Market Context
- The complaint alleges the Accused Product is "materially indistinguishable" in appearance from the design claimed in the ’246 Patent (Compl. ¶19, 23). The complaint includes images of Plaintiff’s product, which embodies the patented design, showing a two-part device with a clear lid and a black base used for shredding meat (Compl. p. 3, Figs. 1-3).
- The complaint alleges that Defendant targets U.S. consumers, including those in Illinois, through its online storefront, which accepts U.S. currency and ships to the United States (Compl. ¶13-14, 18). Plaintiff alleges that Defendant’s infringing sales are substantial, with analytics tools estimating sales of approximately $800,000 in a single month, and that these sales have directly correlated with a significant decline in sales of Plaintiff's own patented product (Compl. ¶24).
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Product infringes by incorporating an ornamental design that is "materially indistinguishable" from the one claimed in the ’246 Patent (Compl. ¶27). The legal test for design patent infringement is whether an "ordinary observer," giving the matter the attention a typical purchaser would, would find the two designs substantially the same. The complaint provides side-by-side comparisons in its Exhibit D to support this allegation (Compl. ¶27).
’246 Patent Infringement Allegations
| Key Ornamental Feature (from Figures) | Alleged Infringing Feature | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall visual appearance of the meat grinder | The Accused Product's "overall visual appearance and key ornamental features" are alleged to be "materially indistinguishable" from the patented design. | ¶27 | ’246 Patent, col. 2:30-32 |
| A circular body with a base and a corresponding lid featuring integrated handles | The Accused Product is alleged to have the same overall configuration, as shown in side-by-side comparisons. | ¶27, Ex. D | ’246 Patent, col. 2:33-34 |
| An array of tooth-like protrusions on the interior surfaces | The Accused Product is alleged to incorporate a visually identical array of protrusions. | ¶27, Ex. D | ’246 Patent, col. 2:42-45 |
Identified Points of Contention
- Scope Questions: The primary question in a design patent case is the scope of the claimed design in the eyes of an ordinary observer. The dispute will center on whether the Accused Product is close enough in appearance to the design shown in the ’246 Patent's figures to cause an ordinary observer to purchase it believing it to be the patented product.
- Technical Questions: While the case is about ornamentality, the factual analysis will involve a detailed visual comparison of the products. A key question for the fact-finder will be: Are there any differences between the patented design and the accused product, and if so, are they significant enough to alter the overall visual impression, or are they minor variations that an ordinary observer would overlook? The complaint’s allegation that the products are "materially indistinguishable" suggests Plaintiff's position is that any differences are trivial (Compl. ¶23).
V. Key Claim Terms for Construction
In design patent litigation, the figures themselves largely define the claim scope, making traditional claim construction less central than in utility patent cases. However, the patent's title can be relevant.
- The Term: "Meat Grinder"
- Context and Importance: The title of the patent, "Meat Grinder," defines the article of manufacture to which the ornamental design is applied. This sets the context for the "ordinary observer" and limits the scope of the patent right to designs applied to this type of product. The construction of this term is unlikely to be contentious, as both the patented design and the accused product are used and marketed as meat grinders or shredders.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The parties are unlikely to dispute that the term encompasses kitchen utensils for shredding or grinding meat. The patent's classification codes also place it within the field of domestic kitchen equipment ('246 Patent, (52) U.S. Cl.).
- Evidence for a Narrower Interpretation: The figures themselves provide the most definitive evidence, showing a specific type of manually operated meat shredder/grinder (’246 Patent, Figs. 1-12).
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of indirect infringement and requests an injunction against aiding and abetting (Compl. ¶28; Prayer for Relief ¶1(b)). However, the body of the complaint does not plead specific facts to support the elements of knowledge and intent required for a claim of induced infringement.
- Willful Infringement: Plaintiff avers that Defendant's infringement "has been, and continues to be, willful" (Compl. ¶31). The complaint does not specify whether this allegation is based on pre- or post-suit knowledge. It does allege that Plaintiff marks its product packaging with the patent number, which could potentially serve as a basis for pre-suit notice if evidence shows Defendant was aware of it (Compl. ¶10).
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents a focused design patent dispute in the e-commerce context. The outcome will likely depend on the answers to two primary questions:
- A core issue will be one of visual identity: Will a fact-finder, acting as an ordinary observer, conclude that the overall ornamental design of the Defendant’s accused product is substantially the same as the design claimed in the ’246 Patent? The case will turn on a direct visual comparison, as referenced in the complaint's Exhibit D.
- A key evidentiary question will be one of commercial harm: Assuming infringement is found, what is the appropriate measure of damages? The analysis will likely focus on quantifying Defendant’s profits from the infringing sales, particularly given Plaintiff’s allegation that Defendant’s online sales are substantial and have directly caused a decline in its own market share.