DCT
1:25-cv-15023
Dongguan Lianguang Electronics Technology Co Ltd v. Entities Partnerships Unincorp Associations
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Lianguang Electronics Technology Co., Ltd. (China)
- Defendant: The Entities, Partnerships and Unincorporated Associations Identified on Schedule A (Various)
- Plaintiff’s Counsel: Pattishall, McAuliffe, Newbury, Hilliard & Geraldson LLP
- Case Identification: 1:25-cv-15023, N.D. Ill., 12/10/2025
- Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the events giving rise to the claims occurred in the district, and Defendants target consumers in the district through online stores.
- Core Dispute: Plaintiff alleges that rechargeable batteries sold by numerous online entities under the PUJIMAX brand infringe two U.S. design patents covering the ornamental appearance of a battery.
- Technical Context: The dispute is in the consumer electronics sector, focusing on the proprietary ornamental design of rechargeable batteries sold on major e-commerce platforms.
- Key Procedural History: The complaint does not mention prior litigation or administrative proceedings involving the patents-in-suit. The defendants are identified as a group of online sellers on a sealed "Schedule A," a common strategy in cases targeting numerous, pseudonymous e-commerce entities.
Case Timeline
| Date | Event |
|---|---|
| 2021-04-01 | Priority Date for U.S. Design Patent Nos. D965,512 and D965,513 |
| 2022-10-04 | Issue Date for U.S. Design Patent Nos. D965,512 and D965,513 |
| During 2023 | Plaintiff allegedly begins selling products embodying the patented designs |
| 2025-12-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D965,512 - "Battery," issued October 4, 2022
The Invention Explained
- Problem Addressed: Design patents do not solve technical problems; they protect novel, non-obvious ornamental designs for articles of manufacture. This patent claims a new ornamental design for a battery.
- The Patented Solution: The patent claims the specific visual appearance of a battery. The design consists of a generally cylindrical body with a distinctive top cap assembly. Key claimed features include the overall proportions of the battery, the configuration of the raised positive terminal, and a recessed, elongated notch on the side of the top cap assembly, as depicted in the patent’s figures (’512 Patent, FIG. 7). The complaint alleges this design is innovative and has achieved commercial success (Compl. ¶20).
- Technical Importance: The design provides a unique visual identity intended to distinguish the plaintiff's products in a competitive market for consumer batteries (Compl. ¶2, ¶24).
Key Claims at a Glance
- Design patents contain a single claim. The asserted claim is for "The ornamental design for a battery, as shown and described" (’512 Patent, Claim).
- The claimed design is defined by the visual features depicted in the patent's seven drawing sheets, including:
- A main cylindrical body.
- A top cap assembly featuring a raised positive terminal.
- An elongated, recessed cutout located on the side of the top cap assembly.
U.S. Design Patent No. D965,513 - "Battery," issued October 4, 2022
The Invention Explained
- Problem Addressed: This patent, like the ’512 Patent, protects a novel ornamental design for a battery.
- The Patented Solution: The ’513 Patent claims a distinct ornamental design for a battery. The design features a cylindrical main body and a top cap section that appears slightly wider than the body. The most prominent feature of this design is a vertically oriented, recessed, oblong or "racetrack" shaped element on the front face of the top cap assembly (’513 Patent, FIG. 1, FIG. 7). The complaint asserts this design is novel and has been embodied in commercially successful products (Compl. ¶20-21).
- Technical Importance: The claimed ornamental features create a distinct trade dress that, according to the complaint, consumers have come to associate with the plaintiff as a single source (Compl. ¶24).
Key Claims at a Glance
- The patent asserts a single claim for "The ornamental design for a battery, as shown and described" (’513 Patent, Claim).
- The asserted design is defined by the visual features shown in the patent's figures, including:
- A main cylindrical body.
- A top cap assembly that is slightly wider than the main body.
- A vertically oriented, recessed, oblong feature on the face of the top cap assembly.
III. The Accused Instrumentality
Product Identification
- Rechargeable batteries marketed and sold under the "PUJIMAX" brand (Compl. ¶9).
Functionality and Market Context
- The accused instrumentalities are rechargeable batteries offered for sale by the defendant entities through online storefronts, including on the Temu.com platform (Compl. ¶10). The complaint alleges that these products are "imitation products" that copy the plaintiff's patented designs and have "flooded the market" following the commercial success of the plaintiff's LANKOO/SMARTOOOLS branded batteries (Compl. ¶7, ¶29). A side-by-side comparison provided in the complaint shows the accused PUJIMAX products next to figures from the patents-in-suit (Compl. p. 9).
IV. Analysis of Infringement Allegations
The infringement test for a design patent is whether an "ordinary observer," familiar with the prior art designs, would be deceived into purchasing the accused product believing it to be the patented design. The complaint alleges that the accused products are "visually indistinguishable" from the patented designs (Compl. ¶3). The table provided in the complaint presents a direct visual comparison between the patented designs and the accused products (Compl. p. 9).
The complaint does not provide a traditional claim chart. The analysis below is based on the visual evidence and allegations presented.
D965,512 Infringement Allegations
| Claim Element (Feature of the Patented Design) | Alleged Infringing Functionality (Feature of the Accused Product) | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall ornamental design for a battery as depicted in the patent figures. | The overall appearance of the accused PUJIMAX battery, which is alleged to be a copy or colorable imitation of the patented design. | ¶31; p. 9 | FIG. 1-7 |
| A top cap assembly with a recessed, elongated notch on its side. | The accused PUJIMAX battery incorporates a top cap with a similarly shaped, sized, and positioned recessed notch. | p. 9 | FIG. 5-7 |
D965,513 Infringement Allegations
| Claim Element (Feature of the Patented Design) | Alleged Infringing Functionality (Feature of the Accused Product) | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall ornamental design for a battery as depicted in the patent figures. | The overall appearance of the accused PUJIMAX battery, which is alleged to be a copy or colorable imitation of the patented design. | ¶31; p. 9 | FIG. 1-7 |
| A top cap assembly, wider than the main body, featuring a vertically oriented, recessed oblong element on its face. | The accused PUJIMAX battery incorporates a similarly proportioned wider top cap with a visually corresponding recessed oblong element. | p. 9 | FIG. 1, 7 |
- Identified Points of Contention:
- Scope Questions: The central question for the court will be one of visual scope: are the designs of the accused PUJIMAX batteries "substantially the same" as the designs claimed in the ’512 and ’513 patents, such that an ordinary observer would be deceived?
- Technical Questions: The analysis will involve a side-by-side comparison of the products and the patent figures. The question will be whether any differences in proportion, surface ornamentation, or minor features between the accused products and the claimed designs are sufficient to avoid infringement in the eye of the ordinary observer.
V. Key Claim Terms for Construction
Claim construction, the process of defining the meaning of disputed terms in a utility patent claim, is generally not applicable to design patent cases. The "claim" is understood to be the design itself as depicted in the drawings. The scope of the claim is determined by the overall visual appearance of the design shown in the patent's figures, not by the interpretation of written terms. Therefore, the dispute will likely focus on a direct visual comparison under the "ordinary observer" test rather than on construing specific claim terms.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a separate count for indirect infringement. However, the prayer for relief seeks to enjoin Defendants from "Assisting, aiding, or abetting any other person or entity in engaging in the infringement of the Patents-in-Suit" (Compl. Prayer for Relief ¶a.ii). The core factual allegations in Count I focus on direct infringement (Compl. ¶44).
- Willful Infringement: The complaint alleges that Defendants are "acting in active concert to knowingly and willfully" infringe the patents-in-suit (Compl. ¶47). The basis for this allegation appears to be the assertion that Defendants recognized the commercial success of Plaintiff's designs and "flooded the market with imitation products that copy the distinctive designs" (Compl. ¶29). The complaint also alleges Defendants have "actual and/or constructive knowledge" of their infringing activities (Compl. ¶39).
VII. Analyst’s Conclusion: Key Questions for the Case
- Visual Similarity: The case will fundamentally turn on the application of the ordinary observer test. A core issue will be one of visual identity: are the accused PUJIMAX battery designs substantially the same as the designs claimed in the ’512 and ’513 patents, or do sufficient visual differences exist to distinguish them in the mind of a typical purchaser?
- Defendant Identification and Jurisdiction: A significant procedural question will be one of enforcement and liability: can the Plaintiff successfully identify, serve, and establish personal jurisdiction over the numerous, allegedly pseudonymous online sellers listed in the sealed Schedule A, and can it prove they operate as an "interconnected group" as alleged?