DCT

1:25-cv-15663

Anker Innovations Technology Co Ltd v. Beijing Seven Talents Technology Co Ltd

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-15663, N.D. Ill., 12/24/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendants' targeting of business activities in Illinois, including operating interactive e-commerce stores, selling and shipping infringing products to Illinois customers, and causing injury to Plaintiff Fantasia Trading LLC, which maintains a warehouse in Bolingbrook, Illinois.
  • Core Dispute: Plaintiff alleges that Defendant’s smart home security products, sold under the AOSU brand, infringe two of Plaintiff's design patents for a video doorbell and a security camera, and also infringe Plaintiff's federally registered "HOMEBASE" trademark.
  • Technical Context: The dispute is set in the competitive consumer smart home security market, where the ornamental design and aesthetic of products like video doorbells and cameras are significant factors in brand identity and consumer choice.
  • Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings (e.g., IPRs) involving the patents-in-suit.

Case Timeline

Date Event
2020-07-20 U.S. Design Patent No. D966,918 Priority Date
2022-10-18 U.S. Design Patent No. D966,918 Issues
2023-05-30 U.S. Design Patent No. D1,077,022 Priority Date
2025-05-27 U.S. Design Patent No. D1,077,022 Issues
2025-12-12 Plaintiff’s counsel places order for accused Aosu product
2025-12-24 Complaint Filing Date

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

U.S. Design Patent No. D966,918 - "Doorbell," issued October 18, 2022

The Invention Explained

  • Problem Addressed: The patent addresses the need for a new, original, and ornamental design for a video doorbell, an article of manufacture where aesthetic appeal is a key market differentiator (Compl. ¶ 26).
  • The Patented Solution: The patent protects the specific visual appearance of the doorbell as depicted in its figures. The design is characterized by an elongated rectangular form with softly rounded vertical edges, a prominent circular camera lens assembly positioned in the upper half, and a large, unadorned circular button element located in the lower half (D’918 Patent, FIGS. 1, 2). This combination of elements creates a distinct visual identity.
  • Technical Importance: In the crowded consumer electronics space, a distinctive product design serves as a crucial brand identifier and can significantly influence consumer purchasing decisions (Compl. ¶¶ 26, 32).

Key Claims at a Glance

  • The patent contains a single claim for "The ornamental design for a doorbell, as shown and described" (D’918 Patent, Claim).

U.S. Design Patent No. D1,077,022 - "Camera," issued May 27, 2025

The Invention Explained

  • Problem Addressed: The patent addresses the need for a unique ornamental design for a wall-mounted security camera that integrates a light source.
  • The Patented Solution: The D’022 Patent protects the ornamental design of a camera featuring a two-part construction. The design consists of a compact, rectangular upper housing containing the camera lens, which is visually distinct from a larger, integrated lower body that serves as a light panel. The overall unit has a trapezoidal side profile, with the front face sloping downward and inward (D’022 Patent, FIGS. 1, 5, 6).
  • Technical Importance: The aesthetic integration of camera and lighting functions into a single, cohesive design helps differentiate the product in a competitive market and contributes to brand recognition (Compl. ¶¶ 26, 32).

Key Claims at a Glance

  • The patent contains a single claim for "The ornamental design for a camera as shown and described" (D’022 Patent, Claim).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "AOSU Video Doorbell Ultra/Outdoor Doorbell Camera Wireless 5MP" and the "AOSU Solar Wall Light Cam Pro" as infringing products (Compl. ¶¶ 59-60, 61).

Functionality and Market Context

The accused products are smart home security devices that directly compete with Plaintiff's Eufy-branded products in the same consumer market (Compl. ¶¶ 50, 67). The complaint alleges these products are sold through various online retail channels, including Defendants' own website (aosulife.com), Amazon, Walmart, and Best Buy (Compl. ¶¶ 51-53, 68). The complaint includes a side-by-side comparison image showing the accused AOSU doorbell next to the drawing from the D'918 Patent (Compl. ¶ 59, p. 15). A similar comparison is provided for the accused AOSU camera and the D'022 Patent (Compl. ¶ 60, p. 16).

IV. Analysis of Infringement Allegations

For design patents, infringement is determined by the "ordinary observer" test, which asks whether an ordinary observer would be deceived into purchasing the accused product believing it to be the patented design. The analysis focuses on the overall visual similarity.

D966,918 Infringement Allegations

The complaint provides a side-by-side visual comparison to support its infringement claim for the D'918 Patent (Compl. ¶ 59).

Patented Design Feature (from D'918 Patent) Corresponding Accused Product Feature Complaint Citation Patent Citation
Elongated, rectangular overall shape with softly rounded vertical edges A similar elongated, rectangular body with rounded edges ¶59 FIG. 1
A prominent, circular camera lens assembly located in the upper half of the device A circular camera lens located in a similar position in the upper half of the device body ¶59 FIG. 2
A large, simple circular button element located in the lower half of the device A large circular button, which includes a bell icon, located in the lower half of the device ¶59 FIG. 2

D1,077,022 Infringement Allegations

The complaint provides a side-by-side visual comparison to support its infringement claim for the D'022 Patent (Compl. ¶ 60).

Patented Design Feature (from D'022 Patent) Corresponding Accused Product Feature Complaint Citation Patent Citation
A two-part design with a distinct, darker, rectangular upper camera housing A dark, rectangular upper housing containing camera components ¶60 FIG. 1
A larger, lighter-colored lower body serving as a light panel A white lower body that functions as a light panel ¶60 FIG. 3
A trapezoidal side profile where the front face slopes downward and inward A similar trapezoidal side profile ¶60 FIG. 5

Identified Points of Contention

  • Scope Questions: The central dispute will be whether the visual differences between the patented designs and the accused products are substantial enough to prevent an ordinary observer from being deceived. For the D'918 Patent, a point of contention may be the visual effect of the bell icon on the accused product's button, which is absent in the patented design. For the D'022 Patent, points of contention may arise from minor differences in proportion, curvature, and the interface between the upper and lower sections.
  • Technical Questions: A factual question will be how the overall visual impression of each accused product compares to the corresponding patented design when viewed as a whole, rather than as a collection of dissected features. The complaint also presents side-by-side comparisons of the parties' marketing materials, suggesting that alleged similarities in advertising style may be used as evidence of intent to copy the product designs (Compl. p. 14).

V. Key Claim Terms for Construction

This section is not applicable as the asserted patents are design patents, which do not contain textual claim terms requiring construction. The "claim" is the design itself as shown in the drawings.

VI. Other Allegations

  • Indirect Infringement: The complaint includes allegations of indirect infringement for both patents (Compl. ¶¶ 92, 98). However, it does not plead specific facts to support theories of induced or contributory infringement beyond the general allegations of making, using, offering for sale, selling, and importing the accused products.
  • Willful Infringement: The complaint alleges that Defendants' infringement was willful (Compl. ¶ 64). This allegation is supported by claims that Defendants "systematically copied Anker's brand of security technologies" and "deliberately and coordinated efforts to misappropriate Anker's product designs and brand identity" (Compl. ¶¶ 54, 56).

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

  1. A core issue will be one of visual deception: Applying the ordinary observer test, are the accused AOSU doorbell and camera designs "substantially the same" as the designs protected by the D'918 and D'022 patents, such that a consumer would be deceived into purchasing one believing it to be the other, despite any minor differences?
  2. A key evidentiary question will be the impact of alleged copying: To what extent will the court consider extrinsic evidence, such as the alleged imitation of Plaintiff's marketing materials and the alleged infringement of the "HOMEBASE" trademark, as proof of intent to copy the patented designs, which could in turn influence the assessment of design patent infringement?