DCT
1:26-cv-00639
Dyson Technology Ltd v. Partnerships Unincorp Associations
Key Events
Complaint
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, alleged to be foreign)
- Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
- Case Identification: 1:26-cv-00639, N.D. Ill., 01/20/2026
- Venue Allegations: Venue is based on allegations that Defendants operate interactive e-commerce stores that target and sell products to consumers in Illinois.
- Core Dispute: Plaintiff alleges that Defendants’ unauthorized e-commerce storefronts are making, using, selling, and/or importing battery packs that infringe a Dyson design patent.
- Technical Context: The dispute centers on the ornamental design of a removable battery pack, a key component for modern cordless appliances like vacuum cleaners.
- Key Procedural History: The complaint frames this action as a response to a network of difficult-to-identify foreign sellers operating through multiple online aliases to evade intellectual property enforcement.
Case Timeline
| Date | Event |
|---|---|
| 2013-02-18 | U.S. Patent No. D710,299 Priority Date |
| 2014-08-05 | U.S. Patent No. D710,299 Issues |
| 2026-01-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D710,299 - *"Battery pack"*
The Invention Explained
- Problem Addressed: The patent addresses the challenge of creating a new, original, and ornamental design for an article of manufacture—specifically, a battery pack for an electronic device (D'299 Patent, Title).
- The Patented Solution: The patent claims the specific visual appearance of a battery pack, characterized by its combination of shapes, lines, and surfaces as depicted in the patent's seven figures (D'299 Patent, Claim, FIGS. 1-7). The design features a generally rectangular base with rounded edges, from which a distinct, multi-faceted connector tower rises at an angle (D'299 Patent, FIG. 1, FIG. 4). The design's overall visual impression is defined by the interplay of these geometric elements.
- Technical Importance: Distinctive designs for product components like battery packs can serve as a source identifier and contribute to a product line's overall brand aesthetic, which Plaintiff alleges is a key aspect of its products (Compl. ¶8).
Key Claims at a Glance
- Design patents contain a single claim. The asserted claim is: "The ornamental design for a battery pack, as shown and described" (D'299 Patent, Claim).
- The scope of this claim is defined by the solid lines in Figures 1 through 7 of the patent (D'299 Patent, DESCRIPTION). The broken lines in the figures illustrate environmental structure and form no part of the claimed design (D'299 Patent, DESCRIPTION).
III. The Accused Instrumentality
Product Identification
- The accused products are battery packs sold by Defendants, referred to as the "Infringing Products" (Compl. ¶3).
Functionality and Market Context
- The complaint alleges that Defendants operate numerous e-commerce stores under various "Seller Aliases" on platforms such as Amazon, eBay, Temu, and Walmart (Compl. ¶12).
- These stores are alleged to offer for sale and sell battery packs that embody Dyson's patented design to consumers in the United States, including in Illinois (Compl. ¶¶12, 14, 21). The complaint includes an image from the '299 Patent, FIG. 1, to represent the patented design that is allegedly infringed (Compl. p. 4).
IV. Analysis of Infringement Allegations
The complaint alleges that the "Infringing Products" sold by Defendants are visually the same as the patented design (Compl. ¶3). The infringement test for a design patent is 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 does not contain images of the accused products themselves, precluding a side-by-side visual comparison in this report. The infringement theory is summarized below.
D710,299 Infringement Allegations
| Claim Element (Visual Feature from Claim) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall ornamental design for a battery pack as shown in the patent figures. | Defendants are making, using, offering for sale, and/or importing into the United States "the same unauthorized and unlicensed product... that infringes Dyson's patented design." | ¶3, ¶25 | D'299 Patent, FIGS. 1-7 |
| A combination of a rectangular base with rounded corners and an angled, multi-surfaced connector tower rising from the base. | Defendants' "Infringing Products" allegedly incorporate the overall visual appearance claimed in the Dyson Design. | ¶21, ¶25 | D'299 Patent, FIG. 1 |
Identified Points of Contention
- Evidentiary Question: The central question will be factual and evidentiary: what is the actual ornamental design of the accused battery packs? The court will need to compare the accused products to the figures in the '299 Patent to determine if their overall visual appearance is substantially the same.
- Prior Art Question: A potential point of contention, not raised in the complaint, is the scope of the prior art for battery pack designs. The degree of similarity required for infringement is viewed in the context of designs that were known at the time the patented design was created.
V. Key Claim Terms for Construction
In design patent litigation, claim construction is typically not a central issue, as the claim's scope is defined by the drawings rather than words. Based on the complaint, there are no specific terms that appear to be subjects of a likely construction dispute. The single claim is for the "ornamental design for a battery pack," and the complaint alleges the accused products are battery packs (Compl. ¶3).
VI. Other Allegations
Indirect Infringement
- The complaint makes a general allegation that Defendants' products "infringe directly and/or indirectly" the patented design (Compl. ¶25). The prayer for relief also seeks to enjoin Defendants from "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing acts (Prayer ¶1(b)). However, the factual allegations primarily focus on direct infringement through making, using, selling, and importing (Compl. ¶21).
Willful Infringement
- The complaint alleges that Defendants' infringement was willful (Compl. ¶22). This allegation is based on the assertion that Defendants acted "knowingly and willfully" when they imported, distributed, offered for sale, and sold the accused products without authorization (Compl. ¶21).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary proof: Can the Plaintiff produce evidence demonstrating that the products sold by the largely anonymous Defendants possess an ornamental design that, in the eyes of an ordinary observer, is substantially the same as the design claimed in the '299 Patent?
- A key procedural question will be one of enforcement: Given that the Defendants are alleged to be a network of foreign entities operating under concealed identities and aliases (Compl. ¶¶10-11, 17), can the Plaintiff effectively identify the responsible parties, obtain personal jurisdiction, and enforce any potential judgment or injunction against them?