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" (Jurisdiction(s) unknown, alleged to be primarily People's Republic of China)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:26-cv-00933, N.D. Ill., 01/27/2026
• Venue Allegations: Venue is asserted based on Defendants targeting business activities toward consumers in the United States and Illinois through interactive e-commerce stores, offering shipping to Illinois, and accepting payment in U.S. dollars.
• Core Dispute: Plaintiff alleges that numerous unidentified e-commerce operators are infringing a design patent by selling battery packs that copy the patented ornamental design.
• Technical Context: The dispute concerns the ornamental design of a battery pack, likely for use with cordless vacuum cleaners, a product category where brand identity and design aesthetics are significant market differentiators.
• Key Procedural History: The complaint is structured as an action against a group of unidentified "John Doe" defendants, a common procedural posture in cases targeting online sellers on large e-commerce platforms who allegedly use aliases to conceal their identities.

Case Timeline

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

U.S. Design Patent No. D710,299 - "Battery pack"

• Patent Identification: U.S. Design Patent No. D710,299, "Battery pack," issued August 5, 2014 (’299 Patent).

The Invention Explained

• Problem Addressed: The patent does not describe a technical problem, as is typical for design patents. The implicit goal is to create a unique and non-obvious ornamental appearance for a battery pack, distinguishing it from prior art designs D710,299 Patent, Title
• The Patented Solution: The patent protects the specific visual appearance of a battery pack, characterized by its overall shape and the arrangement of its surface features. The design consists of a main rectangular body with rounded edges, from which an upright connecting structure with complex contours and apertures protrudes. The combination of these elements forms the claimed ornamental design D710,299 Patent, FIGS. 1-7
• Technical Importance: The design provides a distinctive aesthetic for a component part, contributing to the overall visual identity and branding of the larger product (e.g., a cordless vacuum) with which it is used Compl. ¶8

Key Claims at a Glance

• Design patents contain a single claim. The asserted claim in the ’299 Patent is for "the ornamental design for a battery pack, as shown and described" D710,299 Patent, Claim
• The scope of the claim is defined by the solid lines in the patent's seven drawing figures, which depict the design from perspective, front, rear, side, top, and bottom views D710,299 Patent, FIGS. 1-7

III. The Accused Instrumentality

• Product Identification: The "Infringing Products" are identified as unauthorized and unlicensed battery packs that allegedly feature Dyson's patented design Compl. ¶3
• Functionality and Market Context: The complaint alleges that Defendants operate e-commerce stores on platforms such as Amazon, eBay, Temu, and Walmart, using various "Seller Aliases" to target and sell the Infringing Products to consumers in the United States, including Illinois Compl. ¶¶2, 12 These stores are allegedly designed to appear as authorized retailers, making it difficult for consumers to distinguish them from legitimate channels Compl. ¶15 The complaint includes an image from the ’299 Patent, FIG. 1, to represent the design at issue. Compl. p. 4

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart exhibit. Instead, it alleges infringement narratively. The central allegation is that the Defendants are making, using, offering for sale, selling, and/or importing battery packs that embody the ornamental design claimed in the ’299 Patent Compl. ¶¶25-26

The legal standard for design patent infringement is the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design. The complaint asserts that Defendants sell "the same unauthorized and unlicensed product...that infringes Dyson's patented design" Compl. ¶3 The visual evidence provided in the complaint consists of the seven figures from the ’299 Patent itself, which serve to illustrate the patented design that is allegedly copied Compl. pp. 4-7

• Identified Points of Contention:
  • Visual Similarity: The core question for the court will be whether the accused products are "substantially the same" as the design claimed in the ’299 Patent from the perspective of an ordinary observer. This will require a side-by-side visual comparison of the accused products with the patent figures.
  • Scope Questions: The analysis may require distinguishing between the ornamental features protected by the patent and any functional aspects of the battery pack's design, as design patents do not protect functionality. The court may need to determine which visual elements are purely ornamental and thus part of the claimed design.

V. Key Claim Terms for Construction

Claim construction is generally not performed in design patent cases. The claim is understood to be the design as depicted in the patent's drawings. The infringement analysis is a visual comparison rather than a dispute over the meaning of textual terms.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants' acts constitute direct and/or indirect infringement Compl. ¶21, 25 The prayer for relief also seeks to enjoin defendants from "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing the patent Compl. p. 13
• Willful Infringement: The complaint alleges that "Defendants' infringement of the Dyson Design...was willful" and that Defendants are "working to knowingly and willfully import, distribute, offer for sale, and sell Infringing Products" Compl. ¶¶21, 22

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

• A primary issue will be one of visual comparison: Applying the "ordinary observer" test, are the ornamental features of the battery packs sold by the Defendants substantially the same as the specific design claimed in the seven figures of the ’299 Patent, such that a typical purchaser would be deceived?
• A key procedural and evidentiary question will be identifying the specific accused products for each of the numerous unnamed defendants and obtaining sufficient evidence to conduct the visual comparison required for an infringement analysis.
• The determination of willfulness will likely depend on facts developed during discovery regarding the Defendants' knowledge of the ’299 Patent and the extent to which their product designs constitute deliberate copying versus independent development.