DCT

2:23-cv-13026

GM Global Technology Operations LLC v. Quality Collision Parts Inc

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Key Events
Amended Complaint
amended complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-13026, E.D. Mich., 01/30/2026
  • Venue Allegations: Venue is alleged to be proper as the corporate defendants are incorporated in Michigan, maintain a regular and established place of business within the district, and allegedly commit acts of infringement in the district. The individual defendants are residents of the district.
  • Core Dispute: Plaintiff alleges that Defendants’ aftermarket automotive replacement parts infringe ten of Plaintiff's U.S. design patents covering the ornamental appearance of various vehicle components, including headlamps, grilles, and bumpers.
  • Technical Context: The dispute is situated in the automotive aftermarket parts industry, where the ornamental design of components is a key factor in product value and brand identity.
  • Key Procedural History: The complaint alleges that Defendants received notice of the asserted patents through a U.S. Customs and Border Protection seizure of parts in July 2022, followed by direct communications from Plaintiff. The complaint further alleges that after the initial lawsuit was filed, Defendants created a successor entity, Power Auto Parts, and transferred assets in an effort to shield them from liability.

Case Timeline

Date Event
2011-07-13 U.S. Patent D670,840 Priority Date
2012-11-13 U.S. Patent D670,840 Issued
2015-10-23 U.S. Patent D777,622 Priority Date
2016-02-04 U.S. Patent D800,615 & D811,954 Priority Date
2016-06-21 U.S. Patent D805,964 Priority Date
2016-08-05 U.S. Patent D807,241 Priority Date
2016-09-01 U.S. Patent D811,964 Priority Date
2017-01-31 U.S. Patent D777,622 Issued
2017-05-08 U.S. Patent D826,114 & D843,025 Priority Date
2017-10-24 U.S. Patent D800,615 Issued
2017-11-13 U.S. Patent D867,939 Priority Date
2017-12-26 U.S. Patent D805,964 Issued
2018-01-09 U.S. Patent D807,241 Issued
2018-03-06 U.S. Patent D811,954 Issued
2018-03-06 U.S. Patent D811,964 Issued
2018-08-21 U.S. Patent D826,114 Issued
2019-03-12 U.S. Patent D843,025 Issued
2019-11-26 U.S. Patent D867,939 Issued
2022-07-01 Alleged CBP seizure of Defendants' parts (approx. date)
2022-12-07 Alleged date of notice of infringement to Defendants
2023-06-13 Alleged date of formal written notice to Defendants
2023-12-27 Power Auto Parts, Inc. allegedly incorporated
2026-01-30 First Amended Complaint Filed

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

U.S. Patent No. D670,840 - "Vehicle Head Lamp"

  • Patent Identification: U.S. Patent No. D670,840, "Vehicle Head Lamp," issued November 13, 2012 (Compl. ¶81).

The Invention Explained

  • Problem Addressed: Design patents protect ornamental appearance rather than solving a technical problem. The implicit goal is to create a novel and nonobvious aesthetic design for an article of manufacture (Compl. ¶24).
  • The Patented Solution: The patent claims the specific ornamental design for a vehicle headlamp as depicted in the patent's figures (’840 Patent, CLAIM, Figs. 1-4). The design is characterized by a swept-back, generally trapezoidal shape with a distinct arrangement of internal structures, contours, and surfaces that create a specific visual appearance ('840 Patent, Fig. 1).
  • Technical Importance: The complaint alleges that Plaintiff invests millions of dollars annually in product design to create "innovative and aesthetically beautiful designs" that serve as a source identifier for its vehicles (Compl. ¶24, ¶27).

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is: "The ornamental design for a vehicle head lamp, as shown and described" ('840 Patent, CLAIM).
  • The essential elements of the claim are the visual features of the headlamp as depicted in Figures 1-4 of the patent, including its overall shape, proportions, and surface ornamentation.

U.S. Patent No. D843,025 - "Vehicle Front Headlamp"

  • Patent Identification: U.S. Patent No. D843,025, "Vehicle Front Headlamp," issued March 12, 2019 (Compl. ¶97).

The Invention Explained

  • Problem Addressed: The patent addresses the need for a unique ornamental design for a vehicle headlamp, a key component of a vehicle's exterior styling (Compl. ¶25).
  • The Patented Solution: The patent claims the ornamental design for a vehicle front headlamp, showing two distinct embodiments (’025 Patent, CLAIM, DESCRIPTION). The design features an angular, complex perimeter shape with prominent internal elements that form a distinctive lighting signature ('025 Patent, Figs. 1, 5).
  • Technical Importance: The unique appearance of components such as headlamps is alleged to be a critical aspect of Plaintiff's brand identity and market differentiation (Compl. ¶27).

Key Claims at a Glance

  • The asserted claim is: "The ornamental designs for a vehicle front headlamp, as shown and described" ('025 Patent, CLAIM).
  • The claim covers the specific visual appearance of the headlamp embodiments shown in Figures 1-8 of the patent.

Multi-Patent Capsules

  • U.S. Patent No. D807,241: Titled "Vehicle Grille," issued January 9, 2018 (Compl. ¶113). The patent claims the ornamental design for a vehicle grille. The complaint alleges infringement by Defendants' aftermarket grilles sold for the 2018-2021 Chevrolet Equinox (Compl. ¶116, ¶117, ¶119).
  • U.S. Patent No. D805,964: Titled "Vehicle Grille," issued December 26, 2017 (Compl. ¶129). The patent claims the ornamental design for a vehicle grille. The complaint alleges infringement by Defendants' aftermarket grilles sold for the 2017-2019 Buick LaCrosse (Compl. ¶132, ¶133, ¶135).
  • U.S. Patent No. D811,954: Titled "Radiator Grille of Car," issued March 6, 2018 (Compl. ¶145). The patent claims the ornamental design for a vehicle radiator grille. The complaint alleges infringement by Defendants' aftermarket grilles sold for the 2017-2022 Buick Encore (Compl. ¶148, ¶149, ¶151).
  • U.S. Patent No. D811,964: Titled "Vehicle Front Upper Bumper," issued March 6, 2018 (Compl. ¶161). The patent claims the ornamental design for a front upper bumper. The complaint alleges infringement by Defendants' aftermarket bumpers sold for the 2018-2021 Chevrolet Equinox (Compl. ¶164, ¶165, ¶167).
  • U.S. Patent No. D826,114: Titled "Vehicle Front Bumper," issued August 21, 2018 (Compl. ¶177). The patent claims the ornamental design for a vehicle front bumper assembly (fascia). The complaint alleges infringement by Defendants' aftermarket fascias sold for the 2019-2020 Chevrolet Malibu (Compl. ¶180, ¶181, ¶183).
  • U.S. Patent No. D800,615: Titled "Front Bumper of Car," issued October 24, 2017 (Compl. ¶193). The patent claims the ornamental design for a vehicle front bumper (fascia). The complaint alleges infringement by Defendants' aftermarket fascias sold for the 2017-2022 Buick Encore (Compl. ¶196, ¶197, ¶199).
  • U.S. Patent No. D867,939: Titled "Vehicle Grille Bezel," issued November 26, 2019 (Compl. ¶209). The patent claims the ornamental design for a vehicle grille bezel. The complaint alleges infringement by Defendants' aftermarket grille bezels sold for the 2019 Chevrolet Cruze (Compl. ¶212, ¶213, ¶215).
  • U.S. Patent No. D777,622: Titled "Vehicle Hood," issued January 31, 2017 (Compl. ¶225). The patent claims the ornamental design for a vehicle hood. The complaint alleges infringement by Defendants' aftermarket hoods sold for the 2016-2019 Chevrolet Cruze (Compl. ¶228, ¶229, ¶231).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are various aftermarket replacement and replica automotive body parts sold by Defendants, including but not limited to headlamps, grilles, bumpers, fascias, hoods, and bezels (Compl. ¶2, ¶32). The complaint identifies specific part numbers for each asserted patent (e.g., Compl. ¶87, ¶103).

Functionality and Market Context

The complaint alleges that the accused products are designed to be "near-identical (if not completely identical) carbon copies in terms of ornamental appearance to the GM parts that they are meant to replace" (Compl. ¶28). Defendants allegedly market their products as being "designed and built to fit the exact specifications" of GM vehicles and as a way for consumers to "save you money" compared to purchasing from an authorized GM dealer (Compl. ¶29).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits for each asserted patent but does not include them in the provided filing. The following is a summary of the narrative infringement theory presented in the complaint.

D670,840 Infringement Allegations

The complaint alleges that Defendants' aftermarket headlamps, specifically part numbers GM2502362, GM2503362, and GM2503400, directly infringe the '840 Patent (Compl. ¶87, ¶88). These parts are marketed for the 2013-2016 Chevrolet Malibu, which is the commercial embodiment of the patented design (Compl. ¶84, ¶85). The infringement theory asserts that the accused parts are "substantially similar, if not identical, to the designs disclosed in the D’840 Patent" (Compl. ¶87). The core of the allegation is that the overall ornamental appearance of the accused headlamps is legally indistinguishable from the design claimed in the patent.

D843,025 Infringement Allegations

The complaint alleges that Defendants' aftermarket headlamps, part numbers GM2502498 and GM2503498, directly infringe the '025 Patent (Compl. ¶103, ¶104). These accused parts are sold as replacements for the 2019-2024 Chevrolet Malibu headlamp, which commercially embodies the patented design (Compl. ¶100, ¶101). The complaint alleges these parts are "substantially similar, if not identical," to the patented designs, asserting that an ordinary observer would find the designs to be the same (Compl. ¶103).

Identified Points of Contention

  • Scope Questions: The central question for each patent-in-suit will be whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused part is the same as the patented design. The dispute will likely focus on the overall visual impression created by the products compared to the patent drawings, rather than on minor differences.
  • Technical Questions: In the context of design patents, the questions are aesthetic, not technical. A primary point of contention may be: Do any visual differences between the accused parts and the patent drawings negate the ornamental similarity of the designs as a whole, or are they trivial in the context of the overall appearance?

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings rather than textual limitations. Therefore, formal claim construction of specific terms is generally not a central issue. The analysis focuses on a comparison of the accused design to the claimed design from the perspective of an ordinary observer, considering the design as a whole.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendants' infringement has been willful (e.g., Compl. ¶92, ¶95). The basis for this allegation includes alleged notice provided to Defendants through several events: a U.S. Customs and Border Protection (CBP) seizure and investigation beginning in July 2022 (Compl. ¶34-35); direct communications from Plaintiff regarding its infringement determination around December 2022 (Compl. ¶37); being directed to Plaintiff's virtual patent marking list in May 2023 (Compl. ¶38); and receiving a formal notice letter by June 13, 2023 (Compl. ¶39). The complaint alleges that Defendants continued their infringing conduct despite this knowledge (Compl. ¶95).

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

  • A core issue will be one of visual comparison: For each of the ten asserted design patents, is the overall ornamental appearance of the corresponding accused aftermarket part "substantially the same" as the patented design from the perspective of an ordinary observer, such that the observer would be induced to purchase one supposing it to be the other?
  • A second central question will be one of corporate liability and intent: Does the evidence support Plaintiff's allegations that Power Auto Parts is a mere successor to Quality Collision, formed to evade liability? Further, will the evidence of alleged pre-suit notice through the CBP seizure and direct correspondence support a finding of willful infringement, potentially justifying enhanced damages?
  • Finally, the case may present a question of individual liability: The complaint names several individuals as defendants and includes claims for piercing the corporate veil. A key issue will be whether Plaintiff can produce sufficient evidence to disregard the corporate form and hold the individual defendants personally liable for the alleged infringement and other related claims.