Shenzhen Haorun E Commerce Co Ltd v. Shenzhen Lanhe Tech Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Haorun E-commerce Co., Ltd. (China)
  • Defendant: Shenzhen Lanhe Technologies Co., Ltd. (China)
  • Plaintiff’s Counsel: Nitin Kaushik
• Case Identification: 1:25-cv-09366, S.D.N.Y., 11/25/2025
• Venue Allegations: Venue is based on Defendant’s business activities within the district, including offering products for sale to New York consumers through e-commerce platforms such as Amazon.com.
• Core Dispute: Plaintiff seeks a declaratory judgment that its mobile phone cases do not infringe Defendant's design patent and, alternatively, that the patent is invalid and unenforceable.
• Technical Context: The dispute concerns the ornamental design of mobile phone cases, a highly competitive consumer electronics accessory market where visual differentiation is a key driver of commercial success.
• Key Procedural History: The complaint states this action was precipitated by multiple infringement complaints filed by the Defendant on Amazon against the Plaintiff’s product listings, resulting in their removal or suspension. The Plaintiff alleges invalidity based on specific prior art patents and challenges the validity of the patent’s priority claim.

Case Timeline

Date	Event
2022-02-08	'730 Patent Priority Date (via CN307319077S)
2023-05-05	'730 Patent Application Filing Date
2024-06-11	'730 Patent Issue Date
2025-11-25	Complaint Filing Date

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

U.S. Design Patent No. D1,030,730 S - “Case for Mobile Phone”

• Patent Identification: U.S. Design Patent No. D1,030,730 S (“Case for Mobile Phone”), issued June 11, 2024 (the “’730 Patent”).

The Invention Explained

• Problem Addressed: In the field of design patents, the objective is to create a new, original, and ornamental design for an article of manufacture, thereby providing a unique aesthetic appearance that distinguishes it from existing products ('730 Patent, Claim).
• The Patented Solution: The ’730 Patent claims a specific ornamental design for a mobile phone case. The protectable design, depicted in solid lines in the patent's figures, consists of the overall visual appearance of the case, characterized by a rectangular body with rounded corners, a raised rectangular bezel surrounding the camera cutout, and a circular ring stand assembly located on the back panel (’730 Patent, FIG. 1, 3). A key feature of the design is the ring stand element, which is shown in a deployed, functional state, illustrating its appearance as part of the overall design ('730 Patent, FIG. 9). The broken lines in the figures denote aspects of the mobile phone case that are not part of the claimed design ('730 Patent, Description).
• Technical Importance: The claimed design provides a distinct visual identity for a phone case, which is a critical factor for consumer choice in the crowded and competitive mobile accessory market (Compl. ¶4).

Key Claims at a Glance

• The single claim asserted is for "The ornamental design for a case for mobile phone, as shown and described" ('730 Patent, Claim).
• The essential ornamental elements of the claimed design are the visual characteristics depicted in the solid-line portions of the figures, including:
  • The overall shape and contour of the case body.
  • The specific design of the raised bezel around the camera aperture.
  • The appearance and placement of the circular ring stand assembly on the rear of the case.

III. The Accused Instrumentality

Product Identification

The complaint identifies the products at issue as "Plaintiff FenShu Trade's products, namely electroplating iPhone cases with stands" (Compl. ¶1). Multiple Amazon Standard Identification Numbers (ASINs) for these products are listed (Compl. ¶8).

Functionality and Market Context

• The complaint describes the products as mobile phone accessories designed for iPhones that incorporate a stand feature and have an electroplated finish (Compl. ¶1, ¶7).
• The Plaintiff alleges its products have been subject to removal or suspension from Amazon's marketplace due to infringement complaints filed by the Defendant, causing "substantial financial loss" (Compl. ¶8).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

As this is a complaint for a declaratory judgment of non-infringement, the Plaintiff makes allegations about why its products do not infringe rather than mapping product features to claim elements. The complaint does not contain a claim chart or provide sufficient visual or descriptive detail about the accused products to construct one.

The Plaintiff’s theory of non-infringement is based on the "ordinary observer" test established in Egyptian Goddess, Inc. v. Swisa, Inc. (Compl. ¶12). The complaint alleges that an ordinary observer, when comparing the Plaintiff’s products to the patented design, would not find them to be substantially the same (Compl. ¶12). The basis for this conclusion is the assertion that the Plaintiff's designs differ from the claimed design in their "contour, proportion, and ornamental arrangement" (Compl. ¶13). The complaint references, but does not include, professional analyses that allegedly support this conclusion (Compl. ¶9).

• Identified Points of Contention:
  • Visual Scope: A central question will be whether the alleged differences in "contour, proportion, and ornamental arrangement" between the Plaintiff's products and the '730 Patent design are significant enough to deceive an ordinary observer into purchasing one believing it to be the other.
  • Role of Prior Art: The non-infringement analysis will be conducted from the perspective of an ordinary observer familiar with the prior art. The complaint’s invalidity contentions, which are based on specific prior art designs, may therefore directly influence the non-infringement analysis by potentially narrowing the perceived scope of the '730 Patent's design contribution (Compl. ¶15).

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses on defining the scope of the claimed design as a whole, rather than interpreting individual text-based terms.

• The Term: "the ornamental design for a case for mobile phone, as shown and described"
• Context and Importance: The entire dispute hinges on the scope of this claimed design. The court's interpretation of what constitutes the core ornamental features of the design, as depicted in the patent's figures, will determine both the infringement and validity analyses. Practitioners may focus on which specific visual elements are most significant to the overall design impression.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the claim covers the overall visual impression created by the combination of a rectangular case, a raised camera bezel, and a circular ring stand, without being limited to the exact proportions shown.
  • Evidence for a Narrower Interpretation: A party could argue that the claim is limited to the precise proportions, contours, and interrelation of the elements as depicted in the solid lines of the figures ('730 Patent, FIG. 1-9). The use of broken lines to disclaim portions of the case could be used to argue that the claim is narrowly focused only on the specific elements shown in solid lines ('730 Patent, Description).

VI. Other Allegations

The complaint includes counts for declaratory judgment of invalidity and unenforceability.

• Invalidity: The Plaintiff alleges that the ’730 Patent is invalid under 35 U.S.C. §§ 102 and 103 for lacking novelty and non-obviousness in light of prior art, specifically identifying Chinese Design Patents CN306814663S and CN306996237S (Compl. ¶15). The complaint further alleges that the patent's priority claim to Chinese application CN307319077S is defective because the underlying application has been invalidated by the Chinese Patent Office, which would render the priority date ineffective and potentially expose the patent to additional prior art (Compl. ¶16).
• Unenforceability: The complaint asserts that the ’730 Patent is unenforceable due to inequitable conduct, alleging that the patentee failed to disclose relevant prior art to the USPTO during prosecution (Compl. ¶18).

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

• A core issue will be one of visual comparison: will an ordinary observer, familiar with the prior art phone case designs, find the overall ornamental appearance of the Plaintiff's products to be substantially the same as the design claimed in the '730 Patent?
• A key validity question will be one of prior art impact: do the cited Chinese design patents, or other designs in the field, anticipate or render obvious the specific ornamental features claimed in the '730 Patent, thereby invalidating it?
• The case may present a critical procedural question: is the '730 Patent's priority claim to the 2022 Chinese application defective as alleged? An affirmative answer could prove dispositive by changing the effective filing date and allowing intervening prior art to be asserted against the patent.