1:25-cv-10395
Shenzhen Haorun E Commerce Co Ltd v. Shenzhen Lanhe Technologies 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-10395, S.D.N.Y., 12/15/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts business in the district by offering products for sale through e-commerce platforms like Amazon.com.
- Core Dispute: Plaintiff seeks a declaratory judgment that its electroplating iPhone cases with stands do not infringe Defendant’s design patent, and that the patent is invalid and unenforceable.
- Technical Context: The dispute concerns the ornamental design of protective cases for mobile phones, a highly competitive market segment where visual appearance is a key differentiator.
- Key Procedural History: The complaint alleges this action was precipitated by Defendant filing multiple infringement complaints on Amazon against Plaintiff's product listings, which resulted in their removal and financial loss to the Plaintiff. The complaint also alleges that the patent's priority claim is defective because the underlying Chinese application has been invalidated, which may impact the universe of applicable prior art.
Case Timeline
| Date | Event |
|---|---|
| 2022-02-08 | U.S. Patent No. D1,030,730S - Earliest Priority Date |
| 2023-05-05 | U.S. Patent No. D1,030,730S - Application Filing Date |
| 2024-06-11 | U.S. Patent No. D1,030,730S - Issue Date |
| 2025-12-15 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,030,730S - "Case for Mobile Phone"
The patent-in-suit is U.S. Design Patent No. D1,030,730S, issued June 11, 2024 (’730 Patent).
The Invention Explained
- Problem Addressed: Design patents protect ornamental appearance rather than function. The patent does not describe a technical problem but instead presents a new, original, and ornamental design for an article of manufacture—in this case, a mobile phone case (’730 Patent, Claim).
- The Patented Solution: The claimed design consists of the visual ornamental characteristics of a mobile phone case. Key features depicted in the solid lines of the patent figures include a rectangular case body with rounded corners, a raised, squared-off camera bezel, and a circular ring stand assembly on the back panel (’730 Patent, Figs. 1, 3, 9). The ring stand is shown capable of pivoting outward from a recessed base (’730 Patent, Fig. 9). The broken lines in the figures depict portions of the phone case that are not part of the claimed design (’730 Patent, Description).
- Technical Importance: In the crowded mobile accessory market, unique ornamental designs serve as a primary means of product differentiation and brand identification (Compl. ¶4).
Key Claims at a Glance
- The patent contains a single claim: "The ornamental design for a case for mobile phone, as shown and described" (’730 Patent, Claim).
- The scope of this claim is defined by the solid-line drawings within the patent.
III. The Accused Instrumentality
Product Identification
Plaintiff’s "electroplating iPhone cases with stands," sold under the brand FenShu Trade (Compl. ¶1).
Functionality and Market Context
The complaint describes the accused products as accessories for iPhones that provide protection and include a stand feature (Compl. ¶1, ¶4). Plaintiff alleges that these products were sold on e-commerce platforms like Amazon.com until Defendant’s infringement complaints led to the removal of numerous product listings, causing "substantial financial loss" (Compl. ¶7-8). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
This is a declaratory judgment action where the Plaintiff (the accused infringer) is arguing for non-infringement. The central test for design patent infringement is the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art designs, would be deceived into believing the accused design is the same as the patented design (Compl. ¶12).
The complaint does not contain a detailed, element-by-element comparison or a claim chart. Instead, it makes a holistic argument that Plaintiff’s products do not infringe. The core of the non-infringement argument is that the accused products are not "substantially the same" as the claimed design of the ’730 Patent (Compl. ¶12). The Plaintiff contends that its products differ in "contour, proportion, and ornamental arrangement" from the design claimed in the patent (Compl. ¶13).
- Identified Points of Contention:
- Overall Visual Impression: The central question will be whether the visual differences alleged by the Plaintiff are significant enough to prevent an ordinary observer from finding the designs substantially the same. The analysis will compare the overall visual effect of the accused products with the design shown in the ’730 Patent figures.
- Impact of Prior Art: The "ordinary observer" is assumed to be familiar with the prior art. The complaint alleges the existence of invalidating prior art, which could serve to narrow the perceived scope of the ’730 Patent design and highlight differences between it and the accused products (Compl. ¶12, ¶15).
V. Other Allegations
Invalidity and Unenforceability Allegations
Plaintiff raises several affirmative challenges to the ’730 Patent's validity and enforceability.
- Prior Art: The complaint alleges the ’730 Patent is invalid under 35 U.S.C. §§ 102 (novelty) and 103 (non-obviousness) in view of prior art, specifically identifying Chinese Design Patents CN306814663S and CN306996237S (Compl. ¶15). It argues the claimed design is "substantially identical to prior art" and lacks ornamental distinction (Compl. ¶17).
- Defective Priority Claim: A key allegation is that the patent's claim to a February 8, 2022 priority date is defective because the underlying Chinese application (CN307319077S) has been invalidated by the Chinese Patent Office (Compl. ¶6, ¶16). If this allegation is proven, the patent’s effective filing date could be moved to its U.S. filing date of May 5, 2023, potentially allowing a wider range of intervening publications to be used as invalidating prior art.
- Inequitable Conduct: The complaint makes a general allegation of unenforceability due to inequitable conduct, asserting a "lack of candor in failing to disclose relevant prior art during prosecution" (Compl. ¶18).
VI. Analyst’s Conclusion: Key Questions for the Case
This case appears to present three primary questions for the court:
- A question of visual comparison: Applying the "ordinary observer" test, are the asserted differences in contour, proportion, and arrangement between Plaintiff's phone cases and the patented design significant enough to avoid a finding of infringement?
- A question of validity over prior art: Is the ornamental design of the ’730 Patent novel and non-obvious in light of the prior art, particularly the specific Chinese design patents cited by the Plaintiff?
- A question of effective filing date: Did the invalidation of the Chinese priority application render the ’730 Patent's priority claim defective? The answer will determine the universe of prior art that can be asserted against the patent and may be dispositive of the validity issue.