DCT
1:25-cv-10395
Shenzhen Haorun E Commerce Co Ltd v. Shenzhen Lanhe Tech Co Ltd
Key Events
Complaint
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., 12/20/2025
- 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 mobile phone cases 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 segment of the consumer electronics accessories market.
- Key Procedural History: The complaint alleges that this lawsuit was precipitated by Defendant filing multiple infringement complaints on Amazon.com against Plaintiff's products, which resulted in the removal of Plaintiff's listings. The complaint also challenges the validity of the patent's priority claim, alleging the foreign priority application was invalidated by the Chinese Patent Office.
Case Timeline
| Date | Event |
|---|---|
| 2022-02-08 | ’730 Patent Priority Date (from CN 307319077S) |
| 2024-06-11 | ’730 Patent Issue Date |
| 2025-12-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,030,730 S - “Case for Mobile Phone”
The Invention Explained
- Problem Addressed: Design patents protect new, original, and ornamental designs for articles of manufacture. The goal is to secure rights to a unique aesthetic appearance rather than to solve a technical problem.
- The Patented Solution: The patent claims the specific ornamental design for a mobile phone case as depicted in its figures (’730 Patent, CLAIM). The design's claimed features, shown in solid lines, include a rectangular case body with rounded corners, a raised rectangular camera cutout with rounded corners, and a circular ring structure on the back that serves as a stand, as shown in an open state in Figure 9 (’730 Patent, FIG. 1, 3, 9). The patent uses broken lines to disclaim the overall shape of a mobile phone and other features, indicating they are not part of the claimed design (’730 Patent, DESCRIPTION).
- Technical Importance: In the crowded mobile accessory market, a distinct ornamental design can be a significant product differentiator and source of brand identity.
Key Claims at a Glance
- The patent asserts a single claim for "the ornamental design for a case for mobile phone, as shown and described" (’730 Patent, CLAIM).
- The essential visual elements of this single claim, depicted in solid lines in the patent's figures, are:
- The overall configuration and shape of the phone case.
- A raised, rectangular camera bezel with rounded corners.
- A circular ring assembly on the rear of the case, including its hinge portion.
- The appearance of the ring functioning as a stand when opened.
III. The Accused Instrumentality
Product Identification
- Plaintiff’s "electroplating iPhone cases with stands" sold on Amazon.com under various ASINs, including B0F7XBQSFR and B0F7X4K1F4 (Compl. ¶1, 8).
Functionality and Market Context
- The complaint provides minimal detail regarding the specific design of the accused products (Compl. ¶1, 13). It describes them generally as cases with stands for iPhones and alleges that they were subject to removal from Amazon's marketplace following infringement complaints filed by the Defendant (Compl. ¶7-8). The complaint asserts that the accused products differ from the patented design in their "contour, proportion, and ornamental arrangement" (Compl. ¶13). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
This is a declaratory judgment action for non-infringement. The analysis below summarizes the Plaintiff’s asserted points of non-infringement against the patented design. The complaint does not contain a claim chart or specific visual comparisons.
| Key Ornamental Feature of the ’730 Patent | Plaintiff's Allegation of Non-Infringement | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall ornamental design for a case for mobile phone, as shown and described. | Plaintiff alleges its product designs differ in "contour, proportion, and ornamental arrangement" from the claimed design. | ¶13 | CLAIM |
| The specific shape and configuration of the case, camera bezel, and ring stand shown in solid lines. | Plaintiff alleges that under the "ordinary observer" test, its products are not "substantially the same" as the patented design. | ¶12 | FIG. 1-9 |
- Identified Points of Contention:
- Scope Questions: A central issue will be the scope of the claimed design, particularly in light of the patent's use of broken lines to disclaim certain features. The dispute may turn on whether the claimed design, limited to the features shown in solid lines, is narrow enough that the alleged differences in the Plaintiff's products are sufficient to avoid infringement (’730 Patent, DESCRIPTION).
- Visual Comparison Questions: The core test for design patent infringement is 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 alleges differences exist but provides no visual evidence of its own product, raising the question of what specific differences in "contour, proportion, and ornamental arrangement" will be presented to the court (Compl. ¶12-13).
V. Key Claim Terms for Construction
In design patent litigation, the claim is understood through the drawings rather than textual terms. The critical interpretive exercise involves distinguishing claimed from unclaimed subject matter.
- The "Term": The scope of the design as defined by solid vs. broken lines.
- Context and Importance: This distinction is fundamental to the infringement analysis. Features shown in broken lines are for illustrative context only and do not limit the claim. The infringement analysis must focus only on the ornamental features shown in solid lines. Practitioners may focus on this because the extensive use of broken lines could suggest a narrower patent scope that is easier to design around.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the overall visual impression is what is protected, focusing on the combination and arrangement of the solid-line features (the case shape, camera bezel, and ring stand) as a whole.
- Evidence for a Narrower Interpretation: The patent specification explicitly states, "The broken lines depict portions of the case for mobile phone that form no part of the claimed design" (’730 Patent, DESCRIPTION). This language provides a strong basis to argue that protection is limited only to the specific ornamental features depicted in solid lines, and any accused product that omits or alters one of these features may create a different overall visual impression.
VI. Other Allegations
- Invalidity and Unenforceability: The complaint seeks a declaration that the ’730 Patent is invalid under 35 U.S.C. §§ 102 and 103 for lacking novelty and non-obviousness in view of prior art, including Chinese Design Patents CN306814663S and CN306996237S (Compl. ¶15). It further alleges the patent is invalid because its priority claim to a Chinese application is defective, as that application was allegedly invalidated (Compl. ¶16). The complaint also asserts the patent is unenforceable due to inequitable conduct for an alleged failure 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 validity: Does the cited prior art, particularly the identified Chinese design patents, render the ’730 Patent's design anticipated or obvious? A related threshold question is whether the patent's priority claim is defective, which would expose it to a broader range of invalidating prior art.
- The central infringement question will be one of visual comparison: Once the accused product's design is presented, would an ordinary observer, taking into account the prior art and the limited scope defined by the patent's solid lines, find the overall visual appearance of the Plaintiff's product to be substantially the same as the patented design?
- A key procedural question will be one of enforceability: Does the allegation of failing to disclose prior art during prosecution rise to the level of inequitable conduct, potentially rendering the entire patent unenforceable?