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-10395, S.D.N.Y., 01/01/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts business in the district through e-commerce platforms like Amazon.com and has caused injury to Plaintiff within the district.
• 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 accessory market where visual appearance is a key differentiator.
• Key Procedural History: The complaint alleges that Defendant filed multiple infringement complaints on Amazon.com against Plaintiff's product listings, leading to their removal. Plaintiff further alleges that the patent's priority claim is defective due to the invalidation of the priority application by the Chinese Patent Office, and that the patent is unenforceable for inequitable conduct during prosecution.

Case Timeline

Date	Event
2022-02-08	'730 Patent Priority Date (via CN App. 202230065055.6)
2024-06-11	'730 Patent Issue Date
2026-01-01	Complaint Filing Date

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

• Patent Identification: U.S. Design Patent No. D1,030,730 S, titled “Case for Mobile Phone,” issued on June 11, 2024.

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its utilitarian features. The '730 Patent does not describe a technical problem but instead presents a specific aesthetic design for a mobile phone case. (’730 Patent, p. 3 CLAIM).
• The Patented Solution: The patent claims the specific ornamental design for a mobile phone case as depicted in its figures. Key visual features shown in solid lines include the overall rectangular shape with rounded corners, a large rounded-square camera cutout, a prominent circular element on the back (resembling a magnetic charging interface), and a finger-ring stand integrated into the lower portion of the circular element. (’730 Patent, FIGS. 1, 3, 9). The design explicitly disclaims, via broken lines, the unadorned aspects of the phone case that are not part of the claimed design. (’730 Patent, p. 3 DESCRIPTION).
• Technical Importance: The design combines several contemporary functional elements—a protective case, a magnetic charging-compatible element, and a kickstand/grip—into a single, unitary ornamental appearance. (’730 Patent, FIGS. 1, 9).

Key Claims at a Glance

• The patent asserts a single claim: “The ornamental design for a case for mobile phone, as shown and described.” (’730 Patent, p. 3 CLAIM).
• The scope of this claim is defined by the visual representations in the patent's figures. Key ornamental features constituting the design include:
  • The specific proportions and contours of the case body.
  • The size, shape, and placement of the camera cutout.
  • The visual appearance of the circular element on the case back.
  • The specific shape, attachment point, and deployed configuration of the integrated ring stand.

III. The Accused Instrumentality

Product Identification

• Plaintiff’s “electroplating iPhone cases with stands.” (Compl. ¶1).

Functionality and Market Context

• The complaint describes the products at a high level as mobile phone accessories sold on e-commerce platforms such as Amazon.com. (Compl. ¶¶1, 3, 7-8).
• The complaint does not provide specific visual or descriptive details of the accused products’ designs beyond their general category.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement and therefore does not contain a claim chart alleging infringement. Instead, it presents a narrative theory of non-infringement. Plaintiff asserts that under the "ordinary observer" test, its products would not be found to be "substantially the same as the claimed design" when viewed in light of the prior art. (Compl. ¶12). The basis for this assertion is that the Plaintiff’s designs allegedly differ from the patented design in their "contour, proportion, and ornamental arrangement." (Compl. ¶13).

• Identified Points of Contention:
  • Scope Questions: The central issue will be whether the visual differences alleged by the Plaintiff are significant enough to lead an ordinary observer to distinguish its products from the patented design.
  • Technical Questions: A key factual question will be the specific visual appearance of the accused products. The court will need to compare the overall visual impression of Plaintiff’s products with the specific ornamental features shown in the solid lines of the '730 Patent's figures.

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses on the visual scope of the design as depicted in the drawings, rather than on interpreting textual terms.

• The Term: "The ornamental design for a case for mobile phone, as shown and described."
• Context and Importance: The interpretation of the patent's figures is the central issue in determining the scope of the claimed design. This visual scope is the benchmark against which the accused products are compared under the "ordinary observer" test for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that the claim covers any design with the same overall visual impression, focusing on the combination of the large camera cutout, back circle, and integrated ring stand, and de-emphasizing minor variations in proportion or curvature.
  • Evidence for a Narrower Interpretation: A party could argue that the claim is limited to the precise shapes and proportions shown in the figures, pointing to specific details like the exact curvature of the corners, the precise shape of the ring stand, and the specific junction between the stand and the circular element as essential features of the claimed design. (’730 Patent, FIGS. 1, 9). The use of broken lines to disclaim certain features also serves to narrow the scope of the claimed design to only what is depicted in solid lines. (’730 Patent, p. 3 DESCRIPTION).

VI. Other Allegations (Invalidity and Unenforceability)

• Invalidity: Plaintiff alleges 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). The complaint also asserts a critical challenge to the patent's effective filing date, alleging the priority claim to a Chinese application is "defective" because that application was "invalidated by the Chinese Patent Office." (Compl. ¶16).
• Unenforceability: Plaintiff alleges the '730 Patent is unenforceable due to inequitable conduct, based on an alleged "lack of candor in failing to disclose relevant prior art during prosecution." (Compl. ¶18).

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

1. A Threshold Question of Priority: Will the Defendant’s priority claim to the February 8, 2022 Chinese application withstand the Plaintiff’s challenge that the underlying application is invalid? The resolution of this issue is critical, as it will determine the universe of prior art that can be asserted against the '730 Patent.
2. A Visual Question of Infringement: Applying the "ordinary observer" test, is the overall ornamental design of Plaintiff’s "electroplating iPhone cases with stands" substantially the same as the design claimed in the '730 Patent? This will require a side-by-side visual comparison focused on the similarities and differences in the overall aesthetic impression created by the two designs.
3. An Evidentiary Question of Validity: Assuming the priority date is established, do the cited Chinese design patents, or other prior art, disclose a design so similar to the one claimed in the '730 Patent as to render it obvious or not novel to a designer of ordinary skill?