DCT

7:25-cv-05902

Shenzhen Ecoflow Inc v. Medi Products

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-05902, S.D.N.Y., 07/23/2025
  • Venue Allegations: Venue is alleged to be proper as Defendants have a principal place of business in the Southern District of New York, and the alleged acts of infringement occurred within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s SAVERCELL BATTERY BACKUP SYSTEMS infringe a design patent for a portable power supply unit.
  • Technical Context: The technology involves portable, high-capacity battery backup systems, a growing market for consumer, professional, and emergency power needs.
  • Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2021-02-08 U.S. Patent No. D988,261 Priority Date
2023-06-06 U.S. Patent No. D988,261 Issue Date
2025-07-23 Complaint Filing Date

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

U.S. Patent No. D988,261 - “POWER SUPPLY UNIT”

  • Patent Identification: U.S. Patent No. D988,261, “POWER SUPPLY UNIT,” issued June 6, 2023.

The Invention Explained

  • Problem Addressed: Design patents protect the way an article looks, not how it works. The patent does not articulate a functional problem but instead provides a new, original, and ornamental design for a power supply unit (’261 Patent, Claim).
  • The Patented Solution: The patent claims the specific ornamental appearance of a portable power supply unit as depicted in its drawings (’261 Patent, Claim). The design consists of a generally rectangular housing with rounded vertical edges, a flat top surface, and two integrated, outwardly flared handles on the short sides that extend above the top surface (D’261 Patent, Fig. 1.7). Key ornamental features include the specific arrangement of horizontal vents on the front and back panels, and the defined layout of ports and controls on the side panels (D’261 Patent, Figs. 1.1-1.4). The complaint characterizes these features as creating a "unique configuration, shape, proportions, and surface ornamentation" (Compl. ¶14).
  • Technical Importance: The complaint alleges that the patented design provides a "unique" overall visual impression, which serves to distinguish the product in the marketplace (Compl. ¶14).

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is: "The ornamental design for a power supply unit, as shown and described." (’261 Patent, Claim).
  • The scope of a design patent claim is defined by its drawings. The essential elements are the visual characteristics of the power supply unit as shown in Figures 1.1 through 1.13 of the patent.

III. The Accused Instrumentality

Product Identification

  • The SAVERCELL BATTERY BACKUP SYSTEMS ("Accused Product") sold by Medi-Products and promoted by Medicanix (Compl. ¶2, ¶9).

Functionality and Market Context

  • The complaint identifies the Accused Product as a "battery backup system" (Compl. ¶1). For the purposes of design patent infringement, its most relevant feature is its external appearance. The complaint provides photographic evidence of the Accused Product, depicting a portable power unit with a dark grey housing, integrated side handles, and specific layouts for vents and power ports (Compl. ¶19). The complaint alleges that parent company Medicanix promotes these systems to "healthcare professionals" (Compl. ¶30). A side-by-side comparison of the Accused Product and the patented design is provided to illustrate their alleged visual similarity (Compl. ¶19). This comparison shows the Accused Product's back panel, which features a large vented area with two circular fans, alongside a similar view from the patent's drawings (Compl. ¶19, p. 5).

IV. Analysis of Infringement Allegations

The infringement allegation for a design patent rests on the "ordinary observer" test, which asks whether an ordinary observer would find the total ornamental appearance of the accused product to be substantially the same as the patented design. The complaint presents its allegations via a side-by-side visual comparison.

’261 Patent Infringement Allegations

Claim Element (Visual Feature from Patent Drawings) Alleged Infringing Functionality (from Accused Product) Complaint Citation Patent Citation
The overall ornamental design for a power supply unit, including its generally rectangular housing with integrated, flared handles on the short sides. The Accused Product embodies a substantially identical overall shape, including a rectangular housing with integrated, flared handles. A photograph shows the Accused Product's front panel and handle profile next to the patent's corresponding drawing. ¶19 Fig. 1.3
The specific ornamental appearance of the front and back panels, including the pattern and placement of vents. The Accused Product's back panel features a large, horizontally-slatted vent section with two visible fans, which the complaint alleges is visually similar to the patented design. ¶19 Fig. 1.2
The ornamental layout of the right-side panel, including the arrangement of AC outlets, a circular DC port, and other controls. The Accused Product's right-side panel features a similar layout of multiple AC outlets, a circular DC port, and other controls, as depicted in a photograph placed next to the patent's drawing of that view. ¶19 Fig. 1.4
The ornamental appearance of the top view, showing the shape of the handles relative to the main housing. The top-down photograph of the Accused Product is presented as having the same overall outline and handle shape as the top view shown in the patent's drawings. ¶19 Fig. 1.5

Identified Points of Contention

  • Scope Questions: The primary dispute will likely center on whether the overall visual impression of the Accused Product is "substantially the same" as the patented design. A key question for the court will be the visual effect of features present on the Accused Product but not in the patent drawings, such as the prominent "SAVERCELL" and "MEDI-PRODUCTS" branding on the front and back (Compl. ¶19, p. 5).
  • Technical Questions: A potential point of contention is the extent to which the claimed design features are ornamental versus functional. A defendant may argue that elements like the placement of vents, the shape of the handles for portability, and the layout of standard electrical ports are dictated by function and should be discounted or "factored out" of the infringement analysis. The complaint preemptively asserts that the patent protects "non-functional ornamental aspects" (Compl. ¶14).

V. Key Claim Terms for Construction

In design patent cases, formal claim construction is rare, as the single claim refers to the drawings. However, disputes often arise over the scope of the design and the role of functionality.

  • The Term: "ornamental design for a power supply unit"
  • Context and Importance: The core legal question is what constitutes the "ornamental design." The outcome of the case may depend on whether the comparison between the patent and the Accused Product considers all visual features, or only those deemed "ornamental" after "factoring out" any features dictated purely by function. Practitioners may focus on this issue because separating ornament from function is a central battleground in design patent litigation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's drawings show all features of the power supply unit—including handles, vents, and port surrounds—in solid lines, which typically indicates that all depicted features are part of the claimed design (D'261 Patent, Figs. 1.1-1.13). Plaintiff will likely argue that the specific arrangement and combination of these features creates the overall ornamental impression, even if some elements serve a function.
    • Evidence for a Narrower Interpretation: There is no explicit evidence for a narrower interpretation within the patent file itself. However, a defendant would argue, based on general principles of design patent law, that features essential to the use or purpose of the article are functional. They may argue that the need for cooling dictates the vents, ergonomics dictate the handle shape, and industry standards dictate the port arrangements, and therefore these elements cannot be the basis of a design patent infringement claim.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement against Medicanix, stating it encourages infringement by customers and its subsidiary (Medi-Products) through "promotional and marketing materials, instructional manuals," and its website (Compl. ¶¶29-30). It also alleges contributory infringement, claiming Medicanix provides a product "specially made and/or specially adapted for infringing use" with "no substantial non-infringing use" (Compl. ¶¶37-38).
  • Willful Infringement: The complaint makes conclusory allegations of willful infringement against both Defendants "on information and belief" (Compl. ¶¶25, 33). No specific facts supporting pre-suit knowledge of the patent are alleged.

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

This case appears to hinge on classic design patent principles applied to a commercial product. The central questions for the court will likely be:

  • A core issue will be one of visual comparison: From the perspective of an ordinary observer, is the overall ornamental appearance of the accused SAVERCELL product substantially the same as the design claimed in the ’261 Patent, or are the visual differences—particularly the prominent branding on the accused product—sufficient to avoid a finding of infringement?
  • A key legal question will be one of functionality: To what extent are the shared visual features of the two products (e.g., handle shape, vent patterns, port layout) dictated by their function? The court's determination on which elements are ornamental versus functional will be critical in defining the scope of the patent's protection and the basis for the infringement comparison.