DCT
2:25-cv-04895
Shanghai Luyi Jiesheng Intl Trade Co Ltd v. Bo Do Ko USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shanghai Luyi Jiesheng International Trade Co., Ltd (China)
- Defendant: BDK, Bo Do Ko USA, Inc., Custom Auto Crews, Inc., Motorbox Inc, NBTEPEM, and Taizhou Weimin E-Commerce Co., Ltd. (California and China)
- Plaintiff’s Counsel: Law Office of Bole Yuan, Esq.
- Case Identification: 2:25-cv-04895, E.D. Pa., 08/26/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants target consumers and conduct substantial business in the district through the operation of online stores, including sales and shipping of the accused products.
- Core Dispute: Plaintiff alleges that Defendants’ universal-fit car floor mats infringe a U.S. design patent covering the ornamental design for a car floor mat.
- Technical Context: The dispute is in the field of automotive interior accessories, where ornamental design can be a significant market differentiator.
- Key Procedural History: The complaint notes that the patent was assigned to the Plaintiff from the inventor, Chang'E Peng. No other procedural events, such as prior litigation or administrative challenges, are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2023-07-05 | D'565 Patent Priority Date |
| 2025-05-06 | ’565 Patent Issue Date |
| 2025-08-26 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,073,565 - "Car Floor Mat," issued May 6, 2025
The Invention Explained
- Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its utilitarian features. The patent does not describe a technical problem but instead provides a new, original, and ornamental design for a car floor mat.
- The Patented Solution: The patent claims the specific visual appearance of a car floor mat as depicted in its figures (D'565 Patent, Figs. 1-7). The claimed design consists of the mat's overall contoured shape, a raised peripheral border, and a distinct, recessed heel pad area containing several parallel, elongated elements oriented at an angle (D'565 Patent, Figs. 1, 2). The overall effect creates a unique aesthetic for the article.
- Technical Importance: In the market for automotive accessories, unique ornamental designs may contribute to brand identity and consumer appeal, which Plaintiff alleges has resulted in substantial goodwill (Compl. ¶¶28-29).
Key Claims at a Glance
- Design patents contain a single claim, which in this case is for "The ornamental design for a car floor mat, as shown and described" (D'565 Patent, Claim).
- The key ornamental features defined by the solid lines in the patent drawings include:
- A generally rectangular but contoured overall shape with curved corners and indentations.
- A raised border that traces the periphery of the mat.
- A recessed, generally trapezoidal area serving as a heel pad.
- Within the heel pad, a series of elongated, parallel, raised ridges set at an oblique angle to the mat's primary axis.
III. The Accused Instrumentality
Product Identification
- "Motor Trend Waterproof Car Floor Mats Universal Fit Car Mats" and other car floor mats sold by Defendants through various online storefronts (Compl. ¶¶30-31).
Functionality and Market Context
- The accused products are described as car floor mats sold in the United States through e-commerce platforms like Amazon.com (Compl. ¶¶11, 24, 31). The complaint alleges that the Defendants operate as an "interconnected group" using multiple online brand names and storefronts to sell the accused products, which bear "common or similar design elements" to Plaintiff's patented design (Compl. ¶14). A screenshot from an online marketplace listing for the accused product is provided as an example of the infringing activity (Compl. ¶31, p. 8).
IV. Analysis of Infringement Allegations
The standard for design patent infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that the accused products embody the patented design or a colorable imitation thereof (Compl. ¶45). The complaint provides a side-by-side photograph comparing what appears to be an embodiment of the patented design with an accused product (Compl. ¶32, p. 8).
D'565 Patent Infringement Allegations
| Claim Element (Ornamental Feature) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall contoured shape of the car floor mat. | The accused product is alleged to have a substantially similar overall shape, including its contours and proportions. | ¶¶31-32 | Fig. 2 |
| A raised peripheral border tracing the mat's edge. | The accused product features a raised border along its periphery that creates a similar visual effect. | ¶¶31-32 | Fig. 1 |
| A distinct, recessed, generally trapezoidal heel pad area. | The accused product incorporates a recessed heel pad area in a similar location and of a similar shape. | ¶¶31-32 | Fig. 2 |
| A series of angled, elongated, parallel elements within the heel pad area. | The accused product's heel pad includes a set of angled, elongated ridges that allegedly create a visual impression substantially the same as the claimed design. | ¶¶31-32 | Fig. 2 |
- Identified Points of Contention:
- Scope Questions: The central legal and factual question will be whether the overall visual impression of the accused product is "substantially the same" as the patented design. The analysis will not focus on dissecting individual features but on the design as a whole.
- Technical Questions: While not a "technical" mismatch, a key visual question is whether any differences in the number, spacing, or angle of the heel pad ridges, or minor variations in the mat's overall contour, are sufficient to differentiate the accused product from the patented design in the mind of an ordinary observer. The complaint's photographic evidence directly invites this holistic comparison (Compl. ¶32, p. 8).
V. Key Claim Terms for Construction
Claim construction for design patents is typically tied to the drawings as a whole, rather than the construction of specific text-based terms. The "claim" is the visual design itself.
- The Term: The overall ornamental design "as shown and described."
- Context and Importance: Infringement analysis will depend on the scope of the claimed design as a whole, not any single feature in isolation. The court's interpretation will focus on the overall visual impression conveyed by the patent's figures.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims the design for a "car floor mat" generally, which could suggest the design is not limited to a specific make or model of vehicle.
- Evidence for a Narrower Interpretation: The scope of protection is strictly defined by the visual features depicted in solid lines in the patent drawings (D'565 Patent, Figs. 1-7). Any deviation from the depicted proportions, contours, and surface ornamentation could support an argument of non-infringement.
VI. Other Allegations
- Indirect Infringement: The complaint does not specifically plead induced or contributory infringement. It alleges direct infringement through acts of making, using, importing, offering for sale, and selling products that embody the patented design (Compl. ¶45) and by applying the patented design to an article of manufacture for the purpose of sale (Compl. ¶46).
- Willful Infringement: Willfulness is alleged based on Defendants' alleged actual and constructive knowledge of the D'565 Patent (Compl. ¶¶39-41, 48). The complaint asserts that Plaintiff provides notice of its patent rights by marking its products with the patent number, which may serve as a basis for constructive knowledge (Compl. ¶¶25, 44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual comparison: will an ordinary observer, giving such attention as a purchaser usually gives, find that the accused "Motor Trend" floor mat design is "substantially the same" as the design claimed in the D'565 Patent, considering the design as a whole and not just its component parts?
- A critical evidentiary question, though not yet addressed in the complaint, will be the context of the prior art: how crowded is the design field for car floor mats? The density and nature of prior art designs will inform the scope of the patent and determine whether the similarities between the patented and accused designs are sufficient to support a finding of infringement.