DCT

0:25-cv-12423

Jameson LLC v. Shanghaijialeshiyeyouxiangongsi

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:25-cv-12423, D.S.C., 09/09/2025
  • Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and can be sued in any judicial district. Further allegations include that Defendant committed acts of infringement in the district and that Plaintiff, which has a significant presence there, is being harmed in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s "Heavy Duty Reel Buck" product infringes a design patent covering the ornamental appearance of a reel buck apparatus.
  • Technical Context: The dispute concerns industrial equipment designed to hold and dispense large, heavy reels of cable, commonly used in the telecommunications and construction industries.
  • Key Procedural History: The asserted design patent is a continuation of a prior U.S. utility patent application. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date Event
2023-11-28 'D448 Patent Priority Date (filing date of parent application)
2025-05-06 U.S. Design Patent No. D1,073,448 Issues
2025-09-09 Complaint Filed

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

U.S. Design Patent No. D1,073,448 - "Reel Buck Apparatus"

  • Patent Identification: U.S. Design Patent No. D1,073,448, titled "Reel Buck Apparatus", issued May 6, 2025 (’D448 Patent).

The Invention Explained

  • Problem Addressed: Design patents protect ornamental appearance, not function. However, the underlying article of manufacture, a "reel buck," is a tool used in the telecommunications and cable installation fields to manage large, heavy spools of material (Compl. ¶7, ¶19).
  • The Patented Solution: The 'D448 Patent claims the specific ornamental design for a reel buck apparatus. The design, depicted in a single exploded-view FIGURE, consists of a collection of tubular metal components that assemble into a stand, including two A-frame style upper supports, multiple vertical legs, and a central axle bar (’D448 Patent, FIGURE). The overall visual impression is one of an industrial, modular, and skeletal framework.
  • Technical Importance: The complaint alleges that Plaintiff's commercial embodiment of the design is a portable, durable, and efficient tool capable of supporting cable reels weighing up to 1,000 pounds (Compl. ¶8, ¶19).

Key Claims at a Glance

  • Design patents contain a single claim, which is pictorial rather than textual. The 'D448 Patent asserts one claim: "The ornamental design for a reel buck apparatus as shown and described" (’D448 Patent, p. 3). The scope of this claim is defined by the solid lines in the drawing figure.

III. The Accused Instrumentality

Product Identification

  • Defendant’s "Heavy Duty Reel Buck" (also marketed as an "Adjustable Wire Spool Rack" and "Detachable Welded Cable Caddy") (Compl. ¶1, ¶22, Exhibit 4).

Functionality and Market Context

  • The Accused Product is described as a steel wire dispenser for holding cable reels, with a claimed load capacity of 1,000 pounds (Compl., Exhibit 4). The complaint alleges it is sold through online retailers, such as Amazon, directly to customers in the United States, including within the District of South Carolina (Compl. ¶13, ¶22-23). The complaint presents evidence that the Accused Product is sold for $239.99, while Plaintiff's own product is sold for $374.99 (Compl. ¶21, ¶22).

IV. Analysis of Infringement Allegations

The standard for infringement of a design patent is the "ordinary observer" test, which asks 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 that this test is met (Compl. ¶29).

Plaintiff alleges that the 'D448 Patent "create the same visual impression as they are both similarly sized reel buck apparatus with the same ornamental design, disassembled into a similar number of pieces for assembly by the end user" (Compl. ¶30). The core of the infringement allegation is that the Accused Product is "virtually identical to the design claimed" (Compl. ¶28).

The complaint provides a side-by-side visual comparison to support this claim, juxtaposing the exploded view from the 'D448 Patent with a photograph of the disassembled Accused Product. This visual, presented on page 9 of the complaint, highlights the alleged similarities in the shapes, configurations, and arrangements of the constituent parts of the two designs (Compl. p. 9).

Identified Points of Contention

  • Overall Visual Impression: The central dispute will be whether the overall ornamental appearance of the Accused Product is substantially the same as that claimed in the 'D448 Patent. A defense may focus on any perceived differences in proportion, curvature, or surface ornamentation between the claimed design and the accused device.
  • Scope Questions: The 'D448 Patent's single FIGURE is an exploded view. A question may arise as to how this perspective influences the scope of the claimed design when compared to the Accused Product, which is sold disassembled but intended for use in an assembled state.

V. Other Allegations

Indirect Infringement

  • The complaint alleges that Defendant induces infringement by advertising the Accused Product and thereby encouraging end-users to assemble and use it in a manner that practices the patented design (Compl. ¶46).

Willful Infringement

  • Willfulness is alleged "upon information and belief," based on the asserted "substantial similarity" between the products and the way they are advertised. From this, the complaint infers that Defendant had knowledge of the 'D448 Patent and Plaintiff's corresponding commercial product before engaging in the accused conduct (Compl. ¶31, ¶43).

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

This case appears to center on a direct visual comparison common in design patent disputes. The key questions for the court will likely be:

  • A question of visual identity: From the perspective of an ordinary observer in the market for such equipment, is the overall ornamental design of Defendant’s "Heavy Duty Reel Buck" substantially the same as the design claimed in the 'D448 Patent, such that the observer would be deceived?
  • An evidentiary question on willfulness: Beyond the allegation of visual similarity, what evidence can be presented to establish that the Defendant had pre-suit knowledge of the specific 'D448 patent, a required element for a finding of willful infringement?
  • A question of remedy: If infringement is found, the case will raise questions about the appropriate measure of damages, including the potential for disgorgement of the infringer’s total profits under 35 U.S.C. § 289, a remedy unique to design patent infringement that the Plaintiff has requested (Compl. p. 13, ¶1.f).