DCT

2:25-cv-01197

Li v. Chongqingruikeweikejiyouxiangongsi

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01197, E.D. Tex., 12/09/2025
  • Venue Allegations: Venue is based on Defendants' alleged substantial commercial activity within the United States through sales on the Amazon.com marketplace.
  • Core Dispute: Plaintiff alleges that magnetic knife holders sold by Defendants infringe a U.S. design patent protecting the ornamental appearance of an asymmetric, dual-bar knife holder.
  • Technical Context: The dispute concerns the ornamental design of magnetic knife holders, a consumer kitchen product where visual appearance can be a significant factor in purchasing decisions.
  • Key Procedural History: The complaint states that the plaintiff is proceeding pro se due to cost and timing constraints and has not previously filed any lawsuits in federal or state court.

Case Timeline

Date Event
2023-05-25 ’819 Patent Priority Date
2025-08-05 ’819 Patent Issue Date
2025-08-12 Plaintiff purchases accused product
2025-12-09 Complaint Filing Date

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

U.S. Patent No. D1,086,819 S - "Magnetic Knife Holder"

The '819 Patent was issued on August 5, 2025.

The Invention Explained

  • Problem Addressed: As a design patent, the ’819 Patent does not address a technical problem but instead protects a specific, non-functional, ornamental design for an article of manufacture (D'819 Patent, Claim).
  • The Patented Solution: The patent protects the unique visual appearance of a magnetic knife holder. The complaint characterizes the core ornamental features as an "asymmetric two-bar configuration consisting of a larger upper rectangular bar and a smaller lower bar" (Compl. p. 2). The specific proportions, spacing, and overall visual relationship between these two parallel bars, as depicted in the patent's figures, constitute the claimed design (D'819 Patent, Fig. 1.1). The two struts connecting the bars are shown in broken lines, indicating they are environmental structure and not part of the claimed design (D'819 Patent, Fig. 1.2; Compl. p. 3).
  • Technical Importance: In the market for consumer goods like kitchen accessories, a distinctive ornamental design can serve as a key product differentiator and source of brand identity.

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is for "The ornamental design for a magnetic knife holder as shown and described" (D'819 Patent, p. 3).
  • The core ornamental features "as shown" in the patent drawings include:
    • A dual-bar configuration.
    • An asymmetric relationship where the upper bar is larger in mass and dimension than the lower bar.
    • A specific proportional and spatial relationship between the two bars.
    • Rectangular cross-sections for both the upper and lower bars.

III. The Accused Instrumentality

Product Identification

Magnetic knife holders sold by Defendants on their Amazon.com storefronts, specifically identified by Amazon ASIN B0D8TN7KNB (Compl. p. 2).

Functionality and Market Context

The complaint alleges that the accused products are magnetic knife holders that adopt the "same upper-large / lower-small dual-bar design" as claimed in the ’819 Patent (Compl. p. 2). Based on a physical examination, the plaintiff alleges the accused products copy the "asymmetric dual-bar structure, bar proportions, relative spacing, and front/top/bottom visual appearance" of the patented design, creating a "substantially identical overall visual impression" (Compl. p. 2). The complaint notes that the accused product sold by both defendants is identical (Compl. pp. 2-3).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

Claim Chart Summary

Design patent infringement is assessed under the "ordinary observer" test, which asks whether an ordinary observer would believe the accused design is the same as the patented design. The complaint's allegations can be mapped to the core ornamental features as follows:

D'819 Patent Infringement Allegations

Claim Element (Key Ornamental Feature from Figures) Alleged Infringing Functionality Complaint Citation Patent Citation
An asymmetric configuration of a larger upper bar and a smaller lower bar. The accused product "adopt[s] the same upper-large / lower-small dual-bar design." ¶6 Fig. 1.1
The specific proportions and spacing between the upper and lower bars. The accused product "copies the same...bar proportions, relative spacing...visual appearance." ¶6 Figs. 1.3, 1.5
The overall visual impression created by the combination of ornamental features. The accused product presents a "substantially identical overall visual impression to that of USD1086819S." ¶6 Figs. 1.1-1.8

Identified Points of Contention

  • Scope Question: The complaint preemptively identifies a key difference: "Defendants changed the lower bar from a square cross-section to a circular one" (Compl. p. 3). This raises the primary legal question of whether this modification is sufficient to create a visually distinct design in the eyes of an ordinary observer, or if it is an "immaterial" modification as the complaint alleges (Compl. p. 3).
  • Design Question: The dispute will focus on whether the change in the lower bar's geometric profile from rectangular to circular alters the "dominant overall visual impression" allegedly created by the asymmetric proportions and arrangement of the bars (Compl. p. 2).

V. Key Claim Terms for Construction

In design patent litigation, there are typically no "terms" to construe; the analysis focuses on the scope of the design as depicted in the drawings. The central issue here is the scope of the claimed visual features.

  • The "Term": The ornamental design of the "lower bar" as shown in the patent figures.
  • Context and Importance: The primary distinction between the patented design and the accused product lies in the cross-sectional shape of this specific feature. The outcome of the case may depend on whether the claimed design is limited to the exact rectangular geometry shown or if it is broad enough to cover minor variations like a circular profile.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that the dominant visual impression of the design is the "upper-large / lower-small bar relationship, including their relative proportions, massing, [and] alignment," as the complaint suggests (Compl. p. 2). Under this view, the precise cross-sectional geometry of the smaller element is a minor detail that does not alter the overall aesthetic that an ordinary observer would perceive.
    • Evidence for a Narrower Interpretation: The patent drawings consistently and unambiguously depict the lower bar with a square or rectangular cross-section from all angles (D'819 Patent, Figs. 1.1, 1.3, 1.5, 1.7). A party could argue that these specific geometric details are integral to the design "as shown and described," and that changing a core shape from rectilinear to circular creates a patentably distinct design.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

  • The Ordinary Observer Test: The central issue will be a direct application of the ordinary observer test: is the accused product's design, with its circular lower bar, substantially the same as the patented design with its rectangular lower bar, such that an ordinary purchaser would be deceived? The complaint's assertion that the change is "immaterial" will be directly tested (Compl. p. 3).
  • Scope of Design Protection: The case will question the scope of protection afforded by the ’819 Patent. A key determination will be whether the patent's claim to the design "as shown" is strictly limited to the precise geometric forms depicted, or if it also protects the broader design concept of an asymmetrically proportioned dual-bar holder against colorable variations.