DCT

4:25-cv-01007

Shenzhen Shenlaiyibi Intelligent Technology Co Ltd v. Shenzhenshihaoqingwangluokejiyouxiangongsi

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2021-04-20 Priority Date for ’654 and ’642 Patents
2022-04-12 U.S. Patent No. D948,642 Issued
2022-05-03 U.S. Patent No. D950,654 Issued
2022-05-26 Junhuang Xia employment with Plaintiff begins
2023-05-20 Junhuang Xia employment with Plaintiff ends
2023-07-10 Defendant US-UNNMIIY allegedly established by Xia
2025-09-15 Complaint Filed

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

U.S. Design Patent No. D950,654 - "Kettlebell"

The Invention Explained

  • Problem Addressed: As a design patent, the ’654 Patent does not address a technical problem but instead protects a "new, original, and ornamental design for an article of manufacture" (35 U.S.C. § 171). The purpose is to secure rights to a unique aesthetic for a kettlebell.
  • The Patented Solution: The patent claims the specific ornamental appearance of a kettlebell (D950654 Patent, Claim). The design features a handle with a distinctive rounded-trapezoidal shape that flows into a base, which connects to a body composed of several stacked, convex, disc-like weight elements, as depicted in the patent's figures (D950654 Patent, Fig. 1).
  • Technical Importance: The claimed design provides aesthetic differentiation in the competitive consumer market for home fitness equipment (Compl. ¶¶ 26-27).

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is: "The ornamental design for a kettlebell, as shown and described" (D950,654 Patent, Claim). This claim protects the overall visual appearance of the kettlebell illustrated in the patent drawings.

U.S. Design Patent No. D948,642 - "Barbell"

The Invention Explained

  • Problem Addressed: The ’642 Patent protects the ornamental design of a barbell, aiming to provide a unique visual identity rather than solving a functional problem (35 U.S.C. § 171).
  • The Patented Solution: The patent claims the ornamental design for a barbell, which consists of a central bar with an ergonomically contoured grip section, transitioning via distinct collars to narrower shafts for holding weights (D948642 Patent, Claim). An important aspect of the patent's scope is the use of broken lines to depict the weight plates and end nuts, indicating that these elements form the environment for the barbell but are not part of the claimed design (D948,642 Patent, Description). The protected design is limited to the features shown in solid lines, primarily the bar itself (D948,642 Patent, Fig. 3).
  • Technical Importance: The design provides a distinct aesthetic for a central component of an adjustable weight set, differentiating it from other products in the market (Compl. ¶¶ 26-27).

Key Claims at a Glance

  • The single asserted claim is: "The ornamental design for a barbell, as shown and described" (D948,642 Patent, Claim). This claim protects the visual appearance of the barbell bar as depicted in the solid lines of the patent's figures.

III. The Accused Instrumentality

Product Identification

Defendants' adjustable dumbbells, barbells, and kettlebells (Compl. ¶31). The complaint identifies numerous specific products by their Amazon Standard Identification Numbers (ASINs) and a TEMU Item ID (Compl. ¶32).

Functionality and Market Context

The accused products are modular fitness equipment that can be configured as dumbbells, barbells, or kettlebells by adding or removing weight plates (Compl. ¶31). The complaint alleges these products are sold through major e-commerce platforms, including Amazon.com and TEMU, to consumers throughout the United States (Compl. ¶¶ 4, 16). The complaint provides a representative image of an accused product, identified as ASIN B0CZ3HT6X6, configured as both a barbell and a kettlebell (Compl. p. 10).

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibits C and D, but these exhibits were not filed with the complaint. The infringement theory is therefore based on the narrative allegations and visual comparisons provided in the body of the complaint.

The core of the infringement allegation is that the accused products are "substantially the same" as the patented designs and would deceive an ordinary observer into believing they are the patented articles (Compl. ¶¶ 33, 50). To support this, the complaint presents a side-by-side visual comparison of a representative infringing product with figures from both patents-in-suit (Compl. p. 10). This visual shows the accused product, ASIN B0CZ3HT6X6, in a kettlebell configuration next to a figure from the ’654 Patent and in a barbell configuration next to a figure from the ’642 Patent, inviting a direct comparison of their overall appearances.

Identified Points of Contention

  • Scope Questions: For the ’642 Patent (Barbell), a central question will be the proper application of the "ordinary observer" test to a design where key components (the weight plates) are disclaimed via broken lines. The analysis must focus only on the claimed bar, raising the question of whether the accused bar is substantially similar to the patented bar design when isolated from the unclaimed weights.
  • Technical Questions: The primary question is factual: are the ornamental aspects of the accused products and the patented designs substantially similar? The court's analysis will involve comparing the overall visual impression, including shapes, contours, and proportions, while filtering out any features deemed purely functional. The complaint does not address the prior art, but its scope will be a critical factor in determining how similar the designs must be to support a finding of infringement.

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses less on defining words and more on determining the overall scope of the claimed design, including distinguishing ornamental features from functional ones.

  • The Term: "The ornamental design for a [kettlebell/barbell]"
  • Context and Importance: The entire dispute hinges on the scope of what is considered "ornamental" in the claimed designs. Practitioners may focus on this issue because if certain features are found to be dictated by function—for example, the threading that allows weights to be attached or the basic rounded shape of a weight plate for safety and roll-resistance—those features would be excluded from the infringement comparison. This could narrow the scope of the patent protection and make it more difficult to prove infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patents as a whole depict integrated designs with specific proportions and surface contours that create a unitary visual impression. A party could argue that this overall aesthetic is ornamental, even if individual components perform a function.
    • Evidence for a Narrower Interpretation: A party could argue that elements like the contoured grip on the barbell (’642 Patent, Fig. 3) or the general shape of the kettlebell handle (’654 Patent, Fig. 1) are primarily functional for ergonomic handling. The use of broken lines in the ’642 Patent to disclaim the weight plates is explicit evidence that the design of those plates is not part of the claimed "ornamental design" for the barbell itself.

VI. Other Allegations

Willful Infringement

The complaint alleges that infringement has been willful. This allegation is supported by two main assertions: (1) Defendants were put on notice of the patents-in-suit at least as of the filing of the complaint, making any subsequent infringement willful (Compl. ¶52); and (2) Defendants engaged in pre-suit willful conduct based on allegations that Defendant US-UNNMIIY was founded by a former employee of Plaintiff Shenlaiyibi who had knowledge of Plaintiffs' products and designs and established a competing business to sell "substantially similar" products shortly after his termination (Compl. ¶¶ 42-45).

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

This case appears to center on straightforward design patent and trade dress claims, but with a significant undertone of alleged misappropriation by a former employee. The key questions for the court will likely be:

  • A Question of Visual Deception: Is the overall ornamental appearance of Defendants' accused fitness equipment "substantially the same" as the designs claimed in the ’654 and ’642 patents from the perspective of an ordinary observer familiar with the prior art? The side-by-side comparisons in the complaint frame this as the central factual dispute.
  • A Question of Scope: To what extent are the visual features of the patented designs dictated by function? The court's determination of which elements are purely ornamental versus functional will be critical in defining the scope of patent protection and guiding the infringement analysis.
  • A Question of Intent: Do the facts surrounding the former employee support a finding that Defendants deliberately and willfully copied Plaintiffs' patented designs? The answer to this question will be central to the potential for enhanced damages and a finding that the case is exceptional.