4:26-cv-00015
Anjikepeijiajuchang v. Anji Younike Furniture Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Anjikepeijiajuchang dba Cinxzar-US (People's Republic of China)
- Defendant: Anji Younike Furniture Co., Ltd. (People's Republic of China)
- Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
- Case Identification: Anjikepeijiajuchang dba Cinxzar-US v. Anji Younike Furniture Co., Ltd., 4:26-cv-00015, E.D. Tex., 01/05/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant’s actions caused harm to Plaintiff in Texas, which is asserted to be Plaintiff's most significant market.
- Core Dispute: Plaintiff seeks a declaratory judgment that Defendant’s design patent for a chair is invalid as anticipated by prior art, following Defendant’s use of Amazon’s intellectual property reporting system to have Plaintiff’s competing products delisted.
- Technical Context: The dispute centers on the ornamental design of chairs sold in the competitive U.S. e-commerce furniture market, where product listings on dominant platforms like Amazon are critical for market access.
- Key Procedural History: The action was precipitated by Defendant lodging patent infringement complaints against Plaintiff on Amazon.com, leading to the removal of Plaintiff’s product listings. Plaintiff now seeks a court order declaring Defendant's patent invalid to resolve the dispute and compel the reinstatement of its products.
Case Timeline
| Date | Event |
|---|---|
| 2021-04-16 | Earliest customer review date for the alleged prior art "HOMHUM Product" |
| 2022-12-07 | D'441 Patent foreign application priority date |
| 2023-06-07 | D'441 Patent U.S. application filing date |
| 2025-11-11 | U.S. Design Patent No. D1,101,441 S issues |
| 2025-12-17 | Defendant initiates infringement complaints against Plaintiff on Amazon.com |
| 2026-01-05 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D1,101,441 S - "CHAIR"
- Patent Identification: U.S. Design Patent No. D1,101,441 S, titled "CHAIR," issued November 11, 2025 (the "D'441 Patent"). (Compl. ¶17, ¶19).
The Invention Explained
- Problem Addressed: As a design patent, the D'441 Patent does not describe or solve a technical problem; rather, it seeks to protect a new, original, and ornamental design for an article of manufacture—in this case, a chair. (D'441 Patent, Claim).
- The Patented Solution: The patent discloses and claims the specific aesthetic and visual characteristics of a chair design. The key ornamental features depicted in the figures include a continuous, upholstered shell forming both the seat and backrest, prominent parallel vertical seams running down the interior surface, a gently curved and reclined back, and a base composed of four slender, slightly angled legs. (D'441 Patent, Figs. 1, 3, 5).
- Technical Importance: The claimed design provides a distinct visual appearance for a chair, which can serve as a market differentiator in the highly competitive consumer furniture industry. (Compl. ¶14).
Key Claims at a Glance
- The complaint asserts that the entire design claimed in the D'441 Patent is invalid. (Compl. ¶27, ¶30). Design patents contain a single claim.
- Claim 1: "The ornamental design for a chair as shown and described." (D'441 Patent, Claim). The essential elements of this claim are the visual features of the chair as depicted in the patent’s eight figures, including:
- The overall shape and contour of the continuous seat and back shell.
- The pattern of parallel vertical seams on the seat and backrest.
- The configuration of the four slender, angled legs.
- The specific proportions and interrelation of these visual elements.
III. The Accused Instrumentality
Product Identification
Plaintiff's chair products sold on Amazon.com under the storefront "Cinxzar-US" and identified by a list of fifteen American Standard Identification Nos. ("ASINs"). (Compl. ¶12-13).
Functionality and Market Context
The complaint describes the products as chairs sold through the Amazon Marketplace, which constitutes Plaintiff's "primary sales channel into the United States." (Compl. ¶14). The dispute centers on the ornamental appearance of these chairs, which Defendant alleged infringed the D'441 Patent, leading to their removal from the marketplace by Amazon. (Compl. ¶5, ¶15).
IV. Analysis of Invalidity Allegations
The complaint’s central cause of action is for a declaratory judgment of invalidity, arguing that the claimed design was publicly known before the D'441 Patent's priority date. The core of this allegation is that the "HOMHUM Product," a chair sold on Amazon, constitutes invalidating prior art under 35 U.S.C. § 102. (Compl. ¶22). The complaint provides a side-by-side visual comparison of the D'441 Patent's line drawing and a photograph of the "HOMHUM Chair" to support its assertion of similarity. (Compl. p. 6).
D'441 Patent Invalidity Allegations
| Ornamental Feature (from D'441 Patent) | Allegedly Anticipating Feature (from HOMHUM Product) | Complaint Citation | Patent Citation |
|---|---|---|---|
| Four slender, slightly angled legs as the base | Both designs are chairs with four slender, slightly angled legs as the base. | ¶24 | D'441 Patent, Fig. 1 |
| The seat is upholstered | Both designs feature an upholstered seat. | ¶24 | D'441 Patent, Fig. 1 |
| The back and seat form a continuous piece | In both designs, the back and seat form a continuous piece. | ¶24 | D'441 Patent, Fig. 5 |
| Parallel vertical seams running from the top of the backrest down across the interior surface of the seat | Both designs feature parallel vertical seams running along the interior surface of the seat and backrest. | ¶24 | D'441 Patent, Fig. 3 |
| The backrest is gently reclined | Both designs feature a gently reclined backrest. | ¶24 | D'441 Patent, Fig. 6 |
- Identified Points of Contention:
- Scope Questions: A threshold issue will be whether the "HOMHUM Product" qualifies as prior art. This raises the factual question of whether Plaintiff can prove with sufficient evidence (such as sales records or archived web pages) that the HOMHUM chair was "on sale" or "otherwise available to the public" before the D'441 Patent's December 7, 2022 priority date, as alleged. (Compl. ¶23).
- Technical Questions: A central visual question is whether an "ordinary observer," giving such attention as a purchaser usually gives, would find the overall ornamental design of the HOMHUM Product to be substantially the same as the design claimed in the D'441 Patent. (Compl. ¶24). The analysis will involve comparing the visual impressions of the two designs as a whole.
V. Key Claim Terms for Construction
The complaint does not provide sufficient detail for analysis of key claim terms. In design patent litigation, the claim is typically understood to be the design as depicted in the patent's figures, and formal claim construction of verbal terms is rare. The dispute will likely focus on a visual comparison of the claimed design to the alleged prior art rather than on the definition of any particular word or phrase.
VI. Other Allegations
This section is not applicable as the complaint does not allege indirect or willful infringement against the Defendant; rather, it seeks a declaration of non-infringement and invalidity.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on two central questions for the court:
- A core issue will be one of prior art authentication: Can Plaintiff produce sufficient evidence to establish that the "HOMHUM Product" was publicly available and on sale in the United States before the D'441 Patent's priority date of December 7, 2022? The complaint's primary evidence is a screenshot of a customer review from 2021, the authenticity and probative value of which may be challenged.
- A second key question will be one of design identity: Assuming the HOMHUM Product is proven to be valid prior art, would an ordinary observer find its overall ornamental design to be substantially the same as the design claimed in the D'441 Patent, thereby rendering the patent invalid under 35 U.S.C. § 102?