Lfa Co Ltd v. Scarman LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LFA Co., Ltd. (Taiwan)
  • Defendant: Scarman LLC (Texas)
  • Plaintiff’s Counsel: Inhouse Co. Law Firm
• Case Identification: 3:26-cv-00205, N.D. Tex., 01/27/2026
• Venue Allegations: Venue is based on Defendant Scarman LLC having a regular and established place of business within the Northern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s aftermarket tail lights, designed for certain Ford Ranger models, infringe a design patent covering the ornamental appearance of an automobile tail light.
• Technical Context: The case concerns the aftermarket automotive parts industry, where the unique ornamental design of components like tail lights is a significant factor in consumer purchasing decisions.
• Key Procedural History: The complaint notes that Plaintiff acquired all rights to the patent-in-suit on December 16, 2025, approximately six months before the patent issued. No other prior litigation, licensing history, or administrative proceedings are mentioned.

Case Timeline

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

U.S. Design Patent No. D1,079,991 - Automobile Tail Light

The Invention Explained

• Problem Addressed: As a design patent, the ’991 Patent does not address a functional or technical problem. Its purpose is to protect a novel, non-obvious ornamental design for an article of manufacture.
• The Patented Solution: The patent claims the specific visual appearance of an automobile tail light as depicted in its figures '991 Patent, Claim The claimed design consists of the features shown in solid lines, including a vertically oriented, generally rectangular housing with rounded corners, an outer C-shaped light element, and two distinct rectangular light arrays positioned inside the "C" '991 Patent, Figs. 1-2 The patent explicitly disclaims features shown in broken lines, such as the internal circular patterns representing individual light sources, as environmental structure not forming part of the claimed design '991 Patent, Description
• Technical Importance: The design provides a distinct aesthetic for an automotive component, which is a key market differentiator in the aftermarket vehicle parts industry.

Key Claims at a Glance

• The patent contains a single claim for "The ornamental design for an automobile tail light, as shown and described" '991 Patent, Claim
• The essential visual elements of this single claim, depicted in solid lines in the patent's figures, include:
  • The overall shape and proportions of the tail light housing.
  • A continuous, C-shaped light element defining the primary illuminated border.
  • Two separate, horizontally oriented rectangular light clusters located within the C-shaped element.
  • A recessed rectangular area at the bottom of the assembly.

III. The Accused Instrumentality

Product Identification

The accused products are aftermarket "Tail Lights Compatible with 2001-2011 Ford Ranger," specifically identified as the "KUAFU LH & RH Tail Light Compatible with 2001-2011 Ford Ranger LED C Light Bar Rear Brake Tail Lamp Assembly Plastic (Clear Lens+Chrome Housing)" Compl. ¶¶9-10

Functionality and Market Context

The complaint describes the Accused Products as replacement tail light assemblies for specific Ford Ranger truck models, sold to consumers through online marketplaces such as Amazon.com Compl. ¶¶7, 10 The allegations center entirely on the ornamental appearance of the products, which the complaint presents as "nearly identical" to the patented design through photographic evidence Compl. ¶17, pp. 7-9 The complaint includes a side-by-side comparison chart contrasting patent figures with photographs of the Accused Product to illustrate the alleged similarity Compl. pp. 7-9

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Product infringes the single claim of the ’991 Patent under the "ordinary observer" test, asserting that an ordinary purchaser would be deceived by the similarity between the products Compl. ¶¶17, 21 As this is a design patent case, a traditional claim chart is not applicable. The core of the allegation is a visual comparison. The side-by-side chart provided in the complaint juxtaposes patent drawings with product photos from multiple angles. The front view comparison shows a similar overall housing shape and arrangement of light elements Compl. p. 7

Identified Points of Contention

• Scope Questions: The central question will be whether, in the eye of an ordinary observer, the Accused Product's design is substantially the same as the design claimed in the ’991 Patent. The analysis will depend on the overall visual impression, not on a side-by-side dissection of minor differences.
• Technical Questions: A potential point of dispute may arise from differences between the patent's line drawings and the physical embodiment of the Accused Product. A defendant could argue that variations in surface contour, material texture, or the appearance of un-illuminated components create a different overall visual impression, while the plaintiff will likely argue these are trivial differences that do not alter the substantially similar impression.

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is understood to be the design itself as depicted in the drawings. Formal claim construction of terms is rare. Instead, the focus is on identifying the scope of the claimed design based on the drawings.

• The "Term": The overall ornamental design as shown in solid lines in Figures 1-7.
• Context and Importance: The entire infringement analysis rests on a comparison of the overall visual appearance of the Accused Product to the claimed design. The scope is defined by what is shown in solid lines versus what is disclaimed in broken lines.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party may argue that the claim covers any tail light with the same overall visual impression, characterized by the combination of the housing shape, the C-shaped element, and the two internal rectangular clusters. The explicit disclaimer of the internal LED arrangement via broken lines '991 Patent, Fig. 2; Description suggests the claim is not limited to a specific number or style of light sources within the claimed solid-line shapes.
  • Evidence for a Narrower Interpretation: A party could argue that the precise curvature, proportions, and interrelation of the solid-line features are critical to the patented design. Any deviation in the Accused Product from these specific details, it might be argued, is sufficient to create a different overall visual impression for the ordinary observer.

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation that Defendants "intentionally sell, ship, or otherwise deliver the Accused Products" with knowledge of infringement Compl. ¶23 However, it does not plead specific facts to support a claim for induced or contributory infringement, such as instructing end-users on an infringing use.
• Willful Infringement: The complaint alleges that Defendants have knowledge of infringement "since at least the filing of this complaint," which would support a claim for post-suit willfulness Compl. ¶15 Critically, it also alleges that "Defendants copied the design of the Accused Products from the tail light design of the ’991 Patent" Compl. ¶16 If proven, this allegation of direct copying would be strong evidence supporting a finding of pre-suit willful infringement.

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

• A core issue will be one of visual identity: From the perspective of an ordinary observer, giving the attention a purchaser usually gives, is the accused tail light's design substantially the same as the overall ornamental design claimed in the ’991 Patent, such that the observer would be induced to purchase one supposing it to be the other?
• A key evidentiary question will be one of intent: Can the plaintiff produce evidence to support its allegation that the defendant directly copied the patented design? Such evidence would be highly influential for both the infringement analysis under the ordinary observer test and the determination of willfulness.
• A final question relates to the scope of the claimed design: The case may turn on whether any identifiable differences between the Accused Product and the patent drawings are legally significant or are merely minor variations in features that are either disclaimed (e.g., the specific LED patterns shown in broken lines) or trivial to the design's overall visual impression.