DCT
1:25-cv-01815
Dai v. Corps Partnerships Unincorp Associations Ldentified On Schedule A
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Chaohua Dai (China)
- Defendant: Shenzhen Juyuansheng Zhineng Keji Youxian Gongsi d/b/a ShouldYaoWang – Globe (China)
- Plaintiff’s Counsel: Valley & Summit Law
- Case Identification: 1:25-cv-01815, W.D. Tex., 11/27/2025
- Venue Allegations: Plaintiff alleges venue is proper based on Defendant's interactive e-commerce store on Amazon.com, which purposefully directs sales activities to consumers in Texas, offers shipping to the state, and has allegedly resulted in the sale of infringing products to Texas residents.
- Core Dispute: Plaintiff alleges that Defendant’s LED Portable Selfie Light infringes a design patent for a "Fill Light."
- Technical Context: The technology relates to portable lighting accessories for smartphones and other mobile devices, a market segment driven by consumer and professional demand for improved lighting in photography, video conferencing, and social media content creation.
- Key Procedural History: The complaint alleges that Plaintiff submitted an infringement complaint to Amazon.com regarding Defendant’s activities prior to filing this lawsuit, a fact which may be relevant to allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2023-02-20 | D'079 Patent Priority Date (Application Filing) |
| 2024-07-09 | D'079 Patent Issue Date |
| 2025-07-14 | Plaintiff submitted infringement complaint to Amazon.com |
| 2025-11-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,035,079 - "Fill Light"
- Patent Identification: U.S. Design Patent No. D1,035,079, titled "Fill Light", issued July 9, 2024.
The Invention Explained
- Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its utilitarian features. The patent addresses the creation of a new, original, and ornamental design for a portable lighting device.
- The Patented Solution: The patent claims the specific visual appearance of a "fill light" as depicted in its eight figures (’079 Patent, col. 2:1-13). The claimed design consists of the overall visual impression created by a combination of features, including a rectangular light panel with rounded corners, a specific mounting clip extending from the rear of the panel, and a distinct vertical arrangement of circular buttons or ports on the device's side (’079 Patent, FIG. 1, FIG. 6).
- Technical Importance: The complaint alleges that the patented design is "innovative" and enhances the "visual appearance of mobile lighting accessories" (Compl. ¶11).
Key Claims at a Glance
- Design patents contain a single claim. The asserted claim is: "The ornamental design for a fill light, as shown and described" (’079 Patent, col. 2:15-17).
- The claim's scope is defined by the visual features depicted in the patent's drawings, the essential elements of which include:
- The overall shape and proportion of a generally rectangular light panel with rounded corners.
- A specific configuration of a mounting clip extending from the rear of the light panel.
- The placement and appearance of a vertical array of circular elements on one side of the housing.
- The overall aesthetic combination of these visual features.
III. The Accused Instrumentality
Product Identification
- The accused products are "LED Portable Selfie Light" devices sold by Defendant on Amazon.com under the store name "ShouldYaoWang – Globe" (Compl. ¶1, ¶3). The complaint provides a screenshot of a product listing for a "60 LED Portable Selfie Light Video Conference Lighting" as an exemplary infringing product (Compl. ¶24, Ex. 4).
Functionality and Market Context
- The accused product is described as a portable, clip-on light for mobile devices, featuring multiple light modes and brightness levels (Compl. Ex. 4). The complaint alleges Defendant operates a "sophisticated e-commerce storefront" to market and sell these products to consumers throughout the United States, including in Texas (Compl. ¶9, ¶17). Exhibit 4 provides a screenshot from an Amazon.com product listing for the accused device, showing its design and features (Compl. Ex. 4).
IV. Analysis of Infringement Allegations
For a design patent, infringement is determined by the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that Defendant's product is "nearly identical to Plaintiff's patented design" (Compl. ¶1).
D'079 Patent Infringement Allegations
| Visual Feature (from Claim 1, as shown in drawings) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a fill light, characterized by a generally rectangular light panel with rounded corners | The accused product is shown with a generally rectangular light panel with rounded corners, creating a similar overall shape. | ¶1, Ex. 4 | col. 2:3-4 |
| The design's characteristic mounting clip extending from the rear of the panel | The accused product incorporates a mounting clip of a similar shape and placement extending from its rear. | ¶1, Ex. 4 | col. 2:1-2 |
| The design's particular vertical arrangement of circular controls on the side of the housing | The accused product features a vertical array of circular controls on its side that appears visually similar to the patented design. | ¶1, Ex. 4 | col. 2:9-10 |
Identified Points of Contention:
- Scope Questions: The primary question for the court will be whether the overall visual impression of the accused product is substantially the same as that of the patented design in the eyes of an ordinary observer.
- Technical Questions: A factual dispute may arise over the significance of any minor differences between the accused product's design and the patent's drawings. Defendant may argue that differences in proportion, surface texture, or the precise shape of the clip or buttons are sufficient to distinguish the products and avoid a finding of infringement.
V. Key Claim Terms for Construction
Claim construction in design patent cases is typically straightforward, as the drawings themselves define the scope of the claim. Formal construction of terms is less common than in utility patent litigation.
- The Term: "fill light"
- Context and Importance: While the drawings govern the scope of the ornamental design, the words "fill light" in the claim identify the article of manufacture to which the design applies. This limits the scope of protection to this type of article. Practitioners may focus on this term to confirm that the accused product is, in fact, a "fill light," which appears undisputed in this case.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not contain a written description that would narrow the term beyond its plain and ordinary meaning in the context of lighting accessories.
- Evidence for a Narrower Interpretation: The figures themselves provide the primary context, showing a portable, clip-on lighting device, which is consistent with the common understanding of a "fill light" for mobile devices (’079 Patent, FIG. 1-8).
VI. Other Allegations
- Indirect Infringement: The complaint includes a conclusory allegation that Defendant "induces" infringement (Compl. ¶6). However, it does not plead specific facts explaining how Defendant allegedly encourages or instructs its customers or other third parties to infringe the design patent.
- Willful Infringement: Plaintiff alleges that Defendant’s infringement was willful and deliberate (Compl. ¶32). The complaint grounds this allegation on Defendant’s alleged "actual or constructive knowledge" of the patent and, more specifically, on a pre-suit infringement complaint submitted to Amazon.com on July 14, 2025 (Compl. ¶14, ¶23). It further alleges that Defendant engages in "common evasive tactics" such as using aliases to conceal its identity, which may suggest an intent to disregard patent rights (Compl. ¶18, ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual identity: would an ordinary observer, giving the attention a purchaser usually gives, be deceived into purchasing Defendant's product believing it to be the product embodying the patented design, or are the visual differences sufficient to avoid confusion?
- A key evidentiary question will be one of intent and knowledge: does the pre-suit notice allegedly provided to Defendant via an Amazon.com complaint, combined with allegations of evasive online sales conduct, support a finding of willful infringement that could justify enhanced damages?