DCT
1:25-cv-01277
Dongguan Naquan E Commerce Co Ltd v. Sanbo Wang
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Naquan E-Commerce Co., Ltd., Guangzhou Zhongyao Technology Co., Ltd., and Shenzhen Lepeng Supply Chain Co., Ltd. (China)
- Defendant: Sanbo Wang (China)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 1:25-cv-6601, N.D. Ill., 06/26/2025
- Venue Allegations: Plaintiffs allege venue is proper because the Defendant availed herself of the United States by applying for a U.S. patent and submitting patent infringement reports to Amazon, which affected Plaintiffs’ sales and activities in Illinois.
- Core Dispute: Plaintiffs seek a declaratory judgment that Defendant's design patent for a camping light is invalid due to anticipating and obviousness-rendering prior art, and is unenforceable due to inequitable conduct during prosecution.
- Technical Context: The dispute concerns the ornamental design of portable, reel-based LED string lights, a product category in the consumer market for outdoor and camping accessories.
- Key Procedural History: The action was precipitated by infringement reports the Defendant allegedly submitted to Amazon against the Plaintiffs. The complaint also alleges the Defendant was aware of key prior art because her company was found to infringe a related Chinese patent in a Chinese court proceeding that concluded just before this complaint was filed.
Case Timeline
| Date | Event |
|---|---|
| 2022-11-15 | Alleged prior art Chinese Patent No. 307861226 (CN '226) filed |
| 2023-02-24 | CN '226 Patent issued |
| 2023-06-24 | Alleged prior art "Hiromeco Camping String Lights" sold on Amazon |
| 2024-03-05 | Chinese lawsuit filed against Defendant's company for infringing CN '226 |
| 2024-03-26 | '875 Patent application filed |
| 2024-06-26 | Chinese Court allegedly found Defendant's product infringed CN '226 |
| 2025-01-21 | '875 Patent issued |
| 2025-06-13 | Plaintiffs received infringement notice from Amazon |
| 2025-06-26 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
Note: The complaint identifies U.S. Patent No. 1,058,875 as a design patent for a "camping light." The patent document provided for review under this number is a 1913 utility patent for a "Rail Joint." This analysis proceeds based on the patent's subject matter as described and depicted in the complaint, which is the basis of the legal dispute.
U.S. Patent No. 1,058,875 - Camping Light
- Patent Identification: U.S. Patent No. 1,058,875 ("'875 Patent"), allegedly for an "ornamental design for a camping light," issued January 21, 2025 (Compl. ¶¶ 17-18).
The Invention Explained
- Problem Addressed: As a design patent, the '875 patent does not solve a technical problem but instead claims a new, original, and ornamental design for an article of manufacture (Compl. ¶ 18).
- The Patented Solution: The patent claims the specific visual appearance of a camping light. The design, as depicted in the complaint, features a circular, disc-shaped housing for a retractable light string, characterized by a series of concentric rings on its top surface, a central recessed area with a foldable crank or handle for winding, and specific placements for control buttons and ports on its cylindrical side wall (Compl. pp. 5-7).
- Technical Importance: The claimed design provides a distinct aesthetic for a consumer product, which can be a significant differentiator in the competitive market for camping and outdoor equipment (Compl. ¶¶ 13, 16).
Key Claims at a Glance
- Design patents typically contain a single claim for the ornamental design as shown in the figures. The complaint alleges the "'875 Patent claims for ornamental design for a camping light as shown" in its included figures (Compl. ¶ 18).
III. The Accused Instrumentality
Product Identification
- Plaintiffs’ "Camping String Lights," sold on Amazon under ASIN B0D5HTW1NB (Compl. ¶¶ 11, 14). As this is a declaratory judgment action, this is the product Defendant accused of infringement.
Functionality and Market Context
- The product is a portable, rechargeable lighting system featuring a 32.8-foot string of LED lights that retracts into a compact, reel-style housing (Compl. p. 4). The product listing referenced in the complaint describes features such as five light modes, three brightness levels, and a waterproof design (Compl. p. 4).
- The complaint alleges the product is commercially successful, having been designated an "Amazon's Choice" product and ranking eighth in the "Outdoor String Lights" category on Amazon (Compl. ¶¶ 12, 13). A screenshot in the complaint shows the product listing, which indicates "8K+ bought in past month" (Compl. p. 4).
IV. Analysis of Invalidity Allegations
As this is a declaratory judgment action for invalidity, the central allegations concern prior art that allegedly renders the '875 Patent invalid. The complaint's primary argument is that the claimed design is not novel or is obvious in light of prior art designs.
| Claimed Design Feature ('875 Patent) | Allegedly Anticipating Prior Art Feature (from CN '226 Patent) | Complaint Citation |
|---|---|---|
| Overall circular, reel-shaped housing for a light string. | The complaint alleges the CN '226 Patent discloses an identical or substantially similar overall housing shape and function. | ¶ 25; p. 6 |
| Concentric ring pattern on the top surface. | The CN '226 Patent's design is alleged to show a visually indistinguishable concentric ring pattern on its top surface. | ¶ 25; p. 7 |
| Central recessed portion with a foldable winding handle. | The complaint provides figures suggesting the CN '226 Patent discloses a nearly identical central winding mechanism. | ¶ 25; p. 7 |
| Placement and configuration of side buttons and charging ports. | The side views provided in the complaint's visual comparison show a similar arrangement of elements on the housing's perimeter. | ¶ 25; p. 7 |
- Identified Points of Contention:
- Scope Questions: The central legal question will be whether the designs of the alleged prior art and the '875 Patent are "substantially the same" from the perspective of an "ordinary observer." The complaint presents side-by-side comparisons to argue for such similarity (Compl. pp. 6-7).
- Technical Questions: A key factual question will be the public availability and date of the alleged prior art. For the "Hiromeco" product, the court will need to determine if the evidence, such as dated customer reviews containing photographs, is sufficient to establish that the design was publicly known before the '875 Patent's effective filing date (Compl. ¶¶ 27-28). The complaint includes a screenshot of a customer review with photos, dated June 24, 2023, to support this contention (Compl. p. 8).
V. Key Claim Terms for Construction
In design patent cases, the dispute typically centers not on the construction of written terms, but on the overall visual appearance of the claimed design as a whole.
- The Term: The scope of the design claim itself, i.e., "the ornamental design for a camping light as shown."
- Context and Importance: The entire invalidity case rests on comparing the visual impression of the claimed design with the visual impression of the prior art. The court's analysis will focus on similarities and differences in the overall appearance rather than parsing the meaning of specific words. Practitioners will focus on applying the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into purchasing one design supposing it to be the other.
- Intrinsic Evidence for Interpretation: The primary evidence is the drawings themselves.
- Evidence for a Broader Interpretation: The parties may argue that minor differences between the claimed design and the prior art are insufficient to overcome a finding of substantial similarity, focusing on the overall visual impression.
- Evidence for a Narrower Interpretation: The parties may argue that specific, discrete features of the design (e.g., the exact curvature of the housing, the shape of the handle, the number of concentric rings) distinguish it from the prior art and create a different overall visual impression.
VI. Other Allegations
- Inequitable Conduct: The complaint includes a count for unenforceability based on inequitable conduct (Compl. ¶¶ 32-40). Plaintiffs allege the Defendant knew of the material prior art CN '226 Patent during the prosecution of the '875 Patent but intentionally withheld it from the U.S. Patent and Trademark Office (USPTO) (Compl. ¶ 37). The basis for this allegation is a Chinese patent infringement lawsuit where a court allegedly found on June 26, 2024, that the Defendant's product infringed the CN '226 Patent, which Plaintiffs argue establishes Defendant's knowledge of the art (Compl. ¶ 36).
- Exceptional Case: While not alleging willful infringement, Plaintiffs seek a finding that the case is "exceptional" under 35 U.S.C. § 285, which would entitle them to attorneys' fees (Prayer for Relief ¶ d). This is based on the allegations of inequitable conduct and the Defendant's "baseless infringement report to the Amazon platform" (Compl. ¶ 30).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action appears to hinge on two primary questions for the court:
- A core question will be one of invalidity: Is the ornamental design claimed in the '875 Patent anticipated by or obvious over the prior art, specifically the Chinese '226 Patent and the publicly sold "Hiromeco" lights? This will require a factual comparison of the designs under the ordinary observer test.
- A second critical question is one of enforceability: Does the evidence surrounding the Chinese patent litigation support a finding that the Defendant knew the CN '226 Patent was material prior art and intentionally withheld it from the USPTO with deceptive intent, thereby rendering the '875 Patent unenforceable for inequitable conduct?