1:25-cv-01553
Shenzhen Weiwei Technology Co Ltd v. Anji Hengjian Smart Home Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiffs: Shenzhen Weiwei Technology Co. Ltd. et al. (People's Republic of China)
- Defendant: Anji Hengjian Smart Home Technology Co., Ltd. (People's Republic of China)
- Plaintiffs’ Counsel: Ni, Wang & Massand, PLLC
- Case Identification: 3:24-cv-02237, N.D. Tex., 08/30/2024
- Venue Allegations: Plaintiffs allege venue is proper in the Northern District of Texas because harm was caused there, Texas is the top market for Plaintiffs' products, and the delisting of products from Amazon.com, an interactive website accessible in the district, had a substantial effect in the state.
- Core Dispute: Plaintiffs seek a declaratory judgment that Defendant’s U.S. Design Patent No. D1,027,476 is invalid due to the existence of prior art that was publicly available more than one year before the patent's effective filing date.
- Technical Context: The dispute centers on the ornamental design of a modern upholstered swivel office chair, a product category with significant competition in the e-commerce furniture market.
- Key Procedural History: The complaint alleges that Defendant submitted patent infringement complaints to Amazon.com, resulting in the delisting of Plaintiffs’ products. This action by the patent holder prompted Plaintiffs to file this declaratory judgment action to challenge the patent's validity and resolve the threat of an infringement lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2021-03-21 | Alleged earliest seller review date for the "HOMEFUN Product" prior art (Compl. ¶19) |
| 2022-03-21 | D1,027,476 S Patent priority date (filing date) (Compl. ¶15) |
| 2024-05-21 | U.S. Design Patent No. D1,027,476 S issues (Compl. ¶15) |
| 2024-08-20 | Defendant allegedly initiates patent infringement complaints on Amazon.com (Compl. ¶5, ¶17) |
| 2024-08-30 | Complaint for Declaratory Judgment of Invalidity filed (Compl. p. 1) |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,027,476 S - Chair
The Invention Explained
- Problem Addressed: As a design patent, the D’476 Patent does not describe a technical problem but instead claims a new, original, and ornamental design for an article of manufacture (D’476 Patent, p. 1).
- The Patented Solution: The patent claims the specific visual appearance of a chair (D’476 Patent, Claim). The design features a continuous, upholstered seat, back, and armrest structure with vertical seams or channels on the interior surfaces. The upper portion has an open area in the lower back, and the chair is supported by a central column with a five-caster base (D’476 Patent, FIG. 1, FIG. 2).
- Technical Importance: The claimed design represents a specific aesthetic in the competitive market for home and office task chairs, where ornamental appearance is a key driver of consumer choice (Compl. ¶7, ¶10).
Key Claims at a Glance
- The patent asserts a single claim: "The ornamental design for a chair, as shown and described" (D’476 Patent, Claim). This claim protects the overall visual appearance of the chair as depicted in the patent's seven figures.
III. The Accused Instrumentality
Product Identification
Plaintiffs' "Swivel Chair" products, sold on Amazon.com under various storefronts and identified by specific Amazon Standard Identification Numbers (ASINs) (Compl. ¶7, ¶8).
Functionality and Market Context
- The complaint describes Plaintiffs' products as swivel chairs sold through e-commerce channels, primarily the Amazon Marketplace (Compl. ¶7, ¶10).
- The products are positioned as high-quality, affordable options in the U.S. market, with Texas being the most significant sales market for Plaintiffs (Compl. ¶9, ¶10). The delisting of these products from Amazon following Defendant’s infringement complaints is alleged to have caused immediate and irreparable harm (Compl. ¶11).
IV. Analysis of Invalidity Allegations
This is a declaratory judgment action for invalidity. The central allegation is that the D’476 Patent is invalid under 35 U.S.C. § 102 because an identical design was on sale and available to the public more than one year prior to the patent's effective filing date. The complaint provides a screenshot of a product listing for the alleged prior art, the "HOMEFUN Product," showing customer reviews dating back to March 21, 2021 (Compl. p. 5). The complaint also presents a side-by-side visual comparison to support its claim that the designs are identical (Compl. p. 6).
D’476 Patent Invalidity Allegations
| Claimed Design Feature (as shown in D’476 Patent) | Alleged Prior Art Disclosure (HOMEFUN Product) | Complaint Citation | Patent Citation |
|---|---|---|---|
| An ornamental design for a chair. | The "Green Velvet Morden Cute Upholstered Task Chair" sold by HOMEFUN at Homedepot.com is alleged to be an identical prior art design available to the public before the patent's critical date. | ¶19 | Claim |
| A continuous upholstered piece forming the seat, back, and armrests, with an open area in the lower back. | The HOMEFUN Product is alleged to have the same continuous upholstered structure with an open lower back area. The complaint's side-by-side comparison image illustrates this similarity. | ¶20, p. 6 | FIG. 1, 2 |
| Vertical seams or channels throughout the interior surface of the chair. | The HOMEFUN Product is alleged to have identical vertical seams on its interior surface. | ¶20, p. 6 | FIG. 1, 6 |
| A base with five ball casters. | The HOMEFUN Product is alleged to have the same five-caster base. | ¶20 | FIG. 1, 7 |
Identified Points of Contention
- Evidentiary Question: A central question will be whether Plaintiffs can produce sufficient evidence to prove that the "HOMEFUN Product" was, in fact, on sale and publicly available before the critical date of March 21, 2021 (one year prior to the D'476 patent's filing date). The complaint relies on a screenshot of seller reviews, the authenticity and conclusiveness of which may be scrutinized (Compl. p. 5).
- Scope Question: The legal analysis will turn on the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into believing the patented design is the same as the prior art design. The complaint argues that the resemblance is so close that the designs are "exactly the same" (Compl. ¶20).
V. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action will likely depend on the answers to two primary questions:
A core issue will be one of anticipation: Can Plaintiffs definitively prove with clear and convincing evidence that the specific design of the "HOMEFUN Product" was publicly disclosed or on sale in the United States before the D'476 Patent's critical date of March 21, 2021? The strength of the evidence supporting the 2021 product availability date will be paramount.
A key question of design identity will be addressed through the "ordinary observer" test: Assuming the prior art's existence is proven, are the overall visual impressions of the claimed design and the HOMEFUN Product "substantially the same," such that the D'476 Patent would be rendered invalid? The side-by-side comparison provided in the complaint suggests this will be a central point of argument.