DCT

1:25-cv-02107

Dongguan Qiangu Jihua Electronics Co Ltd v. Shenzhen Cononlux Technology Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-02107, E.D. Va., 11/19/2025
  • Venue Allegations: Plaintiff asserts that venue is proper because the defendant, a foreign entity not residing in the United States, is subject to personal jurisdiction under 35 U.S.C. §293 and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff, a seller of LED lamps, seeks a declaratory judgment that Defendant's design patent for a lamp is invalid, unenforceable due to inequitable conduct, and not infringed by Plaintiff's products.
  • Technical Context: The dispute concerns the ornamental design of minimalist LED floor lamps, a product category with a significant consumer market.
  • Key Procedural History: The complaint alleges that this declaratory judgment action was prompted by Defendant's threats of an imminent patent infringement lawsuit, communicated through an intermediary, which Plaintiff claims were timed to disrupt its sales during the holiday retail season. Plaintiff also alleges a pattern of misconduct before the USPTO, asserting Defendant improperly claimed micro-entity status during prosecution of the patent-in-suit and other applications.

Case Timeline

Date Event
2020-08-30 Alleged prior art YouTube video published
2021-04-02 Alleged prior art Amazon product listing first available
2021-04-23 D'050 Patent application filed (priority date)
2022-03-01 D'050 Patent issued
2025-09-27 Defendant allegedly communicates intent to file infringement suit
2025-11-19 Complaint for Declaratory Judgment filed

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

U.S. Design Patent No. D945,050 - "LAMP," issued March 1, 2022

The Invention Explained

  • Problem Addressed: Design patents protect ornamental appearance rather than functional utility. As such, the D'050 Patent does not describe a technical problem but instead claims a specific aesthetic design for a lamp.
  • The Patented Solution: The patent claims "the ornamental design for a lamp, as shown and described" (’050 Patent, Claim). The design, depicted in figures, consists of a tall, slender, cylindrical vertical shaft connected to a low-profile base. The base is composed of two straight legs of equal length that meet at the vertical shaft and extend forward to form an acute V-shape when viewed from above (’050 Patent, FIG. 1, FIG. 6). The overall visual impression is one of minimalist and modern aesthetics.
  • Technical Importance: The design contributes a specific visual configuration to the market for minimalist floor lamps, which often prioritize simple geometric forms and an unobtrusive footprint.

Key Claims at a Glance

  • The patent asserts a single claim for the ornamental design as depicted in its figures.
  • The essential visual elements of the claimed design include:
    • A tall, slender, multi-segmented vertical post.
    • A base comprising two straight legs extending from the bottom of the post.
    • The two legs form a forward-facing V-shape on the floor.
    • The specific proportions and junction between the vertical post and the two-legged base.

III. The Accused Instrumentality

Product Identification

  • Plaintiff’s LED lamp products sold on Amazon, identified in the complaint by ASIN B0D93T78D7 (Compl. ¶11).

Functionality and Market Context

  • The accused product is a consumer LED floor lamp sold through online retail channels (Compl. ¶10). The complaint alleges that the product's design is distinct from the patented design, arguing that an "ordinary observer" would not find them to be "substantially the same" in light of the extensive prior art (Compl. ¶23). Specifically, the complaint alleges the base portion of Plaintiff's product has "distinctive proportions, angled lower surface, different plug location, and a three-stepped profile" that are absent from the claimed design (Compl. ¶24). The complaint includes a visual comparison of the accused product's base and the patented design's base to highlight these alleged differences (Compl. p. 8).

IV. Analysis of Infringement Allegations

This is a declaratory judgment action for non-infringement. Plaintiff argues that its product does not infringe the D'050 patent. The analysis will turn on the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design.

D'050 Patent Non-Infringement Allegations

Patented Design Feature (as shown in Figures) Alleged Differentiating Feature of Accused Product Complaint Citation Patent Citation
The overall ornamental design for a lamp The accused product's design is allegedly differentiable in its surface ornamentation and the configuration of its base portion. ¶24 FIGS. 1-7
A specific junction and configuration of the base The accused product's base portion allegedly has distinctive proportions, an angled lower surface, a different plug location, and a three-stepped profile. These features are depicted in a set of photographs comparing detailed views of the accused product's base to line drawings from another patent. ¶24 FIGS. 1, 7
  • Identified Points of Contention:
    • Scope Questions: The central question is whether the visual differences alleged by the Plaintiff, particularly in the base of the lamp, are sufficient to distinguish the accused product from the patented design in the eyes of an ordinary observer. The complaint's comparison images juxtapose photographs of the accused product against line drawings, raising the question of how the court will compare the actual products. The image provided shows detailed photographs of the accused product's base, highlighting its specific profile and features (Compl. p. 8).
    • Technical Questions: While design patent infringement is not a technical analysis, a key factual question will be how the claimed design and the accused product compare when placed in the context of the asserted prior art. The complaint presents prior art designs, including figures from U.S. Design Patents D950137 and D939131, that also feature minimalist lamps with two-legged bases (Compl. p. 6). The court will need to determine if the patented design is a narrow departure from a crowded field, which may lead to a finding of non-infringement if the accused product has even minor differences.

V. Key Claim Terms for Construction

In a design patent case, there are typically no terms to construe in the traditional sense. The single claim incorporates the figures by reference ("as shown and described"). The analysis is not one of defining words, but of comparing the overall visual appearance of the claimed design with the accused product. The dispute will therefore center on the application of the ordinary observer test rather than claim construction.

VI. Other Allegations

  • Inequitable Conduct: The complaint makes extensive allegations of inequitable conduct, which, if proven, would render the D'050 patent unenforceable (Compl. ¶¶25-34, 49-53). Plaintiff alleges that Defendant knowingly and with intent to deceive misrepresented its size to the USPTO, improperly claiming "micro-entity" status to pay significantly reduced fees (Compl. ¶26, ¶34). The complaint provides evidence suggesting Defendant's gross income and operational scale in 2020 and subsequent years far exceeded the micro-entity thresholds (Compl. ¶¶27-33). It is alleged that Defendant's 2021 annual report disclosed operational liquidity of approximately $900,000, well above the $202,563 gross income limit for that year (Compl. ¶27, ¶29).

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

The resolution of this declaratory judgment action appears to hinge on three central questions for the court:

  1. A core issue will be one of invalidity in a crowded field: Given the prior art cited in the complaint, which includes other minimalist lamps with similar V-shaped bases, is the D'050 patent's design non-obvious to a designer of ordinary skill, or is it merely a minor variation of existing designs?
  2. A second issue is one of infringement scope under the ordinary observer test: Are the alleged visual differences between the accused lamp and the patented design, particularly concerning the configuration and profile of the base, significant enough that an ordinary observer would not mistake one for the other, especially when viewed in the context of the prior art?
  3. A critical question will be one of unenforceability due to alleged misconduct: Does the evidence support the claim that the defendant intentionally deceived the USPTO by falsely claiming micro-entity status, and if so, does this conduct rise to the level of inequitable conduct sufficient to render the entire patent unenforceable?