DCT
3:25-cv-00845
Heshan Jiahojia Sanitary Ware Industry Co Ltd v. Unincorp Associations
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Heshan Jiahojia Sanitary Ware Industry, Co., Ltd. (P.R. China)
- Defendant: The Unincorporated Associations Identified in Schedule A (P.R. China and other non-U.S. jurisdictions)
- Plaintiff’s Counsel: DNL ZITO PLLC
- Case Identification: 3:25-cv-00845, E.D. Va., 10/14/2025
- Venue Allegations: Plaintiff alleges venue is proper because the Defendants are non-U.S. entities who have committed patent infringement in the district by selling and shipping accused products to consumers in Virginia through e-commerce platforms, thereby establishing minimum contacts.
- Core Dispute: Plaintiff alleges that numerous Defendants' faucet products, sold through online storefronts on platforms like Amazon.com, Temu.com, and Wayfair.com, infringe two U.S. design patents covering the ornamental appearance of "waterfall" style faucets.
- Technical Context: This dispute concerns the ornamental design of sanitary ware, specifically widespread and single-unit bathroom faucets that create a wide, open stream of water.
- Key Procedural History: The complaint does not reference prior litigation or administrative proceedings involving the patents-in-suit. It does allege that the defendants are numerous, potentially related entities who operate under fictitious names to conceal their identities.
Case Timeline
| Date | Event |
|---|---|
| 2022-03-11 | U.S. Patent No. D967,340 Priority Date |
| 2022-10-18 | U.S. Patent No. D967,340 Issued |
| 2023-01-05 | U.S. Patent No. D983,326 Priority Date |
| 2023-04-11 | U.S. Patent No. D983,326 Issued |
| 2023-05-01 | Alleged First Listings of Infringing Products on Amazon.com |
| 2025-10-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D967,340 - "Faucet"
- Patent Identification: U.S. Design Patent No. D967,340, "Faucet," issued October 18, 2022 (the ’340 Patent).
The Invention Explained
- Problem Addressed: Design patents protect new, original, and ornamental designs for articles of manufacture. The implicit problem addressed is the need for a novel aesthetic appearance for a bathroom faucet (Compl. ¶19).
- The Patented Solution: The patent claims the ornamental design for a three-piece, widespread faucet. The design features a central, rectangular spout with a wide, open channel creating a "waterfall" effect, flanked by two separate, blocky rectangular handles with thin, flat control levers on top (’340 Patent, FIG. 1). The complaint alleges this is a "distinctive patented waterfall design" (Compl. ¶21).
Key Claims at a Glance
- Design patents contain a single claim. The asserted claim is: "The ornamental design for a faucet, as shown and described" (’340 Patent, Claim).
- The essential elements of the claim are the visual characteristics of the faucet spout and handles as depicted in solid lines in the patent's figures.
U.S. Design Patent No. D983,326 - "Faucet"
- Patent Identification: U.S. Design Patent No. D983,326, "Faucet," issued April 11, 2023 (the ’326 Patent).
The Invention Explained
- Problem Addressed: As with the ’340 Patent, this patent addresses the need for a new and ornamental faucet design (Compl. ¶19).
- The Patented Solution: The patent claims the ornamental design for a single-unit faucet assembly. The design consists of a cylindrical central body from which a curved, open-channel "waterfall" spout extends. Two control handles are integrated into the faucet's base, positioned on either side of the central body (’326 Patent, FIG. 1). Plaintiff's commercial embodiment of this design is shown in the complaint (Compl. ¶18).
Key Claims at a Glance
- The single asserted claim is: "The ornamental design for a faucet, as shown and described" (’326 Patent, Claim).
- The essential elements are the visual characteristics of the integrated faucet body, spout, and handles as depicted in solid lines in the patent's figures.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "Infringing Design Products," specifically various models of bathroom faucets sold by Defendants on e-commerce platforms such as Amazon.com, Temu.com, and Wayfair.com (Compl. ¶7, ¶27). The complaint identifies specific accused products sold under brand names including VOTON, AVSIILE, FORIOUS-USA, and FRANSITON (Compl. ¶29, ¶31).
Functionality and Market Context
- The accused products are functional bathroom faucets that allegedly copy the ornamental designs protected by the patents-in-suit (Compl. ¶25). The complaint alleges that these products are sold at a lower price than Plaintiff's patented faucets and that they directly compete with and cause harm to Plaintiff's sales and market position (Compl. ¶27, ¶36). The complaint provides an image of an accused widespread faucet sold by "Defendant No. 1 VOTON," which is alleged to infringe the ’340 Patent (Compl. ¶29).
IV. Analysis of Infringement Allegations
The standard for design patent infringement is whether, in the eye of an ordinary observer, the accused design is substantially the same as the claimed design, such that the observer would be induced to purchase one believing it to be the other (Compl. ¶44, ¶52).
- 'D340 Patent Infringement Allegations
| Claim Element (from the single claim) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a faucet, as shown and described. | The accused faucets sold by Defendants Nos. 1-21, such as the VOTON product, allegedly embody a three-piece widespread design with a central open-channel spout and two separate blocky handles that is substantially the same as the design claimed in the patent. | ¶29, ¶43-44 | ’340 Patent, FIGS. 1-8 |
- 'D326 Patent Infringement Allegations
| Claim Element (from the single claim) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a faucet, as shown and described. | The accused faucets sold by Defendants Nos. 2 and 22-23, such as the FORIOUS-USA and FRANSITON products, allegedly embody a single-unit design with a curved open-channel spout and integrated handles that is substantially the same as the design claimed in the patent. The complaint provides an image of an accused single-unit faucet from "Defendant No. 22 FRANSITON" to support its allegations (Compl. ¶31). | ¶31, ¶51-52 | ’326 Patent, FIGS. 1-9 |
- Identified Points of Contention:
- Scope Questions: The primary question for the court will be whether the overall visual appearance of the accused products is "substantially the same" as the specific ornamental designs depicted in the patents. The analysis will focus on similarities in shape, configuration, and proportion of the claimed features shown in solid lines.
- Technical Questions: While design patent cases are not primarily technical, a factual question will be whether minor differences in curvature, angles, or surface finish between the accused products and the patent drawings are sufficient to differentiate the designs in the mind of an ordinary observer.
V. Key Claim Terms for Construction
In design patent litigation, the claim is defined by the drawings. Formal claim construction of terms is rare. Instead, the focus is on the scope of the claimed design as a whole.
- The Term: "The ornamental design for a faucet"
- Context and Importance: The scope of the intellectual property right is defined by what is shown in solid lines in the patent drawings versus what is disclaimed as environment in broken lines. Practitioners may focus on this distinction because it determines which visual features are material to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patents explicitly state that "The broken lines shown in the drawings illustrate portions of the faucet that form no part of the claimed design" (’340 Patent, Description; ’326 Patent, Description). This could support an interpretation where the claimed design is protected regardless of the specific underlying plumbing or mounting hardware, so long as the visible ornamental features are copied.
- Evidence for a Narrower Interpretation: The overall visual impression is what matters. A defendant may argue that even if the portions shown in broken lines are disclaimed, the specific proportions and relationships between the claimed solid-line features create a narrow and specific overall appearance that the accused products do not replicate.
VI. Other Allegations
- Indirect Infringement: The complaint pleads only direct infringement under 35 U.S.C. § 271(a) and does not contain separate counts for induced or contributory infringement (Compl. ¶29, ¶31, ¶43, ¶51).
- Willful Infringement: The complaint alleges that Defendants have been willfully infringing "since at least as early as it became aware of these patents" (Compl. ¶38). It further alleges that Defendants have no good faith defense to the infringement allegations and seeks treble damages (Compl. ¶32, ¶38; Prayer for Relief ¶G). The complaint suggests that infringing sales began in May 2023, after both patents had issued (Compl. ¶35).
VII. Analyst’s Conclusion: Key Questions for the Case
- Visual Comparison: The central issue will be one of ornamental similarity: from the perspective of an ordinary purchaser of faucets, are the accused products substantially the same as the specific designs shown in the ’340 and ’326 Patents? This will require a detailed visual comparison of the products' overall shape, proportions, and configuration against the patented designs.
- Defendant Identification and Enforcement: A significant practical question, emphasized throughout the complaint, will be one of party identification and jurisdiction: can the Plaintiff successfully identify, serve, and establish liability for the numerous foreign entities allegedly operating behind pseudonymous online storefronts? The resolution of this procedural challenge will be critical to the enforceability of any judgment.