2:24-cv-00562
Shenzhen Laiderui Lighting Technology Co Ltd v. Zhang
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Laiderui Lighting Technology Co Ltd. (China)
- Defendant: Zhifen Zhang and Xia Men Ji Xin Dian Zi Shang Wu You Xian Gong Si (China)
- Plaintiff’s Counsel: AU LLC; MANN LAW GROUP Group
- Case Identification: 2:24-cv-00562, W.D. Wash., 06/20/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendants' enforcement of the patent-in-suit via the Amazon.com platform, which is based in the district, caused the cessation of Plaintiff's product sales into Washington.
- Core Dispute: Plaintiff seeks a declaratory judgment that its ceiling fan products do not infringe Defendant's design patent and that the patent is invalid and unenforceable.
- Technical Context: The dispute centers on the ornamental design of consumer home goods, specifically ceiling fans with integrated lighting, a product category where aesthetic differentiation is a key market driver.
- Key Procedural History: The lawsuit was precipitated by an infringement complaint Defendants filed against Plaintiff through Amazon's intellectual property enforcement program, which resulted in the removal of Plaintiff's products from the platform.
Case Timeline
| Date | Event |
|---|---|
| 2023-05-06 | Priority Date ('442 Patent) |
| 2023-12-19 | U.S. Design Patent No. D1,008,442 Issues |
| 2024-04-06 | Defendant files infringement complaint against Plaintiff on Amazon.com |
| 2024-06-20 | Plaintiff files First Amended Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,008,442 - "CEILING FAN WITH LIGHT"
The Invention Explained
- Problem Addressed: Design patents address the need for new, original, and ornamental designs for articles of manufacture. The implicit problem is to create a visually distinct and aesthetically pleasing appearance for a ceiling fan to distinguish it from pre-existing designs in the marketplace.
- The Patented Solution: The patent claims a specific ornamental design for a "CEILING FAN WITH LIGHT" ('442 Patent, Title). The design, depicted in the patent's figures, features a five-petal, flower-like configuration for the fan body, with a central light source and specific curved contours on each "petal" element ('442 Patent, FIG. 1, 3). The claim is for the visual appearance of the article, not its mechanical or electrical function.
- Technical Importance: The claimed design provides a unique aesthetic for a common household appliance, which can be a significant factor in consumer purchasing decisions.
Key Claims at a Glance
- The patent contains a single claim: "The ornamental design for a ceiling fan with light, as shown and described." ('442 Patent, Claim).
- The essential visual elements of the claimed design, as depicted in the solid lines of the patent drawings, include:
- An overall configuration of five blade-like structures arranged in a floral or star-shaped pattern.
- Each of the five structures having a specific three-dimensional curvature and layered appearance.
- A central circular portion intended to house a light fixture.
- The specific proportions and interrelation between these elements as shown in the patent's figures.
III. The Accused Instrumentality
Product Identification
Plaintiff’s ceiling fan products, sold on Amazon.com under the ASINs B0CCV31QX9 and B0CCV5B8SG (the "Products") (Compl. ¶10).
Functionality and Market Context
The complaint identifies the Products as ceiling fans sold through Plaintiff's "LEDAIRY" Amazon storefront (Compl. ¶10). The complaint includes images of the two Products, one in white and one in black, both depicting ceiling fans with an integrated light and a five-petal, flower-like shape. This image shows the overall appearance of the products at issue (Compl. ¶10). The Products are alleged to be competitors of the Defendants' products on the Amazon marketplace (Compl. ¶11).
IV. Analysis of Infringement Allegations
This is a declaratory judgment action where the Plaintiff seeks a ruling of non-infringement. The complaint does not contain a detailed infringement analysis or claim chart; rather, it asserts that its Products do not infringe (Compl. ¶1). The infringement analysis for a design patent turns on the "ordinary observer" test: whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design. The table below compares the claimed design to the Plaintiff's product based on the available figures.
'442 Patent Non-Infringement Comparison
| Claim Element (from '442 Patent, as shown) | Plaintiff's Product Feature Alleged Not to Infringe (from Compl. ¶10 Image) | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a ceiling fan with light, as shown and described. | The overall ornamental appearance of Plaintiff's ceiling fan products. | ¶1, ¶10 | Claim; FIGs. 1-8 |
Identified Points of Contention
- Scope Questions: The complaint raises a significant question about the scope of the claim itself, alleging the patent drawings are indefinite because "lines at some points appear to be solid lines, but at other points appear to be dashed (or broken) lines" (Compl. ¶24). The resolution of this validity challenge will be a prerequisite to any infringement analysis, as it questions whether the boundaries of the claimed design can be determined at all.
- Technical Questions: A central question for the infringement analysis will be whether the visual differences between the specific contours, proportions, and surface details shown in the '442 Patent's drawings and the corresponding features of the Plaintiff's Products are significant enough to create a different overall visual impression for an ordinary observer. The complaint does not detail these differences, but they will be the focus of any substantive comparison.
V. Key Claim Terms for Construction
In design patent litigation, claim construction focuses on the scope of the design as a whole, as depicted in the drawings, rather than on discrete text-based terms.
- The Term: "The ornamental design... as shown and described."
- Context and Importance: This phrase incorporates the patent's drawings as the definition of the claim. The central issue is determining the precise scope of the protected design—specifically, what is included (solid lines) versus what is disclaimed (dashed lines). The Plaintiff's indefiniteness allegation (Compl. ¶¶21-26) makes the clarity of these lines the most critical construction issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue for a broader interpretation focusing on the overall visual impression of a five-petal floral ceiling fan, suggesting minor differences in curves or details do not alter the general appearance.
- Evidence for a Narrower Interpretation: The patent specification explicitly states: "The dashed lines in the figures illustrate portions of the ceiling fan with light that form no part of the claimed design" ('442 Patent, Description). This statement provides strong intrinsic evidence that the claim is limited to the exact features depicted in solid lines, which may support an argument that any deviation in the accused product from those precise solid-line features avoids infringement.
VI. Other Allegations
The complaint does not contain allegations of indirect or willful patent infringement by the Plaintiff. Instead, it alleges tortious conduct by the Defendants related to their patent enforcement activities.
- Willful Infringement: The complaint does not allege that the Plaintiff's potential infringement was willful. However, it does allege that Defendants acted "willfully, intentionally and unjustifiably" in making "false claims of patent infringement" to Amazon to terminate Plaintiff's product sales (Compl. ¶45). This allegation supports the state law claim for Tortious Interference with Prospective Economic Advantage, rather than a claim for enhanced damages under the Patent Act.
VII. 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 concerning the patent's validity, followed by a factual question of infringement.
A threshold issue will be one of claim definiteness: Do the drawings of the '442 Patent, as Plaintiff alleges, fail to clearly distinguish between claimed solid lines and unclaimed dashed lines, rendering the patent invalid for indefiniteness under 35 U.S.C. § 112?
A second validity challenge will be one of ornamentality versus functionality: Is the claimed design, as a whole, primarily ornamental, as required by 35 U.S.C. § 171, or are its features dictated by functional considerations, which would render the design patent invalid?
If the patent is deemed valid, the case will turn on a question of substantial similarity: Would an ordinary observer, comparing the patented design to the Plaintiff's products, be deceived into believing the products are the same? The answer will depend on a detailed visual comparison of the specific contours and overall appearance of the respective designs.