DCT

2:25-cv-00536

Dongguan Zhouda Technology Co Ltd v. Dai

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00536, W.D. Wash., 03/26/2025
  • Venue Allegations: Plaintiffs allege venue is proper because Defendant enforced the patent-in-suit via the Amazon.com platform, which is based in the forum, causing cessation of Plaintiffs' product sales into Washington.
  • Core Dispute: Plaintiffs, a group of online sellers, seek a declaratory judgment that Defendant's design patent for a tumbler lid is invalid and unenforceable, and allege that Defendant's enforcement of the patent through Amazon's reporting system constitutes unfair competition and tortious interference.
  • Technical Context: The dispute concerns the ornamental design of a tumbler lid, a common accessory in the competitive consumer drinkware market.
  • Key Procedural History: The lawsuit was precipitated by Defendant's use of Amazon.com's infringement reporting procedures to have Plaintiffs' product listings removed. The complaint alleges these enforcement actions were wrongful and have caused financial harm and damage to Plaintiffs' seller reputations.

Case Timeline

Date Event
2024-07-31 ’616 Patent Priority/Filing Date
2025-01-07 ’616 Patent Issue Date
2025-03-26 Complaint Filing Date

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

U.S. Design Patent No. D1,056,616 - "Tumbler Lid"

  • Patent Identification: U.S. Design Patent No. D1,056,616, "Tumbler Lid," issued January 7, 2025.

The Invention Explained

  • Problem Addressed: Design patents protect the ornamental appearance of an article, not a technical function. The patent seeks to protect a "new, original, and ornamental design for an article of manufacture," which in this case is a tumbler lid (’616 Patent, p. 1).
  • The Patented Solution: The patent discloses a specific visual design for a tumbler lid, characterized by features shown in solid lines in the patent's figures (’616 Patent, Description). The overall appearance includes the shape of a flip-up mouthpiece, its integration into a central recessed channel, and the configuration of the lid's main body, as depicted from multiple perspectives in Figures 1-9 (’616 Patent, Figs. 1, 7, 9). The claim is for the ornamental design "as shown and described" (’616 Patent, Claim).
  • Technical Importance: The complaint alleges that Defendant's enforcement of this design patent has prevented Plaintiffs from selling their respective products and has caused lost income, which suggests the design has commercial significance in the marketplace (Compl. ¶39).

Key Claims at a Glance

  • The patent asserts a single claim: "The ornamental design for a tumbler lid, as shown and described" (Compl. ¶27; ’616 Patent, Claim).
  • The scope of this claim is defined by the visual elements depicted in solid lines in the patent’s drawings, while elements shown in broken lines are disclaimed and form no part of the protected design (’616 Patent, Description).

III. The Accused Instrumentality

Product Identification

The products at issue are "cup lids" sold by the four Plaintiffs on their respective Amazon.com storefronts (Compl. ¶¶ 11-14). The complaint identifies specific products by their Amazon Standard Identification Numbers (ASINs), such as "B0DSJRMR8D" for the "ANTAND Products" and "B0DRVBT6NG" for the "HWHIEUAIK-US Products," among many others listed for all Plaintiffs (Compl. ¶¶ 11-14).

Functionality and Market Context

The complaint describes the products as "cup lids" that were sold on the Amazon.com platform prior to Defendant's enforcement actions (Compl. ¶¶ 11-14). Plaintiffs allege that Defendant's infringement complaints submitted to Amazon have prevented them from selling these products, resulting in lost sales and damage to their seller accounts (Compl. ¶¶ 20-23, 39). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

As this is a complaint for declaratory judgment of non-infringement and invalidity, it does not contain a detailed infringement analysis or claim chart from the Plaintiffs. Instead, it challenges the validity of the patent and the propriety of the Defendant’s enforcement actions. The core of the case, as framed by the Plaintiffs, revolves around the following invalidity contentions rather than claim element mapping.

Identified Points of Contention

  • Invalidity (Prior Art): The complaint alleges that "cup lids exhibiting the same ornamental features as those disclosed and claimed by the ‘616 Patent were on sale, sold, or described" in publications prior to the patent's priority date, raising questions of invalidity under 35 U.S.C. §§ 102 and 103 (Compl. ¶28).
  • Invalidity (Indefiniteness): A central allegation is that the patent is invalid under 35 U.S.C. § 112 because its drawings are indefinite (Compl. ¶¶ 29, 34). The complaint asserts that lines in the drawings "at some points appear to be solid lines, but at other points appear to be dashed (or broken) lines," making it impossible "to discern the proper scope of the ornamental design" (Compl. ¶¶ 32-33).
  • Invalidity (Functionality): The complaint raises the question of whether the design is invalid under 35 U.S.C. § 171 because it is "primarily functional, rather than ornamental" (Compl. ¶35).

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses on the scope of the claimed design as a whole, as depicted in the drawings. The key issue identified in the complaint is not a specific word, but the interpretation of the lines used in the drawings.

  • The Term: The demarcation between claimed subject matter (solid lines) and unclaimed environment (broken lines).
  • Context and Importance: This interpretation is critical to the dispute. The complaint's primary invalidity argument hinges on the allegation that the drawings are indefinite due to inconsistent or ambiguous use of solid and broken lines (Compl. ¶¶ 32-33). The court's determination of whether the drawings clearly define the scope of the design will be foundational to both the validity and infringement analyses.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (i.e., Definite): A party defending the patent may argue that the drawings, when viewed as a whole by a person of ordinary skill in the art, are sufficiently clear. They would likely point to the patent’s description, which explicitly states, "The broken lines in the drawings illustrate the portions of the tumbler lid, which form no part of the claimed design" (’616 Patent, Description), as evidence of a clear intent that conforms to standard patent drawing conventions.
    • Evidence for a Narrower Interpretation (i.e., Indefinite): The Plaintiffs allege that "many of the drawings... includes lines that at some points appear to be solid lines, but at other points appear to be dashed (or broken) lines" (Compl. ¶32). They will argue this alleged ambiguity makes it impossible to determine the precise boundaries of the claimed design, rendering the patent invalid for indefiniteness under 35 U.S.C. § 112 (Compl. ¶33).

VI. Other Allegations

This complaint does not allege patent infringement but rather seeks a declaration of its absence. The additional counts are directed at the Defendant's conduct in enforcing the patent.

  • Unfair Business Practices (Count II): The complaint alleges that the Defendant violated Washington state law by "making a false and/or misleading statement of fact to Amazon.com when it represented... that the Plaintiffs' respective Products infringed the ‘616 Patent" (Compl. ¶¶ 37-38).
  • Tortious Interference (Count III): The complaint alleges that Defendant was aware of Plaintiffs' business relationship with Amazon.com and "willfully, intentionally and unjustifiably induced Amazon to terminate each Plaintiff's expectancy of continued sales" by making false claims of infringement (Compl. ¶¶ 51-52).

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

  1. A primary threshold question will be one of validity due to indefiniteness: Are the drawings of the ’616 Patent indefinite under 35 U.S.C. § 112? The case may turn on a factual finding as to whether the alleged inconsistencies in the use of solid and dashed lines render the scope of the claimed design unascertainable to an ordinary observer.
  2. A second key validity question will be whether the design is primarily functional: The court may need to determine if the claimed ornamental features are dictated by their function, which would invalidate the patent under 35 U.S.C. § 171, an issue that is often central in disputes over designs for functional articles.
  3. Finally, beyond patent law, a central issue will be the propriety of the Defendant's enforcement actions: Did the Defendant's infringement complaints to Amazon.com constitute tortious interference and unfair competition under state law? This may depend on whether the Defendant’s infringement assertions were objectively baseless or made in bad faith.