Kaoudt US Direct v. Hezhida Zhangzhou Medical Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhenshi Jiayuhedi Dianzishangwu Youxiangongsi dba Adracy Health and Shenzhenlengchao Shangmao Youxiangongsi dba Kaoudt US Direct (People's Republic of China)
  • Defendant: Hezhida (Zhangzhou) Medical Technology Co., Ltd. (People's Republic of China)
  • Plaintiff’s Counsel: Markingpost IP Law, PLLC
• Case Identification: 2:26-cv-00096, W.D. Wash., 01/16/2026
• Venue Allegations: Plaintiffs allege venue is proper because Defendant is a foreign entity not resident in the United States.
• Core Dispute: Plaintiffs seek a declaratory judgment that their red light therapy mat products do not infringe Defendant’s design patent and/or that the patent is invalid.
• Technical Context: The dispute concerns the ornamental design of red light therapy mats, a consumer product category within the health and wellness market.
• Key Procedural History: The action was precipitated by Defendant lodging an intellectual property infringement complaint against Plaintiffs' products through Amazon.com's enforcement system, leading to the removal or threatened removal of Plaintiffs' product listings. Plaintiffs allege the patented design was on sale more than a year prior to the patent's filing date, which if proven, would invalidate the patent under 35 U.S.C. § 102.

Case Timeline

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

U.S. Design Patent No. D1,069,141 - "THERAPY MAT"

• Patent Identification: U.S. Design Patent No. D1,069,141, "THERAPY MAT," issued April 1, 2025 (’141 Patent).

The Invention Explained

• Problem Addressed: Design patents do not solve technical problems; they protect the novel, non-obvious, and ornamental appearance of an article of manufacture. The ’141 Patent claims a specific visual design for a therapy mat.
• The Patented Solution: The patent claims the ornamental design for a therapy mat as depicted in its figures (’141 Patent, Claim). The design features a generally rectangular mat with a smaller, rounded extension on one end (’141 Patent, FIG. 1, 7). The top surface is characterized by a dense, uniform grid of circular dots, and the perimeter is defined by stitching, which is claimed as part of the design (’141 Patent, FIG. 1; Description). The mat is shown as a single, integral piece without any visible external hardware, logos, or branding (’141 Patent, FIGS. 1-8).
• Technical Importance: The complaint alleges that the therapy mat design field is a "crowded field," suggesting that subtle differences in ornamental design may be sufficient to distinguish products in the marketplace Compl. ¶25

Key Claims at a Glance

• The single claim asserted is for "the ornamental design for a therapy mat, as shown and described" (’141 Patent, Claim).
• The essential visual elements defined by the drawings include:
  • A specific overall shape, consisting of a primary rectangular body and a narrower, rounded end portion.
  • A surface pattern of dense, uniformly spaced circular dots.
  • Stitching along the perimeter.
  • The absence of any surface branding, logos, or external hardware like buckles or connectors.

III. The Accused Instrumentality

Product Identification

Plaintiffs' red light therapy mats sold under the "ADRACY" and "Kaoudt" brands, identified by Amazon ASINs B0DM6Q33BD, B0F9KVJGFQ, B0F2DYZDZC, B0F6FFX8SW, B0F472YM4R, B0CY8L73GC, and B0FHK16Y9W Compl. ¶16

Functionality and Market Context

The Accused Products are described as red light therapy mats sold on the Amazon marketplace Compl. ¶15 The complaint alleges that the Amazon marketplace is Plaintiffs' primary sales channel into the United States Compl. ¶17 The complaint includes a side-by-side visual comparison of the patented design and the Accused Products, showing mats with prominent branding and square-shaped LED elements Compl. p. 7

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the distinctions Plaintiffs allege between their products and the patented design to support their non-infringement claim.

D1,069,141 Non-Infringement Allegations

Identified Points of Contention

The central question for infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing Plaintiffs' product believing it to be the patented design.

• Scope Questions: The dispute may turn on whether the alleged differences—branding, hardware, and LED shape/spacing—are significant enough to create a different overall visual impression, or if they are minor details that an ordinary observer would overlook.
• Technical Questions: A key factual question is how the "crowded field" of prior art for therapy mats affects the scope of the ’141 Patent Compl. ¶25 If the field is indeed crowded, small differences between the patented design and the accused product may be sufficient to avoid infringement.

V. Key Claim Terms for Construction

In a design patent, the "claim" is the visual design depicted in the drawings. The scope is determined by the overall visual impression of those drawings, not by textual terms. However, conventions within the drawings themselves can be critical to interpreting that scope.

• The Feature: Broken lines representing stitching
• Context and Importance: The patent's description states, "The broken lines representing stitching are part of the claimed design" (’141 Patent, Description). The complaint also notes that the patent claims "all broken lines as part of the design," which it argues "effectively narrows its claim scope" Compl. p. 7 The interpretation of these lines is critical because features shown in broken lines can either be part of the claimed design or merely show environmental context that is not claimed. Here, the patentee has explicitly stated the stitching is part of the claimed design.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the specific stitching pattern is merely one ornamental feature among many and that the overall shape and dot pattern are the dominant visual elements.
  • Evidence for a Narrower Interpretation: Plaintiffs argue that explicitly claiming the stitching pattern limits the design's scope to only mats with that particular stitching Compl. p. 7 An ordinary observer, they may contend, would notice differences in stitching, and this claimed element further distinguishes the patent from products that lack this specific feature.

VI. Other Allegations

This section is not applicable as the complaint is for declaratory judgment and does not contain counts for indirect or willful infringement. Plaintiffs do, however, allege that Defendant's actions were taken in bad faith by lodging a "meritless" Amazon complaint and seek attorneys' fees Compl. ¶13, ¶18; Prayer for Relief D

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

This case appears to center on two fundamental and distinct questions for the court:

1. A core issue will be one of validity: did the public sale of an identical product on Amazon, beginning on the alleged date of May 22, 2023, occur more than one year before the patent's September 14, 2023 filing date? If Plaintiffs can prove this fact, it would render the ’141 Patent invalid under the on-sale bar of 35 U.S.C. § 102.
2. A key question on the merits of infringement will be one of overall visual impression: in the context of a potentially "crowded field" of similar therapy mat designs, would an ordinary observer be deceived by the similarities in overall shape, or would the alleged differences in the LED grid pattern, prominent branding, and visible hardware on the accused products create a patently distinct design?