Shenzhen Chenying Technology Co Ltd v. Apple Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Chenying Technology Co., Ltd. (d/b/a Chen Ying Ke Ji)
  • Defendant: Apple Inc. (Cupertino, California)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 5:26-cv-5485, N.D. Cal., 06/08/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant Apple Inc. is identified on the face of the asserted patent as being located in Cupertino, which is within the district, and the action concerns Apple’s assertion of that patent.
• Core Dispute: Plaintiff seeks a declaratory judgment that its portable power banks do not infringe Defendant’s design patent for a connector, and/or that the design patent is invalid because its features are dictated by function.
• Technical Context: The technology concerns the ornamental design of an electrical connector head, specifically the design associated with Apple's Lightning connector, which is widely used for charging and data transfer in mobile electronic devices.
• Key Procedural History: The dispute arose from an intellectual property complaint Apple submitted to Amazon's enforcement platform, which alleged that Plaintiff's products infringe the asserted design patent and threatened removal of Plaintiff's product listings. The complaint's primary invalidity argument centers on allegations that Apple’s own family of related utility patents describe the functional and utilitarian purposes of the same connector features claimed as ornamental in the design patent-in-suit.

Case Timeline

Date	Event
2012-07-06	D'539 Patent Priority Date (Application Filing)
2012-09-07	Earliest Filing Date for Related Apple Utility Patents
2013-01-25	Preliminary Amendment Filed in D'539 Patent Prosecution
2013-06-18	D'539 Patent Issue Date
2026-06-05	Amazon Performance Notification Issued to Plaintiff
2026-06-08	Complaint for Declaratory Judgment Filed

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

• Patent Identification: U.S. Design Patent No. D684,539, titled “Connector,” issued June 18, 2013 (the “D’539 Patent”).

The Invention Explained

• Problem Addressed: As a design patent, the D’539 Patent does not contain a background section describing a technical problem. The complaint, however, frames the context not as an ornamental design choice but as a solution to functional requirements, such as the need for reversible insertion, electrical mating, and physical retention within a device (Compl. ¶¶41-43; Compl. ¶74).
• The Patented Solution: The patent claims the ornamental design for a connector head as depicted in solid lines in its figures (D’539 Patent, claim; D’539 Patent, Figs. 1-8). The design consists of the visual appearance of the connector plug itself, which includes a thin, rounded-rectangular profile and a specific layout of contacts on its face (Compl. ¶22). The patent explicitly disclaims the portions shown in broken lines, such as the attached cable housing, stating they "form no part of the claimed design" (D’539 Patent, description).
• Technical Importance: The complaint alleges that the features comprising the claimed design are not arbitrary ornamentation but are instead "deeply intertwined with, the utilitarian requirements of a Lightning-compatible connector" (Compl. ¶46).

Key Claims at a Glance

• The D’539 Patent contains a single claim for "The ornamental design for a connector, as shown and described" (D’539 Patent, claim; Compl. ¶18).
• The core visual elements of the claimed design, as shown in solid lines in the patent figures, include:
  • A thin, rounded-rectangular plug profile.
  • A specific face and surface contact arrangement.
  • Side contour features.

III. The Accused Instrumentality

Product Identification

The accused products are Plaintiff Chenying’s portable chargers and power banks, including those sold under the "charmast" brand, which feature built-in, Lightning-compatible connector heads (Compl. ¶¶56-58). The complaint identifies twenty unique Amazon Standard Identification Numbers (ASINs) for the accused products (Compl. ¶55).

Functionality and Market Context

The products are accessories designed to provide power to electronic devices such as iPhones, iPads, and AirPods via an integrated cable and connector (Compl. ¶56). The complaint alleges that Apple's infringement assertion through Amazon's marketplace has impaired Chenying’s ability to sell these products and created an immediate risk of removal from the platform (Compl. ¶¶48-49; Compl. ¶59). Product photographs attached as Exhibit I to the complaint show representative accused portable chargers and power banks with integrated Lightning-compatible connector heads (Compl. ¶57).

IV. Analysis of Infringement Allegations

As this is an action for declaratory judgment of non-infringement, the following chart summarizes Chenying’s characterization of Apple's infringement theory and its primary defense that any similarities are dictated by function.

D'539 Patent Infringement Allegations

Claim Element (from the D'539 Patented Design)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a connector, as shown and described.	Chenying’s products are portable chargers and power banks that include integrated, Lightning-compatible connector heads. The complaint alleges that Apple's accusation is based on the mere presence of these functional connector heads.	¶66	description
Thin, rounded-rectangular plug profile.	The accused connector heads incorporate a thin plug profile, which the complaint alleges is a functional feature for insertion and mating with a corresponding receptacle.	¶64; ¶73	description
A face and surface contact arrangement.	The accused connector heads include a contact arrangement that is compatible with Apple devices. The complaint alleges this is dictated by the functional need for electrical contact and orientation detection.	¶64; ¶73	description
Side contour features.	The accused connector heads include side features, which the complaint alleges serve the functional purpose of retaining the connector within a mating receptacle.	¶64; ¶73	description

• Identified Points of Contention:
  • Functionality vs. Ornamentation: The central dispute is whether the D'539 Patent claims a valid ornamental design or whether the design is "dictated by function" (Compl. ¶71). Chenying alleges that Apple’s own related utility patents demonstrate that the key features of the connector head—its profile, contact layout, and retention features—serve utilitarian purposes, which may render the design patent invalid or unenforceable (Compl. ¶¶46, 75).
  • Scope of Comparison: A key question for the infringement analysis will be how to apply the "ordinary observer" test. Chenying argues that when the comparison is properly limited to "protectable ornamental features" and excludes "unprotectable functional connector features," an ordinary observer would not find the accused products embody the claimed design (Compl. ¶68).

V. Key Claim Terms for Construction

In design patent litigation, the dispute is often not over the meaning of a specific word but over the scope of the claimed design as a whole, specifically what is ornamental versus functional.

• The Term: "ornamental design"
• Context and Importance: The determination of what constitutes the "ornamental design" is case-dispositive. If the features that create the overall visual impression of the connector are found to be primarily functional, the patent may be held invalid under 35 U.S.C. § 171. Practitioners may focus on this issue because Chenying has presented extensive allegations based on Apple's own utility patents to support its functionality argument.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation (More Ornamental): The D'539 Patent was examined and issued by the U.S. Patent and Trademark Office, which provides a presumption of validity. The complaint notes that the prosecution history does not reflect a substantive rejection on the grounds of functionality (Compl. ¶25). The patent figures depict a specific visual appearance for the connector head (D’539 Patent, Figs. 1-8).
  • Evidence for a Narrower Interpretation (More Functional): The complaint alleges that a family of Apple's own utility patents, which were considered during the D'539 patent's prosecution, describe the utilitarian benefits of the claimed features (Compl. ¶¶39-40). For example, it is alleged that these utility patents describe the "thin tab profile" as serving the function of reversible insertion (Compl. ¶41), the side features as serving the function of retention (Compl. ¶43), and the contact arrangement as serving orientation detection and electrical configuration (Compl. ¶44).

VI. Other Allegations

• Indirect Infringement: The complaint does not address indirect infringement.
• Willful Infringement: Willful infringement is not at issue in this declaratory judgment action brought by the accused infringer.

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

This case appears poised to revolve around two fundamental and interrelated questions at the heart of design patent law.

• A core issue will be one of validity: Is the claimed "ornamental design" of the D’539 patent invalid because it is "dictated by function"? The resolution will likely depend on the weight the court gives to evidence from Apple's own related utility patents, which Plaintiff alleges prove the functional necessity of the connector's shape, contact layout, and retention features.
• A second key issue will be the scope of the infringement analysis: In applying the "ordinary observer" test, to what extent must the allegedly functional aspects of the connector design be filtered out before comparing the patented design to the accused products? This raises an evidentiary and legal question of whether any remaining ornamental features are substantial enough to cause an ordinary observer to be deceived.