DCT

1:26-cv-21233

Pearsons Luggage & Gifts v. Zhongchuang Jiutong Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-21233, S.D. Fla., 02/24/2026
  • Venue Allegations: The complaint asserts that venue is proper in the district pursuant to 28 U.S.C. § 1391.
  • Core Dispute: Plaintiff seeks a declaratory judgment that Defendant's U.S. design patent for a storage bin is invalid and unenforceable, following Defendant's use of that patent to remove Plaintiff's product listings from an e-commerce platform.
  • Technical Context: The dispute centers on the ornamental design of plastic storage bins, a widely produced and commercially significant consumer product category.
  • Key Procedural History: The complaint alleges that after obtaining the U.S. patent-in-suit, Defendants sent infringement notices to Amazon.com, which resulted in the removal of Plaintiff's product listings. Plaintiff alleges the U.S. patent is invalid as anticipated by Defendants' own prior Chinese and European design patents.

Case Timeline

Date Event
2020-08-04 Chinese Design Patent CN305961397S Issued (Compl. ¶12)
2022-03-04 European Union Design Patent EU008867147 Issued (Compl. ¶14)
2023-07-07 U.S. Design Patent D1,106,675S Application Filed ('675 Patent, (22))
2025-12-23 U.S. Design Patent D1,106,675S Issued (Compl. ¶10)
Jan-Feb 2026 Plaintiff received infringement notices from Amazon (Compl. ¶19)
2026-02-24 Complaint for Declaratory Judgment Filed (Compl. p. 1)

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

U.S. Patent No. D1,106,675 S - "Storage box"

  • Patent Identification: U.S. Design Patent No. D1,106,675 S, "Storage box," issued December 23, 2025 (the "'675 Patent").

The Invention Explained

  • Problem Addressed: Design patents do not solve technical problems; they protect the novel, non-obvious ornamental appearance of an article of manufacture (Compl. ¶24; '675 Patent, Claim). The patent is directed to establishing a proprietary aesthetic for a storage box.
  • The Patented Solution: The '675 Patent claims the specific ornamental design for a storage box as depicted in its nine figures ('675 Patent, Claim). The design features a rectangular bin with tapered sides, vertical reinforcing ribs along the side walls, a reinforced upper lip, and a lid with a series of parallel raised ridges ('675 Patent, FIGS. 1, 3, 7). The complaint includes several figures from the patent to illustrate the claimed design (Compl. ¶11).
  • Technical Importance: The claimed design provides a specific visual appearance for a common consumer product, which can be a key differentiator in a competitive market.

Key Claims at a Glance

  • Design patents typically have a single claim. The asserted claim is: "The ornamental design for a storage box as shown and described" ('675 Patent, Claim). The scope of this claim is defined by the solid lines in the patent's drawings ('675 Patent, Description).

III. The Subject Instrumentality

Product Identification

  • The products subject to the infringement notices are "packs of different sized plastic storage bins" sold by Plaintiff on Amazon.com under various Amazon Standard Identification Numbers (ASINs) (Compl. ¶¶7, 9).

Functionality and Market Context

  • The complaint describes the products as plastic storage bins sold on e-commerce platforms like Amazon.com (Compl. ¶¶6-8). Images in the complaint depict clear and opaque stackable bins with lids, consistent with common consumer storage solutions (Compl. p. 3).
  • Plaintiff alleges it has been "tremendously successful" in selling these products for years on multiple online platforms, suggesting they hold a significant market position that was disrupted by the delisting (Compl. ¶8). An image provided in the complaint shows examples of the Plaintiff's plastic storage bins that were sold online (Compl. p. 3).

IV. Analysis of Invalidity Allegations

The central count of the complaint is a request for a declaratory judgment of invalidity and unenforceability, not a direct allegation of infringement (Compl. ¶¶22-30). Plaintiff's invalidity argument is based on alleged anticipation by prior art, specifically a Chinese and an EU design patent allegedly owned by or listing the Defendant as an inventor (Compl. ¶¶12, 14, 17-18, 26-27). The complaint alleges that these earlier patents fully disclose the design claimed in the '675 Patent.

The complaint includes images comparing the designs of the '675 Patent, the Chinese Patent, and the EU Patent (Compl. ¶¶11, 13, 15). It alleges that the Chinese and EU patents "contain no visual differences" from each other and that "all design features of the US Patent have been fully disclosed by both the Chinese Patent and the EU Patent" (Compl. ¶¶16-17).

V. Key Claim Terms for Construction

  • The Term: The ornamental design for a storage box as shown and described.
  • Context and Importance: In design patent cases, the analysis does not typically center on construing specific textual terms. Instead, the court applies the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. Here, the same test will be applied to assess validity: whether an ordinary observer would find the design of the '675 patent to be substantially the same as the designs in the prior art Chinese and EU patents.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim is not limited to a specific material or color, and the use of broken lines in the figures explicitly disclaims certain portions of the storage box, potentially broadening the scope of the claimed design to cover only the elements shown in solid lines ('675 Patent, Description).
    • Evidence for a Narrower Interpretation: The scope of a design patent is strictly limited to the specific ornamental features depicted in the drawings. Any deviation in the visual appearance between the '675 Patent design and the prior art could potentially support a finding of validity. The specific arrangement and proportions of the ribs, lid features, and overall shape as shown in Figures 1-9 define the precise scope of the claim ('675 Patent, FIGS. 1-9).

VI. Other Allegations

  • Unenforceability / Fraud on the USPTO: The complaint alleges that the '675 Patent is unenforceable due to "fraudulent misrepresentations to the USPTO regarding the US Patent’s design ‘originality’ and compliance with statutory requirements" (Compl. ¶25). Plaintiff asserts that because the design was fully disclosed in the prior Chinese and EU patents, the '675 Patent "contains no original elements undisclosed by prior art" (Compl. ¶27). This suggests a potential argument that Defendants breached their duty of candor by failing to disclose material prior art to the USPTO during prosecution.

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

  • A core issue will be one of validity based on anticipation: Would an ordinary observer, viewing the design of the '675 Patent and the designs of the prior art Chinese and EU patents, consider the designs to be substantially the same? The Plaintiff's assertion of "no visual differences" will be tested against the legal standard for anticipation in design patents (Compl. ¶16).
  • A second key issue will be one of enforceability: Did the Defendants engage in inequitable conduct by failing to disclose the Chinese and EU patents to the USPTO during the prosecution of the '675 Patent application? The court may need to determine if these prior art patents were material and if there was an intent to deceive the patent office.