Shenzhen Jiyou Supply Chain Co Ltd v. Individuals Corps Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Jiyou Supply Chain Co. LTD. (People's Republic of China)
  • Defendant: Dongguan Huangjiang Jinliangtang Hardware Factory (People's Republic of China)
  • Plaintiff's Counsel: LW Legal LLC
• Case Identification: 1:25-cv-06464, N.D. Ill., 08/29/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant is not a resident of the United States and may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant's watch bands infringe a U.S. design patent covering the ornamental design of a watch band.
• Technical Context: The dispute is in the consumer electronics accessory market, specifically concerning the aesthetic and ornamental design of third-party bands for smartwatches.
• Key Procedural History: The filing is a Second Amended Complaint. The complaint asserts that Plaintiff's products are marked in compliance with 35 U.S.C. § 287(a), which may be relevant to damages and claims of willful infringement.

Case Timeline

Date	Event
2022-11-15	'089 Patent - Earliest Foreign Priority Date
2023-05-16	'089 Patent - Issue Date
2025-08-29	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. D986,089, "Watch Band," issued May 16, 2023.

U.S. Patent No. D986,089 - "Watch Band"

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture. The implicit problem addressed is the need for a novel, non-obvious, and ornamental design that distinguishes a product-in this case, a watch band-from others in the marketplace.
• The Patented Solution: The patent claims the specific ornamental design for a watch band as depicted in its figures '089 Patent, claim The design features a wide band with a distinct central portion containing several transverse segments overlaid with a criss-cross lacing or cord pattern '089 Patent, FIG. 1 '089 Patent, FIG. 3 The design creates a rugged, "tactical" aesthetic.
• Technical Importance: In the crowded market for smartwatch accessories, unique ornamental designs serve as a key product differentiator, allowing manufacturers to establish a recognizable brand identity and capture consumer interest based on aesthetics.

Key Claims at a Glance

• As a design patent, the '089 Patent contains a single claim for "The ornamental design for a watch band, as shown and described" '089 Patent, claim
• The scope of the claim is defined by the solid lines in the patent's drawings. The key visual elements constituting the overall design include:
  • The overall shape, proportions, and configuration of the watch band.
  • A central, raised portion featuring multiple rectangular segments.
  • A criss-cross "X" pattern lacing that extends over the central segmented portion.
  • The specific shape of the end pieces designed to connect to a watch case.

III. The Accused Instrumentality

Product Identification

• The accused products are watch bands offered for sale, sold, and imported by the Defendant ('Compl. ¶4).

Functionality and Market Context

• The complaint alleges Defendant sells the accused watch bands through at least one e-commerce store on Alibaba.com, targeting consumers in the United States ('Compl. ¶13; Compl. ¶14). The core allegation is not about the product's function but its appearance, which is alleged to be the "same design as the patented design" ('Compl. ¶15).

IV. Analysis of Infringement Allegations

The standard for design patent infringement is the "ordinary observer" test, which asks 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 complaint alleges that the designs are the same ('Compl. ¶15). A side-by-side comparison is provided in the complaint to support the allegation of visual similarity ('Compl. ¶15).

'089 Patent Infringement Allegations

Claim Element (from the Design)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a watch band, as shown and described.	Defendant's product is alleged to have the "same design as the patented design."	¶15	'089 Patent, col. 1:57-58
The overall visual impression created by the combination of the band's shape, segmented central panel, and criss-cross lacing pattern.	The complaint presents a side-by-side image comparison suggesting the overall visual appearance of the accused product is identical to the patented design.	¶15	'089 Patent, col. 1:64-66

• Identified Points of Contention:
  • Scope Questions: The primary question will be whether the accused product's design is "substantially the same" as the claimed design in the eyes of an ordinary observer. Any minor differences between the accused product and the patent figures will be a focal point of the dispute.
  • Technical Questions: A potential defense could be that certain features of the design are primarily functional rather than ornamental. For example, a question might be raised as to whether the criss-cross lacing pattern serves a functional purpose (e.g., securing items, adjusting fit) that would remove it from the scope of design patent protection.

V. Key Claim Terms for Construction

In design patent litigation, claim construction is typically not focused on interpreting written terms but on determining the overall scope of the claimed design as shown in the drawings. The key "term" is the design itself.

• The Term: "The ornamental design for a watch band"
• Context and Importance: The central issue will be the scope of the claimed design and what constitutes the "overall visual impression." The court's interpretation of this scope will determine the infringement analysis. Practitioners may focus on which features are ornamental and which, if any, are functional and thus unprotectable.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent discloses three different embodiments of the design '089 Patent, FIG. 1 '089 Patent, FIG. 9 '089 Patent, FIG. 17 Plaintiff may argue that the claim covers the common visual elements shared across these embodiments, suggesting a broader scope of protection not limited to a single depiction.
  • Evidence for a Narrower Interpretation: The patent explicitly disclaims matter shown in broken lines, stating it "form[s] no part of the claimed design" '089 Patent, p. 4 A defendant would argue that the claim is strictly limited to the exact visual features shown in solid lines, and any deviation in the accused product defeats the infringement claim.

VI. Other Allegations

• Indirect Infringement: The complaint includes a conclusory allegation of indirect infringement ('Compl. ¶19) but does not plead specific facts to support the knowledge and intent elements required for a claim of induced or contributory infringement.
• Willful Infringement: The complaint alleges willful infringement ('Compl. ¶17). This allegation may be supported by the claim that Plaintiff's products are marked with the patent number ('Compl. ¶11). A screenshot of an Amazon.com listing for Plaintiff's product highlights the patent marking notice, which could be used to argue that Defendant had constructive or actual notice of the patent ('Compl. ¶9).

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

1. Infringement: Is the overall ornamental appearance of Defendant's accused watch band "substantially the same" as the design claimed in the '089 patent from the perspective of an ordinary observer, such that the observer would be deceived?
2. Validity: Can the Defendant identify prior art designs that are close enough to the '089 patent's design to render the patent invalid as anticipated or obvious, or alternatively, to narrow the patent's scope so it no longer covers the accused product?
3. Scope and Functionality: A central question may be whether key visual elements of the claimed design, such as the criss-cross lacing over a segmented panel, are dictated by function. If the court finds these elements to be primarily functional, they would be excluded from the scope of the design patent, potentially weakening the infringement case.