Zhang v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: JJ Zhang (individual) (China)
  • Defendant: POPFAN MALL and the Individual and/or Entity Operating POPFAN MALL (China)
  • Plaintiff's Counsel: YK Law LLP
• Case Identification: 1:25-cv-12597, N.D. Ill., 10/30/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign entity believed to be based in the People's Republic of China, which is engaged in infringing activities and causing harm within the district by selling products to U.S. consumers, including those in Illinois.
• Core Dispute: Plaintiff alleges that Defendant's e-commerce sales of ceiling fans infringe a U.S. design patent for a "Fan with Light."
• Technical Context: The dispute centers on the ornamental design of enclosed or "caged" ceiling fans, a product category popular in home décor for its blend of industrial and rustic aesthetics.
• Key Procedural History: Plaintiff alleges that its own products embodying the patented design are well-established on Amazon and marked with the patent number. The complaint also alleges Defendant is part of a larger, coordinated scheme of e-commerce sellers who use aliases and other tactics to conceal their identities and evade enforcement of intellectual property rights.

Case Timeline

Date	Event
2022-09-22	'815 Patent Priority Date
2023-11-14	'815 Patent Issue Date
2025-10-30	Complaint Filing Date

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

• Patent Identification: U.S. Design Patent No. D1,004,815 ("the '815 Patent"), titled Fan with Light, issued November 14, 2023.

• The Invention Explained:

  • Problem Addressed: Design patents protect ornamental appearance rather than solving a technical problem. The implicit goal is to create a new, original, and non-obvious ornamental design for an article of manufacture, in this case, a ceiling fan U.S. Const. art. I, § 8, cl. 8
  • The Patented Solution: The '815 Patent claims the specific visual appearance of a flush-mount ceiling fan combined with a light fixture, as depicted in its figures '815 Patent, claim The design's primary features are a cylindrical, cage-like enclosure with a woven or lattice-style pattern surrounding the fan blades and light source '815 Patent, FIG. 1 '815 Patent, FIG. 3 The claim explicitly covers the ornamental appearance "as shown and described," with broken lines in the figures indicating that the internal mounting hardware and portions of the central motor housing are not part of the claimed design '815 Patent, description
  • Technical Importance: The complaint alleges that the popularity of this specific design has led to significant infringement by numerous e-commerce stores Compl. ¶16

• Key Claims at a Glance:

  • Design patents have a single claim. The asserted claim is: "The ornamental design for a fan with light, as shown and described." '815 Patent, claim
  • The "elements" of this claim are the visual features of the article depicted in solid lines in the patent's eight figures. This includes:
    • The overall cylindrical shape of the fan enclosure.
    • The specific lattice-work or woven pattern of the enclosure's side wall.
    • The shape and arrangement of the fan blades within the enclosure.
    • The visible portions of the central hub from which the blades extend.

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are "unauthorized and unlicensed products, namely the ceiling fans," sold by Defendant under the seller alias "POPFAN MALL" on e-commerce platforms such as Temu Compl. ¶1 Compl. ¶16

• Functionality and Market Context: The complaint alleges that the accused products are ceiling fans that embody the patented design Compl. ¶1 Compl. ¶27 The focus of the allegations is on the ornamental appearance of the products, which are alleged to "resemble Plaintiff's products so closely that they infringe" Compl. ¶29 The complaint frames Defendant as one of "numerous fully interactive e-commerce stores" targeting U.S. consumers on platforms like Amazon, Walmart, and Temu, suggesting a widespread market for such products Compl. ¶16

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or any images of the accused product. The infringement theory is articulated through a narrative based on the "ordinary observer" test, which is the governing standard for design patent infringement.

The complaint alleges that Defendant is making, using, selling, or importing ceiling fans that are visually "substantially the same" as the design claimed in the '815 Patent Compl. ¶28 The core of the allegation is that the resemblance between the accused products and the patented design "is such as to deceive such an observer, inducing ... purchase [of] one supposing it to be the other" (Compl. ¶28, quoting Egyptian Goddess, 543 F.3d 665, 676). The complaint asserts that an ordinary observer would be deceived into thinking the Defendant's products were the same as the Plaintiff's genuine products Compl. ¶28

• Identified Points of Contention:
  • Evidentiary Question: The central issue is factual: what is the specific appearance of the products sold by "POPFAN MALL"? The complaint's allegations are currently conclusory, and the analysis will depend entirely on a visual comparison between the accused product (once identified in discovery) and the drawings in the '815 Patent.
  • Scope Question: The analysis will require careful attention to the claimed versus unclaimed portions of the design. The infringement test will focus on the features shown in solid lines in the patent figures (e.g., the cage pattern) while ignoring those shown in broken lines (e.g., the mounting plate), as the latter form no part of the claimed design '815 Patent, description Any differences in these unclaimed areas would be irrelevant to the infringement analysis.

V. Key Claim Terms for Construction

In design patent litigation, formal claim construction of written terms is rare. The "claim" is understood to be the visual design depicted in the patent's figures. The analysis, therefore, centers on interpreting the scope of these drawings.

• The "Term": "The ornamental design... as shown and described"
• Context and Importance: This phrase incorporates the patent's drawings as the definition of the claim. The entire infringement analysis hinges on comparing the overall visual impression of the accused product with the design shown in these drawings. Practitioners will focus on the scope of the drawings-specifically, what is included and excluded from the claimed design.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim covers the design as applied to a "fan with light," and the consistent depiction across eight different views (perspective, front, back, top, bottom, etc.) defines a complete, three-dimensional appearance '815 Patent, FIGS. 1-8 This suggests the claim protects the overall visual effect of the design from multiple angles.
  • Evidence for a Narrower Interpretation: The patent specification explicitly states, "The broken lines shown in the drawings and the ghosted area(s) within the broken lines show portions of the fan with light that form no part of the claimed design" '815 Patent, description This acts as a disclaimer, limiting the scope of the patent to the specific ornamental features shown in solid lines (the cage, blades, etc.) and preventing the patent owner from claiming infringement based on similarities in the functional, unclaimed mounting hardware.

VI. Other Allegations

• Indirect Infringement: The prayer for relief requests an injunction against "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" the patent Compl. prayer ¶1(b) However, the factual allegations in the body of the complaint focus on Defendant's own direct infringement by making, using, and selling the accused products Compl. ¶27
• Willful Infringement: The complaint alleges that Defendant "has knowingly, and willfully infringed the Design Patent" Compl. ¶23 This allegation is supported by claims that Defendant is part of an "interrelated group of e-commerce sellers" who use tactics like aliases and offshore accounts to consciously evade intellectual property laws and potential judgments Compl. ¶¶1, 13, 20-22 Plaintiff seeks treble damages for this alleged willful conduct Compl. prayer ¶4

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

1. A core evidentiary question will be one of visual comparison: Does the accused "POPFAN MALL" ceiling fan, once identified and presented to the court, create an overall visual impression substantially the same as the design claimed in the '815 Patent in the eyes of an ordinary observer? The complaint's complete lack of visual evidence of the accused product makes this the central, unresolved issue upon which the case will turn.
2. A key threshold question will be one of identity and liability: Can the Plaintiff successfully link the "POPFAN MALL" seller alias to a specific, legally responsible entity and prove that it conducted the alleged infringing sales? The complaint's extensive allegations of a deliberate scheme to conceal identity Compl. ¶¶1, 11, 13, 19-21 suggest that piercing this anonymity will be a critical and potentially challenging step in the litigation.