Dongguan Lianguang Electronics Technology Co Ltd v. Entities Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Lianguang Electronics Technology Co., Ltd. (China)
  • Defendant: The Entities, Partnerships and Unincorporated Associations Identified on Schedule A
  • Plaintiff’s Counsel: Pattishall, McAuliffe, Newbury, Hilliard & Geraldson LLP; Aitken Law Offices
• Case Identification: 1:25-cv-15023, N.D. Ill., 03/05/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendants target consumers in the Northern District of Illinois through interactive online stores and have shipped accused products into the district.
• Core Dispute: Plaintiff alleges that Defendants’ online sales of PUJIMAX brand rechargeable batteries infringe two U.S. design patents covering the ornamental appearance of batteries.
• Technical Context: The dispute is in the field of consumer rechargeable batteries, a highly competitive market where product appearance and distinctive design can be a significant commercial differentiator.
• Key Procedural History: The operative pleading is a First Amended Complaint. The case targets numerous online sellers, identified in an attached schedule, who are alleged to be an interconnected group operating through e-commerce platforms like Temu.com to sell infringing products.

Case Timeline

Date	Event
2021-04-01	Priority Date for U.S. Patent No. D965,512
2021-04-01	Priority Date for U.S. Patent No. D965,513
2022-10-04	U.S. Patent No. D965,512 Issues
2022-10-04	U.S. Patent No. D965,513 Issues
2023-01-01	Plaintiff begins selling products embodying the patented designs (stated as "since 2023")
2025-12-12	Plaintiff's agent places purchase orders for accused products
2026-03-05	First Amended Complaint Filed

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

U.S. Patent No. D965,512 - BATTERY

• Patent Identification: U.S. Patent No. D965,512, BATTERY, issued October 4, 2022.

The Invention Explained

• Problem Addressed: Design patents do not solve technical problems; they protect ornamental appearance. The patent protects a novel, non-functional aesthetic design for a battery to distinguish it from other products in the market.
• The Patented Solution: The patent claims the ornamental design for a battery as depicted in its seven figures ('512 Patent, claim). The design consists of a generally cylindrical battery body topped with a distinctive cap. Key ornamental features shown in the drawings include the cap's specific proportions relative to the body and a small, recessed notch on the side of the cap just below its top surface ('512 Patent, FIG. 7).
• Technical Importance: In the crowded consumer battery market, a unique and recognizable physical design can create brand identity and signal product quality to consumers (Compl. ¶¶2-3).

Key Claims at a Glance

• The single asserted claim is for "The ornamental design for a battery, as shown and described" ('512 Patent, claim).
• The essential visual elements of this design include:
  • A generally cylindrical body.
  • A cap with a raised central terminal.
  • A distinct, recessed notch on the side of the cap assembly.

U.S. Patent No. D965,513 - BATTERY

• Patent Identification: U.S. Patent No. D965,513, BATTERY, issued October 4, 2022.

The Invention Explained

• Problem Addressed: Similar to the '512 Patent, this patent protects a novel ornamental design for a battery, intended to create a distinct visual impression.
• The Patented Solution: The patent claims the specific ornamental design for a battery shown in its figures ('513 Patent, claim). This design features a cylindrical body and a unique cap structure. The cap is characterized by a two-tiered appearance with a wider upper section that includes a prominent, vertically-oriented recessed slot on its side ('513 Patent, FIG. 7). This side feature is visually distinct from the notch in the '512 Patent design.
• Technical Importance: This alternative design provides another avenue for creating a recognizable product appearance, helping consumers identify the source and quality of the battery in a marketplace with many visually similar products (Compl. ¶¶2-3).

Key Claims at a Glance

• The single asserted claim is for "The ornamental design for a battery, as shown and described" ('513 Patent, claim).
• The essential visual elements of this design include:
  • A generally cylindrical body.
  • A cap structure with a raised central terminal.
  • A prominent, vertically-oriented recessed slot on the side of the cap assembly.

III. The Accused Instrumentality

Product Identification

Rechargeable batteries marketed and sold under the PUJIMAX brand (Compl. ¶9).

Functionality and Market Context

The accused products are rechargeable batteries sold to U.S. consumers through various online storefronts on platforms such as Temu.com (Compl. ¶10). The complaint alleges that these products are "visually indistinguishable" from Plaintiff's patented designs and that Defendants have "flooded the market with imitation products" after recognizing the commercial success of Plaintiff's designs (Compl. ¶3; Compl. ¶35). The complaint includes a table with images of the accused PUJIMAX batteries, which are sold in various colors and feature prominent branding (Compl. p. 10).

IV. Analysis of Infringement Allegations

Design patent infringement is determined by 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. The analysis focuses on the overall visual impression created by the designs.

D965,512 Infringement Allegations

The complaint provides a side-by-side visual comparison of the patent's Figure 7 and images of accused products from different defendants (Compl. p. 10).

Patented Design Feature (as shown in Figures)	Alleged Infringing Feature (as shown in Complaint)	Complaint Citation
Overall cylindrical battery shape with a distinct cap.	The accused PUJIMAX batteries have an overall cylindrical shape and a distinct cap.	p. 10
A cap assembly with a raised central terminal and a specific height relative to the body.	The accused products' cap assembly appears to have similar proportions and a raised central terminal.	p. 10
A small, recessed notch on the side of the cap.	The accused products are depicted with a small, recessed notch on the side of the cap in a similar location and of a similar shape.	p. 10

D965,513 Infringement Allegations

The complaint provides a similar side-by-side visual comparison for the '513 patent design (Compl. p. 11).

Patented Design Feature (as shown in Figures)	Alleged Infringing Feature (as shown in Complaint)	Complaint Citation
Overall cylindrical battery shape with a distinct cap.	The accused PUJIMAX batteries have an overall cylindrical shape and a distinct cap.	p. 11
A cap assembly with a two-tiered appearance and a raised central terminal.	The accused products' cap assembly appears to have a similar two-tiered structure and a raised central terminal.	p. 11
A prominent, vertically-oriented recessed slot on the side of the cap.	The accused products are depicted with a prominent, vertically-oriented recessed slot on the side of the cap that appears to match the patented design's shape and placement.	p. 11

Identified Points of Contention

• Scope Questions: A central question will be whether the surface ornamentation on the accused products (e.g., the PUJIMAX brand name, color schemes, and other text) creates a sufficiently different overall visual impression to avoid infringement in the eye of an ordinary observer. Design patents protect the underlying shape and configuration, and the court will need to determine the weight given to these non-claimed surface features.
• Technical Questions: The court will compare the patented designs, which are shown in line drawings, with the accused products. A question may arise as to whether any minor differences in proportion or curvature between the patent drawings and the physical accused products are significant enough to alter the overall visual impression.

V. Other Allegations

Indirect Infringement

The complaint does not plead separate counts for induced or contributory infringement.

Willful Infringement

The complaint alleges that Defendants acted "knowingly and willfully" (Compl. ¶52). The basis for this allegation is that, upon information and belief, Defendants are "working in active concert" to copy commercially successful designs and are using "multiple storefronts and/or fictitious seller aliases" to conceal their identities and the scope of their operations (Compl. ¶40; Compl. ¶40a). The complaint also alleges Defendants had "actual and/or constructive knowledge" of their infringing activities (Compl. ¶44).

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

• A core issue will be one of visual perception: In applying the "ordinary observer" test, will a fact-finder conclude that the accused PUJIMAX batteries are substantially the same in overall ornamental appearance as the designs claimed in the '512 and '513 Patents, despite differences in surface branding, color, and texture not shown in the patent drawings?
• A key procedural question will be one of joinder and enforcement: Can the Plaintiff successfully establish that the numerous, pseudonymous online sellers listed in Schedule A constitute an "interconnected group" arising out of the "same series of transactions or occurrences" (Compl. ¶14)? Proving this connection will be critical for maintaining the case against all defendants and for any potential enforcement of a judgment.
• A potential defense may focus on functionality: The court may need to consider whether any of the claimed ornamental features, particularly the specific cap configurations, are primarily dictated by function (e.g., for compatibility with chargers or devices). If a design is primarily functional, it is not protectable by a design patent, a determination that could narrow the scope of protection.