Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: valuebattery21 (People's Republic of China or other foreign jurisdictions)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:26-cv-00639, N.D. Ill., 01/22/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant's operation of an interactive e-commerce store that targets consumers in the United States, including Illinois, offers shipping to Illinois, accepts payment in U.S. dollars, and has allegedly sold infringing products to Illinois residents.
• Core Dispute: Plaintiff alleges that Defendant’s sale of replacement battery packs via an online storefront infringes a U.S. design patent owned by Dyson.
• Technical Context: The dispute is in the consumer electronics accessories market, specifically concerning the ornamental design of battery packs for high-end cordless vacuums, where visual brand identity is a key market differentiator.
• Key Procedural History: The filing is an Amended Complaint against an e-commerce operator whose specific identity Plaintiff alleges is concealed through the use of seller aliases and other tactics.

Case Timeline

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

U.S. Design Patent No. D710,299 - "BATTERY PACK"

The patent-in-suit is U.S. Design Patent No. D710,299, issued August 5, 2014 (the "’299 Patent").

The Invention Explained

• Problem Addressed: As a design patent, the '299 Patent does not address a functional problem. Instead, it serves to protect a unique ornamental appearance for a product. The complaint asserts that Dyson's products are known for their "distinctive patented designs," which are "broadly recognized by consumers" and associated with quality and innovation Compl. ¶8
• The Patented Solution: The patent claims the specific ornamental design for a battery pack, as depicted in its seven figures '299 Patent, claim The design consists of the visual characteristics of the item, including a rectangular base with rounded ends and a prominent, angular vertical structure for attachment '299 Patent, FIG. 1 The scope of the protected design is limited to the elements shown in solid lines, while elements shown in broken lines illustrate environmental structure and are not part of the claimed design '299 Patent, description
• Technical Importance: The complaint alleges that the distinctive appearance of Dyson products, including designs like the one patented, have become "iconic" and are "instantly recognizable as such" by the public Compl. ¶5

Key Claims at a Glance

• The '299 Patent contains a single claim for "the ornamental design for a battery pack, as shown and described" '299 Patent, claim
• The elements of this design claim are the collective visual features of the battery pack as a whole, including:
  • The overall configuration and shape of the pack as depicted in the patent's figures from multiple perspectives (perspective, front, rear, side, top, and bottom).
  • The specific contours of the main rectangular body and the distinct shape of the vertical attachment neck.
  • The claimed design is for the overall visual impression created by these features in combination, not for any individual feature in isolation.

III. The Accused Instrumentality

Product Identification

The accused products are "unauthorized and unlicensed" battery packs sold by Defendant on an e-commerce store operating under the seller alias "valuebattery21" Compl. ¶¶2-3 The complaint refers to these collectively as the "Infringing Products" Compl. ¶3

Functionality and Market Context

The complaint alleges the accused products are sold through a "fully interactive, e-commerce store" that targets U.S. consumers Compl. ¶12 It further alleges that the store "appears sophisticated" and uses "content and images that make it very difficult for consumers to distinguish such stores from an authorized retailer" Compl. ¶15 Defendant is not an authorized retailer of genuine Dyson products Compl. ¶15

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or a side-by-side visual comparison of the accused product with the patented design. The infringement allegation is based on the assertion that the Defendant's products embody the ornamental design claimed in the '299 Patent Compl. ¶24 To illustrate the claimed design, the complaint presents the patent's own drawings, including a perspective view from Figure 1 of the '299 Patent Compl. p. 4 As the complaint does not provide a descriptive mapping of the accused product's features onto the claim, a comparative claim chart cannot be constructed.

• Identified Points of Contention:
  • Visual Similarity: The central question for the court will be whether an "ordinary observer," familiar with the prior art designs, would be deceived into purchasing the accused product believing it to be the patented design. This will require a direct visual comparison of the accused product's design and the design claimed in the '299 Patent's figures.
  • Claim Scope: The analysis will focus on the patented design as a whole, as shown in the solid lines of the patent's drawings. A potential dispute may arise over whether differences between the accused product and the patented design are minor and do not change the overall visual impression, or if they are significant enough to place the accused product outside the scope of the claim.

V. Key Claim Terms for Construction

In design patent cases, the claim is defined by the drawings, and detailed verbal construction of terms is less common than in utility patent cases. The "term" for construction is the overall visual appearance of the claimed design.

• The Term: "The ornamental design for a battery pack, as shown and described" '299 Patent, claim
• Context and Importance: The scope of this "term" is the entire case. The infringement analysis will hinge on how broadly or narrowly the court construes the visual impression protected by the '299 Patent's figures. Practitioners may focus on the overall visual effect created by the combination of claimed features, rather than on any single feature in isolation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party may argue that the claim covers any design with the same overall visual impression, and that minor variations in proportion or surface detail on an accused product do not avoid infringement. The claim is for the design "as shown and described," suggesting the overall concept is protected.
  • Evidence for a Narrower Interpretation: A party may argue that the claim is strictly limited to the exact shapes, contours, and proportions depicted in the solid lines of the patent's seven figures. The patent's description explicitly states that the broken lines "form no part of the claimed design," which strictly defines the boundaries of what is protected '299 Patent, description Any deviation from the solid-line features could support an argument of non-infringement.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain factual allegations to support a claim for indirect (induced or contributory) infringement. The prayer for relief includes a request to enjoin "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing acts, but the complaint's narrative focuses exclusively on the Defendant's own direct infringement Compl., prayer 1(b)
• Willful Infringement: The complaint alleges that Defendant "has knowingly and willfully" infringed the '299 Patent Compl. ¶20, and that the infringement was "willful" Compl. ¶21 The basis for this allegation is Defendant's alleged sale of products that infringe a patented design without authorization from Dyson Compl. ¶20

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

• A core issue will be one of visual comparison: does the accused battery pack sold by "valuebattery21" create substantially the same overall visual impression in the eyes of an ordinary observer as the design claimed in the '299 patent? The outcome will depend entirely on a factual comparison of the accused product (which is not pictured in the complaint) to the patent's drawings.
• A key threshold question will be jurisdictional and procedural: can Dyson successfully establish the identity of the defendant, prove personal jurisdiction over a foreign e-commerce operator, and gather evidence of the specific acts of making, offering for sale, or selling that allegedly occurred in the United States? The complaint's allegations regarding the defendant's use of aliases and other concealment tactics suggest this may be a significant focus of the litigation Compl. ¶¶10-11 Compl. ¶¶16-19