Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: zhenjiangjushengpeng_0 (People's Republic of China or other foreign jurisdiction)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:26-cv-00748, N.D. Ill., 01/26/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant targets business activities toward consumers in the United States, including Illinois, through an interactive e-commerce store, offers shipping to Illinois, and has allegedly sold infringing products to Illinois residents.
• Core Dispute: Plaintiff alleges that Defendant’s online sale of battery packs infringes a U.S. design patent covering the ornamental design for a battery pack.
• Technical Context: The dispute concerns the proprietary ornamental design of accessory components, specifically battery packs for consumer electronics like cordless vacuums, where distinctive aesthetics can be a key market differentiator.
• Key Procedural History: The complaint is filed against a seller alias, a common tactic in e-commerce enforcement actions where the true identity of the defendant is initially unknown. The plaintiff notes that it will amend the complaint if the defendant's identity is discovered.

Case Timeline

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

U.S. Patent No. D710,299 - "Battery pack"

• Patent Identification: U.S. Patent No. D710,299, "Battery pack," issued August 5, 2014.

The Invention Explained

• Problem Addressed: The patent does not describe a technical problem, as is typical for a design patent. The implicit goal is to create a unique and non-obvious ornamental appearance for a battery pack, distinguishing it from competitors' products.
• The Patented Solution: The patent protects the specific visual appearance of a battery pack, not its functional or utilitarian features D’299 Patent, Claim The design is characterized by its overall shape, including a main rectangular body with rounded edges and a distinct, multi-part vertical structure extending upwards, as illustrated in the patent's seven figures D’299 Patent, FIG. 1-7 The claim covers the visual impression created by the combination of these ornamental features.
• Technical Importance: In the consumer electronics market, a product's aesthetic design can become a source identifier and a symbol of quality, contributing significantly to brand recognition and commercial success Compl. ¶5, 8

Key Claims at a Glance

• Design patents contain a single claim. The asserted claim is for "The ornamental design for a battery pack, as shown and described" D’299 Patent, Claim This claim protects the overall visual appearance of the article depicted in the patent drawings.

III. The Accused Instrumentality

Product Identification

• The accused products are "battery pack[s]" sold by Defendant under the "zhenjiangjushengpeng_0" seller alias on e-commerce platforms Compl. ¶3 The complaint refers to these as the "Infringing Products."

Functionality and Market Context

• The complaint alleges that Defendant operates one or more "fully interactive, e-commerce stores" on platforms such as Amazon, eBay, Temu, and Walmart to sell the Infringing Products to consumers in the United States Compl. ¶2, 12 The complaint asserts these stores are designed to appear sophisticated, making it difficult for consumers to distinguish them from authorized retailers Compl. ¶15 The complaint shows a perspective view of the patented design in a table. Compl. p. 4, FIG. 1 However, the complaint identifies the specific accused product in an "Exhibit 1" which was not included with the provided filing, and thus no direct visual of the accused product itself is available for analysis in this report Compl. ¶3

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart exhibit. The core of a design patent infringement analysis 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 makes a general allegation that the Defendant is selling products that infringe the Dyson Design Compl. ¶24 Without a visual representation of the accused product, a detailed comparison is not possible.

• Identified Points of Contention:
  • Visual Similarity: The central question will be whether the ornamental design of the accused battery pack is "substantially the same" as the design claimed in the ’D299 Patent. This analysis will depend entirely on a side-by-side comparison of the accused product with the patent's figures.
  • Evidentiary Questions: A threshold issue for the court will be obtaining evidence of what the accused products actually look like. The complaint's allegation of infringement rests on this visual comparison, which is not fully detailed in the body of the complaint itself.

V. Other Allegations

• Willful Infringement: The complaint alleges that Defendant’s infringement was willful Compl. ¶21 This is supported by the allegation that Defendant, without authorization, has "knowingly and willfully offered for sale, sold, and/or imported" products that infringe the Dyson Design Compl. ¶20

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

• A primary procedural question will be one of identity and jurisdiction: Can the plaintiff successfully identify the entity behind the "zhenjiangjushengpeng_0" alias and establish that the court has personal jurisdiction over a defendant alleged to be operating from a foreign country?
• The core substantive question will be the application of the ordinary observer test: Assuming the accused product can be identified and presented as evidence, is its ornamental design substantially the same as the design claimed in the ’D299 Patent, such that it would deceive an ordinary observer into believing it was Dyson's product? The outcome will hinge on this direct visual comparison.