Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: Ibatteries (Jurisdiction unknown; alleged to be People's Republic of China or other foreign jurisdiction)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:26-cv-00933, N.D. Ill., 01/30/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant targets and conducts business with consumers in Illinois through a fully interactive e-commerce store.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce store is making, using, selling, and/or importing battery packs that infringe a Dyson design patent.
• Technical Context: The dispute centers on the ornamental design of replacement battery packs for consumer electronics, such as cordless vacuum cleaners, a market where brand recognition and product appearance are significant.
• Key Procedural History: The filing is an Amended Complaint. The complaint emphasizes that the Defendant is an entity of "unknown makeup" operating under a seller alias, a common challenge in e-commerce patent enforcement against foreign sellers.

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 “D’299 Patent”).

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than its utilitarian features. The purpose is to protect a new, original, and non-obvious ornamental design that gives a product a distinct appearance D’299 Patent, CLAIM
• The Patented Solution: The D’299 Patent claims the specific ornamental design for a battery pack as depicted in its seven figures D’299 Patent, DESCRIPTION The design consists of a main rectangular body with rounded ends and a distinct, centrally-located vertical connector structure with specific contours and surface details. The patent drawings use solid lines to show the claimed portions of the design and broken lines to illustrate the environmental structure, which forms no part of the claimed design D’299 Patent, DESCRIPTION
• Technical Importance: The complaint alleges that Dyson's product designs, including that of its battery packs, are "enormously popular and even iconic" and "instantly recognizable" to consumers, associating the design with the quality of the Dyson brand Compl. ¶¶5, 8

Key Claims at a Glance

• Design patents have a single claim, which is directed to the ornamental design as shown in the drawings. The D’299 Patent’s claim is for "the ornamental design for a battery pack, as shown and described" D’299 Patent, CLAIM
• The infringement analysis for a design patent is holistic, comparing the patented design to the accused product from the perspective of an ordinary observer. Key visual features of the claimed design include:
  • The overall configuration of a primary base unit with an upstanding connector piece.
  • The specific profile and proportions of the base unit, including its rounded ends.
  • The multi-faceted shape and surface details of the connector structure.
  • The relative positioning and scale of these features.

III. The Accused Instrumentality

Product Identification

The accused products are battery packs offered for sale and sold by Defendant through an e-commerce store operating under the alias "ibatteries" (the "Infringing Products") Compl. ¶3

Functionality and Market Context

The complaint alleges Defendant operates a "fully interactive, e-commerce store" on platforms such as Amazon, eBay, Temu, and Walmart to sell the Infringing Products to consumers in the United States, including Illinois Compl. ¶¶2, 12 The complaint alleges these online stores are designed to appear sophisticated and make it "very difficult for consumers to distinguish such stores from an authorized retailer" Compl. ¶15 The complaint includes a figure from the patent to represent the design at issue. The perspective view in FIG. 1 shows the overall ornamental appearance of the battery pack design that Dyson seeks to protect Compl. p. 4

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or side-by-side visual comparison of the patented design and the accused product. The infringement allegation is based on the assertion that the accused "Infringing Products" are the "same unauthorized and unlicensed product... that infringes Dyson's patented design" Compl. ¶3 The legal test for design patent infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into believing the accused product is the same as the patented design.

The core of the infringement allegation is that Defendant is selling products that copy the ornamental design claimed in the D’299 patent Compl. ¶24 The complaint states that Defendant has "offered for sale, sold, and/or imported... the same product that infringes directly and/or indirectly the Dyson Design" Compl. ¶20

• Identified Points of Contention:
  • Visual Similarity: The central question will be a direct visual comparison between the accused battery packs and the design claimed in the D'299 patent. The dispute will turn on whether the accused products are "substantially the same" in overall visual appearance to an ordinary observer.
  • Scope of the Claimed Design: A potential issue is the distinction between the claimed ornamental features (shown in solid lines in the D’299 patent) and any functional or unclaimed environmental aspects (shown in broken lines). The infringement analysis must focus only on the claimed ornamental features.

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses on the scope of the claimed design as a whole rather than on specific text-based terms. The central issue for construction is defining what visual elements are covered by the claim.

• The "Term": The overall scope of the claimed ornamental design.
• Context and Importance: Determining which features of the battery pack are purely ornamental and protected versus which are functional or environmental (and thus unprotected) is critical. The analysis must filter out the unclaimed elements shown in broken lines to properly compare the accused product to the patented design.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that the overall visual impression created by the combination and arrangement of all depicted elements, even if some are unclaimed, should be considered. The design is a holistic entity, and its overall appearance is what is protected.
  • Evidence for a Narrower Interpretation: The patent specification provides explicit guidance, stating, "The broken lines shown in the drawings are included for the purpose of illustrating environmental structure and form no part of the claimed design" D’299 Patent, DESCRIPTION This statement strongly supports an interpretation where only the features rendered in solid lines are considered for the infringement analysis.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of direct "and/or indirectly" infringement Compl. ¶24 and requests an injunction against "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing Compl., prayer 1(b) However, the complaint does not plead specific facts to support a claim for either induced or contributory infringement beyond the acts of direct infringement.
• Willful Infringement: The complaint alleges that Defendant's infringement was willful Compl. ¶21 This allegation is based on the assertion that Defendant "knowingly and willfully" sold infringing products Compl. ¶20 and is part of a larger network of e-commerce operators who use tactics like multiple seller aliases and offshore accounts to conceal their identity and evade enforcement actions Compl. ¶¶11, 17-19

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

• A core issue will be one of visual identity: From the perspective of an ordinary observer, is the ornamental design of the accused battery pack substantially the same as the specific design claimed in the D’299 patent? The outcome will depend on a direct visual comparison, focusing only on the solid-line features depicted in the patent's drawings.
• A key evidentiary question will be one of attribution and damages: Can Dyson successfully identify the defendant, pierce the anonymity of the "ibatteries" seller alias, and prove that this specific entity was responsible for the sales of the accused products in the United States? The complaint’s focus on the challenges of e-commerce enforcement suggests this will be a significant procedural hurdle.
• A central question regarding willfulness will be intent: Can Dyson establish that the defendant's conduct was not merely infringement but egregious, warranting enhanced damages? This may depend on evidence supporting the complaint's allegations of conscious and deceptive business practices designed to evade intellectual property rights.