Dyson Technology Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dyson Technology Limited (United Kingdom)
  • Defendant: imaxpower2020 (Jurisdiction Unknown, alleged to be People's Republic of China or similar)
  • Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
• Case Identification: 1:26-cv-01095, N.D. Ill., 02/02/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant operating a "fully interactive, e-commerce store" that directly targets and sells products to consumers in the United States, including Illinois.
• Core Dispute: Plaintiff alleges that Defendant’s sale of battery packs via an online storefront infringes a U.S. design patent covering the ornamental design of a battery pack.
• Technical Context: The dispute is in the consumer electronics accessories market, specifically for battery packs used in products like cordless vacuums, where distinctive product design can serve as a significant source of brand recognition.
• Key Procedural History: The complaint is an action against an e-commerce operator of allegedly unknown identity, who operates under a "Seller Alias." The complaint notes that tactics such as using aliases and offshore accounts are common for such operators to conceal identity and evade enforcement, suggesting that identifying and serving the defendant may be a key procedural challenge in the case.

Case Timeline

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

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

• Patent Identification: U.S. Design Patent No. D710,299, "BATTERY PACK," issued August 5, 2014 (the "’299 Patent").

The Invention Explained

• Problem Addressed: As a design patent, the ’299 Patent does not address a technical or functional problem. Instead, it seeks to protect a unique and ornamental appearance for a product. The complaint alleges that Dyson's designs have become "enormously popular and even iconic," and that genuine Dyson products are "instantly recognizable" to consumers due to their distinctive designs Compl. ¶5
• The Patented Solution: The patent protects the specific visual, non-functional design of a battery pack. The claimed design consists of the visual characteristics shown in solid lines in the patent's figures, including the overall shape of the main body, a raised connecting structure, and various surface contours and details (’299 Patent, FIG. 1). The patent explicitly states that elements shown in broken lines, which appear to illustrate parts of a connection mechanism, "form no part of the claimed design" (’299 Patent, col. 2:28-31).
• Technical Importance: The commercial importance of the design is its alleged association in the public mind with the "quality and innovation" of the Dyson brand Compl. ¶8

Key Claims at a Glance

• The patent contains a single claim for "The ornamental design for a battery pack, as shown and described" (’299 Patent, col. 2:16-18).
• The "elements" of a design claim are the visual features of the article as depicted in the drawings. Key visual features of the ’299 Patent design include:
  • A generally rectangular, elongated main body with rounded ends.
  • A distinct, raised structure extending vertically from the top surface of the main body.
  • Specific contouring and recessed details on the sides and top of the main body and the raised structure.
• Design patents do not have dependent claims.

III. The Accused Instrumentality

Product Identification

• The "Infringing Products" are battery packs offered for sale, sold, and/or imported by Defendant, an e-commerce store operator doing business under the seller alias "imaxpower2020" Compl. ¶¶3, 10

Functionality and Market Context

• The complaint alleges these are unauthorized and unlicensed battery packs that embody the patented Dyson Design Compl. ¶3 They are allegedly sold through online marketplaces such as Amazon, eBay, Temu, and Walmart Compl. ¶12 The complaint further alleges that the defendant's e-commerce store includes "content and images that make it very difficult for consumers to distinguish such stores from an authorized retailer" Compl. ¶15

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart exhibit or images of the accused product for a side-by-side comparison. The infringement theory is that the accused battery packs are visually indistinguishable from the patented design. The complaint includes a table with Figure 1 of the ’299 Patent, identifying it as the "Dyson Design" that is being infringed Compl. p. 4 This figure from the complaint visually defines the asserted ornamental design for a battery pack Compl. p. 4 The infringement test for a design patent is whether, in the eye of an ordinary observer, the resemblance between the patented design and the accused product is such as to induce such an observer to purchase one supposing it to be the other.

As the complaint does not contain a traditional claim chart, a summary of the allegations is presented below.

’299 Patent Infringement Allegations

• Identified Points of Contention:
  • Evidentiary Question: The primary issue is factual and evidentiary: what is the actual appearance of the accused battery packs? The complaint does not contain images of the accused products, so a visual comparison is not possible based on the pleading alone.
  • Scope Questions: The infringement analysis will depend on the scope of the claimed design, which is defined by the solid lines in the patent's drawings. A key question will be whether the accused product copies these specific ornamental features, or if its resemblance is based on functional elements or features shown in the disclaimed broken lines (’299 Patent, col. 2:28-31). The court must separate the purely ornamental aspects from any functional aspects of the battery pack's design.

V. Key Claim Terms for Construction

In design patent litigation, claim construction consists of describing the claimed ornamental design in words to clarify the scope defined by the drawings. The entire case will turn on the interpretation of the single claim.

• The Term: "The ornamental design for a battery pack, as shown and described."
• Context and Importance: This is the only claim, and its scope defines the entire dispute. The court's primary task is to distinguish the claimed ornamental features from any functional elements and the explicitly disclaimed environmental structure shown in broken lines. Practitioners may focus on this "term" because the comparison between the patented design and the accused product can only be made after the scope of the claimed design is properly established.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Parties may argue that the claim protects the overall visual impression and aesthetic appeal created by the combination of the shapes and contours shown in solid lines across all seven figures, rather than any single isolated feature.
  • Evidence for a Narrower Interpretation: The specific disclaimer in the patent's text is crucial evidence for a narrower scope: "The broken lines shown in the drawings are included for the purpose of illustrating environmental structure and form no part of the claimed design" (’299 Patent, col. 2:28-31). This language limits the claim strictly to the features rendered in solid lines and excludes the specific connection interface shown in those broken lines.

VI. Other Allegations

• Indirect Infringement: The complaint makes conclusory allegations of indirect infringement Compl. ¶¶20, 24 and seeks to enjoin "aiding, abetting, [or] contributing to" infringement Compl. p. 12 However, the complaint does not plead specific facts detailing how Defendant induces or contributes to infringement by a third party; the allegations focus on Defendant's own direct sales.
• Willful Infringement: The complaint alleges that Defendant's infringement was "knowingly and willfully" committed Compl. ¶20-21 The factual basis for this allegation appears to rest on the assertion that Defendant is selling products that copy an "iconic" and "instantly recognizable" design, combined with allegations that Defendant uses tactics like seller aliases to conceal its identity and evade enforcement Compl. ¶¶5, 11, 17

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

1. The Evidentiary Question: As the complaint does not include images of the accused product, the threshold issue for the case is one of evidence. What is the actual ornamental appearance of the battery packs sold by "imaxpower2020," and how does it compare visually to the drawings in the ’299 Patent?

2. The "Ordinary Observer" Test: Assuming discovery reveals a visually similar product, the central legal question will be one of deception. Is the overall visual impression of the accused product substantially the same as the claimed design, such that it would deceive an ordinary observer into purchasing the accused product believing it was the patented one?

3. The Enforcement Challenge: A significant practical question surrounds the defendant's identity and location. Given the allegations that the defendant is an unknown entity operating from a foreign jurisdiction and using tactics to evade detection Compl. ¶¶10-11, 17-19, a key challenge for the plaintiff will likely be identifying the responsible party, effecting service, and ultimately enforcing any judgment that may be obtained.