General Motors LLC v. Best Value Auto Body Supply

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: General Motors LLC (Delaware) and GM Global Technology Operations LLC (Delaware)
  • Defendant: Best Value Auto Body Supply (Illinois) and Jiangsu Srumto Auto Parts Co., Ltd. (China)
  • Plaintiff’s Counsel: Fish & Richardson P.C.
• Case Identification: 1:26-cv-01223, N.D. Ill., 02/03/2026
• Venue Allegations: Venue is alleged as proper for Best Value Auto Body Supply because it has a regular and established place of business and has sold or offered to sell accused products in the Northern District of Illinois. Venue is alleged as proper for Jiangsu Srumto Auto Parts Co., Ltd. based on general venue statutes for foreign defendants.
• Core Dispute: Plaintiff alleges that Defendants’ aftermarket automotive vehicle parts infringe fourteen design patents covering the ornamental appearance of original equipment manufacturer (OEM) components.
• Technical Context: The dispute is situated in the automotive aftermarket parts industry, where the ornamental design of components such as bumpers, fascias, hoods, and fenders is a key aspect of vehicle branding and aesthetics.
• Key Procedural History: The complaint alleges that Plaintiff complied with patent marking provisions by listing the asserted patents on a public website, which may form the basis for allegations of pre-suit knowledge by the Defendants.

Case Timeline

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

U.S. Design Patent No. D793,301 - “Automobile front lower fascia,” issued August 1, 2017

The Invention Explained

• Problem Addressed: Design patents protect the aesthetic appearance of an object rather than its utilitarian function. The patent serves to protect the unique and ornamental visual characteristics of a specific vehicle component, which contributes to the overall brand identity and design language of an automobile Compl. ¶¶15-16
• The Patented Solution: The patent claims the specific ornamental design for an "automobile front lower fascia" (D793301 Patent, title). The protected design is defined by the visual features depicted in solid lines across the patent's figures, such as the perspective view in FIG. 1 and the front view in FIG. 2 D793301 Patent, figs. 1-4 The broken lines illustrate the surrounding environment and form no part of the claimed design D793301 Patent, description
• Technical Importance: The aesthetic design of exterior vehicle components is a primary means of product differentiation in the competitive automotive market, influencing consumer appeal and brand recognition Compl. ¶15

Key Claims at a Glance

• Design patents contain a single claim. The asserted claim is for "The ornamental design for an automobile front lower fascia, as shown and described" D793301 Patent, claim
• The scope of this claim is defined by the visual appearance of the article as a whole, as depicted in the solid-line portions of the drawings.

U.S. Design Patent No. D828,247 - “Vehicle hood,” issued September 11, 2018

The Invention Explained

• Problem Addressed: This patent protects the ornamental design of a vehicle hood, preventing others from producing designs that are confusingly similar in appearance. This protection is intended to preserve the distinct aesthetic that GM has developed through significant investment Compl. ¶¶15-16
• The Patented Solution: The patent claims the ornamental design for a "vehicle hood," which is illustrated from multiple angles in the patent’s figures (D828247 Patent, title; D828247 Patent, figs. 1-4). The design's claimed features, shown in solid lines, include specific contours and surface features that create a distinct visual impression D828247 Patent, description
• Technical Importance: As a large and prominent exterior panel, the hood's design is a critical element of a vehicle's "face" and overall styling, making its unique appearance a valuable intellectual property asset Compl. ¶15

Key Claims at a Glance

• The patent contains a single claim for "The ornamental design for a vehicle hood, as shown and described" D828247 Patent, claim
• The claim's scope is dictated by the overall visual appearance of the design as shown in the solid-line drawings.

U.S. Design Patent No. D828,248 - “Vehicle hood,” issued September 11, 2018

• Technology Synopsis: This patent protects the ornamental design for a vehicle hood, distinct from the design of the ’247 Patent. The claimed design consists of the visual features shown in the patent's drawings.
• Asserted Claims: The single claim for "The ornamental design for a vehicle hood, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1230477 embodies the claimed design Compl. ¶¶45-46

U.S. Design Patent No. D828,256 - “Vehicle fender,” issued September 11, 2018

• Technology Synopsis: This patent protects the specific ornamental design for a vehicle fender. The claimed design is defined by the shape and contour of the fender as illustrated in the patent figures.
• Asserted Claims: The single claim for "The ornamental design for a vehicle fender, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1240413 embodies the claimed design Compl. ¶¶51-52

U.S. Design Patent No. D847,703 - “Vehicle rear bumper,” issued May 7, 2019

• Technology Synopsis: This patent protects the ornamental design for a vehicle rear bumper. The scope of protection is defined by the visual appearance of the bumper as depicted in the patent's drawings.
• Asserted Claims: The single claim for "The ornamental design for a vehicle rear bumper, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1102577 embodies the claimed design Compl. ¶¶57-58

U.S. Design Patent No. D848,318 - “Vehicle front upper bumper fascia,” issued May 14, 2019

• Technology Synopsis: This patent protects the ornamental design for the upper fascia portion of a vehicle's front bumper. The design is defined by the visual features illustrated in the patent's figures.
• Asserted Claims: The single claim for "The ornamental design for a vehicle front upper bumper fascia, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1014134 embodies the claimed design Compl. ¶¶63-64

U.S. Design Patent No. D826,114 - “Vehicle front bumper,” issued August 21, 2018

• Technology Synopsis: This patent protects the ornamental design for a complete vehicle front bumper assembly. The protected design is defined by the overall shape and specific features shown in the patent drawings.
• Asserted Claims: The single claim for "The ornamental design for a vehicle front bumper, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1000A37 embodies the claimed design Compl. ¶¶69-70

U.S. Design Patent No. D883,155 - “Vehicle fender,” issued May 5, 2020

• Technology Synopsis: This patent protects the ornamental design for a vehicle fender. The specific shape, creases, and contours shown in the patent's drawings constitute the claimed design.
• Asserted Claims: The single claim for "The ornamental design for a vehicle fender, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1240422 embodies the claimed design Compl. ¶¶75-76

U.S. Design Patent No. D902,807 - “Vehicle hood,” issued November 24, 2020

• Technology Synopsis: This patent protects the ornamental design for a vehicle hood. The claim covers the specific aesthetic appearance, including surface contours, illustrated in the patent's figures.
• Asserted Claims: The single claim for "The ornamental design for a vehicle hood, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1230483 embodies the claimed design Compl. ¶¶81-82

U.S. Design Patent No. D930,533 - “Vehicle front fender,” issued September 14, 2021

• Technology Synopsis: This patent protects the ornamental design for a vehicle front fender. The visual appearance of the fender shown in the drawings defines the scope of the claim.
• Asserted Claims: The single claim for "The ornamental design for a vehicle front fender, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1240418 embodies the claimed design Compl. ¶¶87-88

U.S. Design Patent No. D955,939 - “Vehicle front bumper,” issued June 28, 2022

• Technology Synopsis: This patent protects the ornamental design for a vehicle front bumper. The claimed design consists of the aesthetic features illustrated in the patent drawings.
• Asserted Claims: The single claim for "The ornamental design for a vehicle front bumper, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1002899 embodies the claimed design Compl. ¶¶93-94

U.S. Design Patent No. D859,239 - “Vehicle rear bumper,” issued September 10, 2019

• Technology Synopsis: This patent protects the ornamental design for a vehicle rear bumper. The visual appearance of the bumper as depicted in the patent's drawings constitutes the protected design.
• Asserted Claims: The single claim for "The ornamental design for a vehicle rear bumper, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1102575 embodies the claimed design Compl. ¶¶99-100

U.S. Design Patent No. D848,647 - “Vehicle front headlamp,” issued May 14, 2019

• Technology Synopsis: This patent protects the ornamental design for a vehicle front headlamp assembly. The claimed design is defined by the specific shapes and arrangement of elements within the headlamp housing as shown in the drawings.
• Asserted Claims: The single claim for "The ornamental designs for a vehicle front headlamp, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM2502497 embodies the claimed design Compl. ¶¶105-106

U.S. Design Patent No. D826,803 - “Vehicle front lower bumper fascia,” issued August 28, 2018

• Technology Synopsis: This patent protects the ornamental design for the lower fascia of a vehicle front bumper. The claim scope is defined by the aesthetic features illustrated in the patent's drawings.
• Asserted Claims: The single claim for "The ornamental design for a vehicle front lower bumper fascia, as shown and described."
• Accused Features: The complaint alleges that aftermarket part number GM1015152 embodies the claimed design Compl. ¶¶111-112

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are aftermarket automotive replacement parts allegedly manufactured, imported, and/or sold by the Defendants Compl. ¶21 The complaint identifies specific accused products by part number in relation to each asserted patent, such as "Part No. GM1015135" Compl. ¶33 and "Part No. GM1230475" Compl. ¶39

Functionality and Market Context

The complaint alleges that the accused products are "replacement copy parts" that are "intended and designed to be substitutable with GM Genuine Parts" Compl. ¶¶21-22 It further alleges that the Defendants' business is "premised on offering replacement parts that match the ornamental appearance of genuine OEM components," positioning them as direct copies intended to compete with Plaintiff's original parts Compl. ¶22

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibits 15-28, which were not provided with the complaint document. The narrative infringement theory is therefore summarized below.

The complaint alleges direct infringement of each design patent under 35 U.S.C. § 271(a) based on the "ordinary observer" test Compl. ¶24 For each asserted patent, the core allegation is that the corresponding accused product is "substantially similar to the design claimed" in the patent Compl. ¶¶34, 40, 46, 52, 58, 64, 70, 76, 82, 88, 94, 100, 106, 112 The complaint asserts that this similarity is such that an ordinary observer, giving the attention a purchaser usually gives, would be induced to purchase the accused product believing it to be the patented design Compl. ¶24

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Visual Similarity: The central factual dispute for each patent will be whether the accused product's design is "substantially the same" as the claimed design from the perspective of an ordinary observer. This analysis will involve a side-by-side comparison of the products and the patent figures, taking into account the overall visual impression created by each design.
  • Scope of the Claimed Design: The patent drawings for each asserted patent use both solid and broken lines. The solid lines depict the claimed ornamental design, while the broken lines show the article's environment and are not part of the claim. A potential point of contention may be the extent to which the unclaimed environmental features (in broken lines) should be considered when assessing the "article of manufacture" and the overall visual impression of the design.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of potential claim construction disputes. In design patent cases, claim construction is typically not a central issue, as the claim is defined by the drawings rather than textual limitations. Any construction would likely be limited to defining the scope of the "article of manufacture" recited in the claim (e.g., "vehicle hood," "automobile front lower fascia").

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement.
  • The inducement allegation is based on Defendants encouraging direct infringement by repair shops and end users through the act of selling and providing the accused products for import and use in the United States Compl. ¶¶25-26
  • The contributory infringement allegation is based on the sale of components of the accused products, with the knowledge that these components are material parts of the claimed design, are specially adapted for use in an infringing manner, and have no substantial non-infringing use Compl. ¶¶27-29
• Willful Infringement: The complaint alleges willful infringement against the Defendants. This allegation is predicated on alleged pre-suit knowledge of the asserted patents, which Plaintiff claims resulted from its compliance with patent marking provisions via a publicly accessible website listing the patents Compl. ¶20 The complaint further alleges that Defendants acted in "deliberate disregard of GM's rights" Compl. ¶¶35, 41, 47, 53, 59, 65, 71, 77, 83, 89, 95, 101, 107, 113

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

• A central factual question will be one of visual similarity: For each of the fourteen asserted design patents, would an ordinary observer, familiar with the prior art, be deceived into purchasing the accused aftermarket part in the belief that it is the patented GM design? This will require a detailed visual comparison of the overall appearance of each accused part against the corresponding patent drawings.
• A key issue for damages may turn on the interpretation of 35 U.S.C. § 289, which allows a patent owner to recover an infringer’s total profit from the sale of an "article of manufacture" to which the patented design is applied. The definition of the relevant "article of manufacture" for each infringing part could become a significant point of contention in calculating damages.
• While not raised in the complaint, a core defense strategy will likely focus on invalidity. Defendants may argue that GM's patented designs are invalid as being obvious or anticipated by prior art designs for similar vehicle components. The ultimate outcome may depend on the strength and scope of the prior art identified during the litigation.