1:26-cv-01724
Wu v. Shenzhenshiyangrunzhedianzishangwuyouxiangongsi
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Qi Wu (China)
- Defendant: Shenzhenshiyangrunzhedianzishang-wuyouxiangongsi d/b/a Yangrunzhe (China)
- Plaintiff’s Counsel: Nicholas S. Lee
- Case Identification: 1:26-cv-01724, N.D. Ill., 02/17/2026
- Venue Allegations: Plaintiff alleges venue is proper because Defendant targets consumers in the United States, including Illinois, through interactive e-commerce stores.
- Core Dispute: Plaintiff alleges that Defendant’s sale of magnetic silicone smartwatch bands infringes a U.S. design patent and constitutes trade dress infringement.
- Technical Context: The dispute concerns the ornamental design of watch bands, a highly competitive accessory market for popular smartwatches.
- Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2022-07-25 | '382 Patent Application Filing Date (Priority Date) |
| 2022-11-22 | '382 Patent Issue Date |
| 2026-02-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D970,382 - Silicone Magnetic Band
- Issued: November 22, 2022
The Invention Explained
- Problem Addressed: The patent does not describe a technical problem but instead provides a new, original, and ornamental design for a watch band (D’382 Patent, Claim).
- The Patented Solution: The patent claims the specific visual appearance of a silicone magnetic band as depicted in its seven figures (D’382 Patent, Figs. 1-7). The design features a two-piece band with a repeating pattern of raised, transverse rectangular segments along its length. One end of the band terminates in a rounded tip, while the other end features a connector piece designed to attach to a watch case. The overall visual impression is that of a textured, segmented strap with a clean, modern aesthetic (D’382 Patent, Fig. 1; D’382 Patent, Fig. 2).
- Technical Importance: The complaint alleges the patented design is associated with Plaintiff’s products, which are sold direct-to-consumer through online marketplaces (Compl. ¶9).
Key Claims at a Glance
- As a design patent, the ’382 Patent contains a single claim: “The ornamental design for a silicone magnetic band, as shown and described” (D’382 Patent, Claim).
- The scope of this claim is defined by the solid-line drawings in the patent figures (D’382 Patent, Figs. 1-7).
III. The Accused Instrumentality
Product Identification
The accused products are “magnetic silicone loop sport band[s] compatible with Apple® Watches” (Compl. ¶8), which the complaint refers to as “Unauthorized Products” (Compl. ¶2).
Functionality and Market Context
The complaint alleges Defendant advertises, offers for sale, and sells the accused products through interactive e-commerce stores on platforms including Amazon, eBay, SHEIN, Temu, and Walmart under the seller alias “Yangrunzhe” (Compl. ¶11; Compl. ¶15). The complaint alleges that Defendant has completed sales of these products to customers in Illinois (Compl. ¶16). The complaint includes an uncaptioned image showing a perspective view of a segmented watch band, consistent with the patented design (Compl. p. 4).
IV. Analysis of Infringement Allegations
The complaint does not provide the claim chart exhibit it references (Compl. ¶23). The infringement theory is therefore based on the narrative allegations.
The central allegation is that Defendant has sold, offered for sale, and imported products that incorporate the ornamental design claimed in the ’382 Patent (Compl. ¶22; Compl. ¶24). For design patent infringement, the legal test is whether, in the eye of an ordinary observer, giving such attention as a purchaser usually gives, the two designs are substantially the same, such that the resemblance is sufficient to deceive the observer into purchasing one supposing it to be the other. The complaint asserts that the products sold by Defendant "incorporate[] each of the design elements claimed in Plaintiff's Patent" (Compl. ¶23).
Identified Points of Contention
- Visual Similarity: The primary question for the court will be a factual one: is the overall visual appearance of the accused watch bands substantially the same as the design depicted in the ’382 Patent’s figures from the perspective of an ordinary observer?
- Scope Questions: The analysis may involve comparing the claimed design to the prior art to determine the scope of the patent’s protection and to assess whether an ordinary observer familiar with the prior art would be deceived.
V. Key Claim Terms for Construction
This section is not applicable, as design patents claim an ornamental design as a whole and do not contain textual claim terms that require judicial construction.
VI. Other Allegations
Indirect Infringement
The complaint makes a passing reference to products that infringe "directly and/or indirectly" (Compl. ¶22) and includes boilerplate language for "aiding, abetting, [or] contributing to" infringement in its prayer for relief (Prayer for Relief, 1(b)). However, the complaint does not plead specific facts to support the knowledge and intent elements required for a claim of induced infringement or the specific elements for contributory infringement.
Willful Infringement
The complaint alleges that Defendant's infringement "has been and continues to be willful" (Compl. ¶26). This allegation may be supported by claims that Defendant operates under multiple seller aliases to evade enforcement and uses services that provide tactics for evading detection by intellectual property owners (Compl. ¶18; Compl. ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the court’s assessment of two primary questions:
- A core issue will be one of visual comparison: From the perspective of an ordinary purchaser of smartwatch accessories, is the overall ornamental design of the accused watch bands substantially the same as the specific design claimed and depicted in the ’382 Patent?
- A key enforcement question will be one of practicability: Assuming infringement is found, can the Plaintiff effectively obtain relief against a foreign-based Defendant that allegedly operates through shifting e-commerce aliases on multiple online platforms (Compl. ¶3; Compl. ¶19)?