Dongguan Saien Chuangke Technology Co Ltd v. Shenzhen Huamingjun Rubber Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Saien Chuangke Technology Co. Ltd. (China) and Zuru Inc. (British Virgin Islands/Hong Kong)
  • Defendant: Shenzhen Huamingjun Rubber Co. Ltd. (China)
  • Plaintiff's Counsel: Rimon P.C.; Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
• Case Identification: 1:26-cv-06539, N.D. Ill., 06/02/2026
• Venue Allegations: Venue is alleged to be proper as the Defendant is a foreign corporation, which may be sued in any judicial district where it is subject to personal jurisdiction. The complaint asserts personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2) and alternatively argues the Defendant has availed itself of the jurisdiction by previously filing a Declaratory Judgment action in the same district.
• Core Dispute: Plaintiffs allege that Defendant's reusable water balloons infringe two U.S. design patents covering the ornamental appearance of such products.
• Technical Context: The dispute centers on the ornamental design of reusable, self-sealing water balloons, a segment of the children's toy market.
• Key Procedural History: The complaint references a prior lawsuit, Dongguan Saien Chuangke Technology Co Ltd v. Shenzhen Huamingjun Rubber Co Ltd, No. 1:24-cv-8111 (N.D. Ill.) ("DSCT I"), in which the court issued a preliminary injunction against an earlier version of Defendant's product for infringing one of the patents now at issue. This prior litigation is cited as establishing Defendant's knowledge of the patents for the purposes of willful infringement allegations.

Case Timeline

Date	Event
2020-01-01	DSCT begins development of reusable water balloons.
2021-12-14	Earliest priority date for D'929 and D'076 Patents.
2022-01-01	DSCT begins selling reusable water balloons under the SOPPYCID brand.
2024-01-01	DSCT grants Zuru an exclusive license to market the products in the U.S.
2024-06-11	U.S. Design Patent No. D1,030,929 issues.
2024-09-05	Plaintiffs file "DSCT I" lawsuit, establishing alleged knowledge of the D'929 Patent.
2024-11-21	Court issues a preliminary injunction in "DSCT I" against Defendant's "2024 Product".
2024-12-26	Alleged start of Defendant's sales of "2024 Product" to Sam's Club.
2025-10-01	Defendant allegedly enters a supply agreement with Sam's Club for the "2026 Product".
2025-11-04	U.S. Design Patent No. D1,101,076 issues.
2026-02-17	Alleged start of U.S. sales for Defendant's "2026 Product".
2026-06-02	Complaint Filing Date.

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

U.S. Design Patent No. D1,030,929 - "Spherical toy water ball"

• Patent Identification: D1,030,929, "Spherical toy water ball," issued June 11, 2024.

The Invention Explained

• Problem Addressed: Design patents do not contain a "problem and solution" section; their purpose is to protect a new, original, and ornamental design for an article of manufacture Compl. ¶26 The implicit goal is to create a novel visual appearance for a reusable water balloon to distinguish it in the marketplace.
• The Patented Solution: The patent protects the specific ornamental design of a "spherical toy water ball" as depicted in the drawings '929 Patent, claim The claimed design, shown in solid lines, consists of a spherical object composed of two hemispheres connected by a hinge '929 Patent, FIG. 2 The exterior surface of the sphere features a distinct pattern of undulating, wavy lines '929 Patent, FIG. 1 The interior of the open hemispheres is shown with broken lines, indicating the concentric rings are not part of this specific claimed design '929 Patent, description
• Technical Importance: The complaint alleges these designs were "revolutionary" and "departed significantly" from prior products, contributing to the commercial success of Plaintiffs' products Compl. ¶3 Compl. ¶5

Key Claims at a Glance

• The single claim is for "The ornamental design for a spherical toy water ball, as shown and described." '929 Patent, claim
• The key visual elements of the claimed design include:
  • A spherical body.
  • An exterior surface characterized by a pattern of wavy lines.
  • A two-hemisphere construction.
  • A connecting hinge shown in solid lines.

U.S. Design Patent No. D1,101,076 - "Toy water ball"

• Patent Identification: D1,101,076, "Toy water ball," issued November 4, 2025.

The Invention Explained

• Problem Addressed: As with the '929 Patent, the goal is to protect a novel ornamental design for a reusable water balloon Compl. ¶28
• The Patented Solution: The '076 Patent claims a visually similar, but distinct, ornamental design. Like the '929 Patent, it shows a hinged, two-hemisphere sphere with a wavy line pattern on the exterior '076 Patent, FIG. 1 This patent provides enlarged views of the hinge and rim areas, suggesting these specific features are important to the overall design '076 Patent, FIG. 3 '076 Patent, FIG. 4 The use of solid lines for the hinge and rims indicates these detailed features are part of the claimed design '076 Patent, description
• Technical Importance: This design represents an alternative or refined aesthetic for the same class of product, broadening the Plaintiffs' portfolio of protected designs Compl. ¶22

Key Claims at a Glance

• The single claim is for "The ornamental design for a toy water ball as shown and described." '076 Patent, claim
• The key visual elements of the claimed design include:
  • A spherical body with an exterior wavy line pattern.
  • A two-hemisphere construction connected by a hinge.
  • Specific ornamental details on the interlocking rims of the hemispheres.
  • Specific ornamental details on the connecting hinge element.

III. The Accused Instrumentality

• Product Identification: The accused instrumentality is Defendant SHR's "2026 Product," a reusable water balloon sold under the "Member's Mark" brand, supplied to and sold by Sam's Club Compl. ¶10 Compl. ¶37
• Functionality and Market Context: The complaint describes the accused product as a reusable water balloon that employs the designs claimed in the Asserted Designs Compl. ¶37 Product imagery shows a spherical item made of two hinged, colored silicone halves that can be opened or closed Compl. p. 9 The product is sold in multi-packs, and the complaint alleges it is available for purchase and pickup at Sam's Club locations in the United States, including Illinois Compl. ¶45 Compl. p. 19 The complaint characterizes the product as a "carbon copy knock-off" designed to trade on the success of Plaintiffs' products Compl. ¶5

IV. Analysis of Infringement Allegations

The complaint alleges that the accused "2026 Product" infringes the asserted design patents under the "ordinary observer" test, stating that an ordinary purchaser would be deceived into believing the accused product is the same as the patented design Compl. ¶59 Compl. ¶63 The complaint presents a visual comparison to support its allegations. This image from the complaint presents a side-by-side comparison of the patent drawings from the '929 Patent and the '076 Patent with photographs of the accused "2026 Product" in its closed and open states Compl. p. 9

'929 Patent Infringement Allegations

Claim Element (from Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a spherical toy water ball, as shown, including a spherical body with an exterior surface featuring a pattern of wavy lines.	The accused 2026 Product is a spherical toy water ball that incorporates a visually identical or substantially similar wavy line pattern on its exterior surface.	¶11; p. 9	'929 Patent, col. 2:6-7
The ornamental design as shown, including two hemispheres connected by a hinge.	The accused 2026 Product is comprised of two hemispheres connected by a hinge, creating the same overall visual appearance as the open-state view of the patented design.	¶11; p. 9	'929 Patent, col. 2:8-10

'076 Patent Infringement Allegations

Claim Element (from Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a toy water ball, as shown, including a spherical body with an exterior wavy line pattern.	The accused 2026 Product is a spherical toy water ball with an exterior wavy line pattern that is substantially the same as that shown in the patent's figures.	¶11; p. 9	'076 Patent, col. 2:10-12
The ornamental design as shown, including specific ornamental features on the interlocking rims and hinge area.	The accused 2026 Product's hinge and rim design allegedly copies the specific ornamental details protected by the '076 Patent, creating a substantially similar overall impression.	¶11; p. 9	'076 Patent, col. 2:13-16

• Identified Points of Contention:
  • Scope Questions: A central question will be how the identified prior art Compl. ¶32 affects the scope of the patented designs. The complaint preemptively argues that "None of the above comparison prior art includes two halves connected by a hinge," suggesting the combination of features is the point of novelty Compl. ¶34 The defense may seek to broaden the universe of relevant prior art to argue the patented design is only a narrow improvement and that the accused product does not fall within that narrow scope.
  • Technical Questions: While not a technical case, the visual analysis will raise questions of degree. Do minor differences in the curvature of the wavy lines, the proportions of the hinge, or the product's material finish on the accused product create a different overall visual impression from the patented designs in the eyes of an ordinary observer?

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is the design as a whole, depicted in the drawings. There are no "terms" to construe in the manner of utility patents. The analysis focuses on the scope of the claimed design as defined by the solid and broken lines in the patent figures.

• The Term: "The ornamental design... as shown and described."
• Context and Importance: The entire dispute rests on the visual scope of this term. The analysis does not parse words but compares the overall visual impression of the claimed design with that of the accused product. Practitioners will focus on which visual elements are claimed (solid lines) versus unclaimed (broken lines or absent) and how those claimed elements combine to create a total look.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patents use line drawings rather than photographs or shaded renderings. A party could argue this was intended to capture the ornamental design's shape and patterns, not a specific color, texture, or material, thus covering products made in various colors like the accused product Compl. p. 5
  • Evidence for a Narrower Interpretation: The specific shapes and contours shown in solid lines define the precise boundaries of the claim. Any element shown in solid lines, such as the specific wave pattern in the '929 Patent or the detailed hinge and rim features in the '076 Patent, could be argued as a strict limitation. The defense may argue that any deviation in the accused product from these specific drawn features is sufficient to avoid infringement.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that SHR induced infringement by Sam's Club and end users Compl. ¶61 Compl. ¶65 The factual basis cited includes SHR's alleged actions of designing, manufacturing, and supplying the "2026 Product" specifically for resale in the United States, including packaging it with U.S. retailer branding (Sam's Club's "Member's Mark") and promoting it through U.S. sales channels Compl. ¶48
• Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents Compl. ¶50 For the D'929 patent, knowledge is alleged from the filing of the DSCT I lawsuit on September 5, 2024 Compl. ¶46 For the D'076 patent, knowledge is alleged to have occurred on or around its issue date due to the "ongoing litigation" between the parties Compl. ¶47

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

• A core issue will be one of visual comparison: from the perspective of an ordinary purchaser of children's toys, and in light of the prior art, is the overall ornamental design of the Defendant's "2026 Product" substantially the same as the designs claimed in the '929 and '076 patents, such that the observer would be deceived?
• A second question will concern the impact of the prior art: how does the prior art presented by both parties define the scope of Plaintiffs' patent protection? The court will need to determine whether the patented designs are a broad, pioneering aesthetic or a narrow improvement over existing designs, which will directly influence the infringement analysis.
• Finally, a key legal and factual question will be the separation of function from ornament: to what extent are the shared design features (e.g., a spherical shape, a two-part hinged construction) dictated by the item's function as a reusable water balloon? The infringement analysis will depend on whether the similarities between the products lie in purely ornamental features or in functional elements that are not protected by a design patent.