LAN v. Shenzhen Baichirui Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dun Lan (Jurisdiction not specified in the complaint)
  • Defendant: Shenzhen Baichirui Technology Co., Ltd (China)
  • Plaintiff's Counsel: Stratum Law LLC
• Case Identification: 1:26-cv-06609, N.D. Ill., 06/03/2026
• Venue Allegations: Venue is asserted under 28 U.S.C. § 1391(c)(3) for foreign defendants. The complaint alleges Defendant targets consumers in Illinois through interactive online stores, offers shipping to Illinois, accepts U.S. dollar payments, has made sales to Illinois residents, and has potentially stored infringing products in Amazon fulfillment centers within the state.
• Core Dispute: Plaintiff alleges that Defendant's "HVAC Adaptor Cord" sold online via Amazon infringes a U.S. design patent for an HVAC adaptor cord.
• Technical Context: The technology relates to the ornamental design of a specialized electrical cord used in the heating, ventilation, and air conditioning (HVAC) field.
• Key Procedural History: The complaint references Plaintiff's prior enforcement efforts, such as "take down notices," and alludes to analyses of transaction logs from "previous similar cases," but does not specify any prior litigation between the named parties.

Case Timeline

Date	Event
2022-04-14	D'513 Patent Priority Date (Application Filing)
2023-05-09	D'513 Patent Issue Date
2026-06-03	Complaint Filing Date

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

U.S. Patent No. D985,513 - HVAC ADAPTOR CORD

The Invention Explained

• Problem Addressed: Design patents protect ornamental appearance rather than solving a technical problem. The patent secures rights to a "new, original, and ornamental design for an article of manufacture" D'513 Patent, cover page
• The Patented Solution: The patent claims the specific ornamental design for an HVAC adaptor cord D'513 Patent, claim The design, as depicted in solid lines in the figures, consists of a three-pronged electrical plug, a section of cord, a Y-shaped split, and three distinct alligator-style clips D'513 Patent, FIG. 1 D'513 Patent, FIG. 4 The claim's scope is defined by these visual characteristics, including the proportions and specific contours of the plug housing and clips, as illustrated across multiple views D'513 Patent, FIGS. 1-15
• Technical Importance: The patent provides a distinct visual identity for a functional tool within the market for HVAC equipment and accessories.

Key Claims at a Glance

• Design patents contain a single claim. The asserted claim is for "The ornamental design for a HVAC adaptor cord, as shown and described" D'513 Patent, claim
• The essential visual elements of the claimed design include:
  • The overall configuration of a cord with a three-prong plug on one end and a trifurcated termination with three alligator clips on the other.
  • The specific shape and surface features of the molded three-prong plug housing.
  • The particular shape, proportions, and appearance of the three alligator clips.

III. The Accused Instrumentality

Product Identification

The "HVAC Adaptor Cord" sold by Defendant Shenzhen Baichirui Technology Co., Ltd, operating under the Amazon seller name "ByteSwift" and through the "Bytcew Amazon Store" Compl. ¶1 Compl. ¶7

Functionality and Market Context

The complaint identifies the accused product as an electrical adaptor cord sold online, which it characterizes as "counterfeit and infringing merchandise" Compl. ¶1 The complaint alleges these products are offered for sale and sold to consumers throughout the United States, including Illinois, via commercial online marketplaces such as Amazon.com Compl. ¶3 Compl. ¶7 A side-by-side comparison provided in the complaint shows the accused product features a three-prong plug and three alligator clips connected by a cord, visually mirroring the configuration of the patented design Compl. Ex. 4, p. 2

IV. Analysis of Infringement Allegations

The complaint alleges that the accused product is "practically identical to the asserted design" and creates the "same overall visual impression on an ordinary observer" Compl. ¶17 The infringement argument is supported by a claim chart exhibit comparing figures from the D'513 Patent with photographs of the accused product.

A marketing photograph from the defendant's online store shows the accused HVAC adaptor cord in a coiled state, emphasizing its three-pronged plug and three alligator clips. Compl. Ex. 4, p. 2 Another image from the same exhibit presents the accused product in a staged "in-use" context, held in a person's hands. Compl. Ex. 4, p. 2 A third visual provides a close-up comparison between the patent's drawing of an alligator clip and a photograph of the corresponding clip on the accused product Compl. Ex. 4, p. 4

D'513 Patent Infringement Allegations

Claim Element (from the sole Design Claim)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The overall ornamental design of the HVAC adaptor cord, including the configuration of a three-prong plug, a Y-split cord, and three alligator clips.	The accused product is an HVAC adaptor cord embodying a three-prong plug, a Y-split cord, and three alligator clips that allegedly creates a visual impression substantially the same as the patented design.	¶17; Ex. 4	FIG. 1
The specific ornamental appearance of the three-prong plug housing.	The plug housing of the accused product is alleged to be visually indistinct from the plug housing shown in the patent's figures.	Ex. 4, p. 4	FIG. 9
The specific ornamental appearance of the alligator clips.	The alligator clips of the accused product are alleged to be "practically identical" to the clips shown in the patent's figures, contributing to the overall infringing appearance.	¶17; Ex. 4, p. 4	FIG. 10

Identified Points of Contention

• Scope Questions: The central question for the court will be one of design scope and application of the "ordinary observer" test. The issue is whether the accused product's design is substantially the same as the claimed design, such that an ordinary observer would be deceived into purchasing the accused product believing it was the patented one.
• Technical Questions: While design patents focus on ornamentality, a defense could raise questions about any perceived differences in proportion, surface texture, or specific contours between the accused product and the patent's drawings. The case may turn on whether such differences are significant enough to alter the overall visual impression for an ordinary observer.

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings, making formal claim construction of terms less common than in utility patent cases. The analysis focuses on the overall visual appearance of the claimed design.

• The Term: "The ornamental design for a HVAC adaptor cord, as shown and described"
• Context and Importance: The entire dispute hinges on the scope of this claimed design. The court's interpretation of the design's overall visual impression, and what features are material to it, will determine whether the accused product infringes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue that the claim covers the overall configuration and impression created by the combination of the plug, Y-split, and specific clip style, and that minor, unobservable, or trivial differences in dimension or finish do not escape infringement. The patent's multiple perspective views establish the core, consistent features of the design D'513 Patent, FIGS. 1-8
  • Evidence for a Narrower Interpretation: A defendant may argue that the patent only protects the exact ornamental features as depicted in the solid lines of the drawings. Any deviation in the accused product, such as different proportions, surface textures, or edge curvatures on the plug or clips, could be argued to create a different overall visual impression, thereby avoiding infringement D'513 Patent, FIG. 10 D'513 Patent, FIG. 11

VI. Other Allegations

• Indirect Infringement: The complaint makes passing allegations of indirect infringement and requests an injunction against aiding and abetting Compl. ¶9 Compl. Prayer 1(b) However, the factual allegations focus exclusively on the Defendant's own acts of making, offering for sale, and selling the accused products, without providing a specific factual basis for a separate claim of inducement or contributory infringement.
• Willful Infringement: The complaint alleges that Defendant's infringement was and is willful Compl. ¶14 This allegation is supported by claims that the accused product is "practically identical" to the patented design, which creates a "strong presumption of copying" Compl. ¶17, and that Defendant knowingly continues its activities without authorization from the Plaintiff Compl. ¶13

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

1. A core issue will be one of visual identity: Applying the ordinary observer test, is the overall ornamental design of the accused "HVAC Adaptor Cord" substantially the same as the design claimed in the D'513 patent, or are there sufficient visual differences to distinguish them in the eyes of a typical purchaser?
2. An evidentiary question will be one of copying: Will the high degree of visual similarity between the products, as alleged in the complaint's claim chart, be sufficient to support an inference of copying, which would strengthen the case for infringement and willfulness?
3. A practical question concerns enforcement: Given the allegations that the foreign Defendant operates through online marketplaces and may use methods to obscure its operations Compl. ¶¶11-12, how effectively can any potential injunction or damages award be enforced against the primary defendant and the third-party platforms it utilizes?