Shenzhen Ruisike Industrial Development Co Ltd v. Individuals Corps Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Ruisike Industrial Development Co., Ltd. (China)
  • Defendant: The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule "A"
  • Plaintiff's Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:26-cv-07544, N.D. Ill., 06/29/2026
• Venue Allegations: Venue is asserted based on Defendants being foreign entities not residing in any U.S. judicial district, and having purposefully directed commercial activities toward Illinois through interactive e-commerce storefronts accessible to consumers in the district.
• Core Dispute: Plaintiff alleges that numerous e-commerce sellers, identified on a schedule, are infringing its U.S. design patent by advertising, offering for sale, and selling automotive connectors with a substantially similar ornamental appearance.
• Technical Context: The technology at issue is the ornamental design for an automotive plug-in connector, a device type commonly used for aftermarket vehicle electronics such as fuel management system disablers that connect to a vehicle's On-Board Diagnostics (OBD2) port.
• Key Procedural History: The complaint is structured as a "Schedule A" action, a procedural approach often used to collectively sue numerous, and often anonymous, online merchants in a single lawsuit to combat widespread e-commerce infringement. The complaint alleges this is necessary because Defendants can obscure their identities and quickly move infringing listings to new storefronts.

Case Timeline

Date	Event
2024-12-27	'623 Patent Priority Date (File Date)
2025-04-01	'623 Patent Issue Date
2026-06-29	Complaint Filing Date

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

U.S. Design Patent No. D1,068,623 - "Connector for Automobile"

• Patent Identification: U.S. Design Patent No. D1,068,623 (the "'623 Patent"), titled "Connector for Automobile," issued April 1, 2025.

The Invention Explained

• Problem Addressed: Design patents protect ornamental appearance rather than functional utility. The '623 Patent does not describe a technical problem but instead provides a new, original, and ornamental design for an article of manufacture, specifically an automotive connector ("'623 Patent, title; '623 Patent, claim").
• The Patented Solution: The patent protects the unique visual appearance of the connector as depicted in its figures ("'623 Patent, claim"). The design consists of a housing with a generally rectangular main body featuring rounded top corners, a trapezoidal lower connector interface, and distinct ribbed texturing on its side surfaces ("'623 Patent, FIG. 1; '623 Patent, FIG. 3; '623 Patent, FIG. 5"). The broken lines shown in the drawings, such as the internal pin configuration, illustrate portions of the article that do not form part of the claimed design ("'623 Patent, description").
• Technical Importance: The complaint alleges that the patented design is embodied in Plaintiff's "AFM/DFM disabler product" ("Compl. ¶1"), suggesting the design's commercial importance lies in creating a distinct and recognizable product appearance in the aftermarket automotive electronics market.

Key Claims at a Glance

• The patent asserts a single claim: "The ornamental design for a connector for automobile, as shown and described" ("'623 Patent, claim").
• The scope of this claim is defined by the visual characteristics depicted in the solid lines of the patent's eight figures, which collectively illustrate the design's overall shape, proportions, and surface ornamentation from multiple perspectives ("'623 Patent, FIGS. 1-8").

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Unauthorized Products" sold by the Schedule A Defendants on various online marketplaces, including Amazon, Walmart, eBay, AliExpress, and TikTok Shop ("Compl. ¶1"). These products are generally described as "AFM or DFM disabler devices, active fuel management delete devices, [and] OBD2 plug-in automotive control devices" ("Compl. ¶2; Compl. ¶21").

Functionality and Market Context

The complaint asserts that the infringement claim is independent of the products' "internal electronics, functionality, or intended use" ("Compl. ¶21"). The core allegation is that these products, regardless of their specific function, share the "same or substantially similar ornamental connector design and overall visual appearance" as that claimed in the '623 Patent ("Compl. ¶21"). The complaint includes images of Plaintiff's own commercial product, which embodies the patented design. Product Image 1 in the complaint shows a frontal view of what is described as Plaintiff's AFM/DFM disabler, illustrating the claimed overall shape and surface branding ("Compl. ¶11").

IV. Analysis of Infringement Allegations

The complaint does not contain a formal claim chart. Instead, it advances a narrative theory of infringement based on the "ordinary observer" test, which is the standard for design patent infringement. The core allegation is that Defendants' products are "substantially the same as the patented design in the eyes of an ordinary observer, giving such attention as a purchaser usually gives" ("Compl. ¶27").

The complaint alleges that the "Unauthorized Products embody the overall ornamental design claimed in the '623 Patent" by having the "same or substantially similar overall configuration, shape, contour, surface ornamentation, and visual appearance depicted in the drawings of the '623 Patent" ("Compl. ¶23"). While the complaint references "screenshots and evidence showing Defendants' accused online marketplace listings" in an "Exhibit B," that exhibit was not provided with the filed complaint ("Compl. ¶24"). Therefore, a direct visual comparison between the patented design and the accused products is not possible based on the provided document.

• Identified Points of Contention:
  • Scope Questions: The central legal question will be the application of the "ordinary observer" test. The court will need to determine if the accused products and the patented design are "substantially the same" such that an ordinary observer would be deceived into purchasing the former thinking it was the latter. This will involve comparing the overall visual impression of the accused products to the drawings in the '623 Patent.
  • Technical Questions: A key factual question will be whether the specific visual features of the various accused products are sufficiently similar to the patented design. This analysis may focus on comparing elements such as the housing's proportions, the curvature of the corners, and the pattern of the side-surface texturing. A potential issue for the court is how to apply this analysis uniformly to a large number of different products sold by the various Schedule A defendants.

V. Key Claim Terms for Construction

In design patent litigation, there are no "terms" to construe in the manner of utility patents. The "claim" is the visual design itself, as depicted in the drawings. The analysis focuses on the scope of the claimed design as a whole.

• The "Term": "The ornamental design for a connector for automobile, as shown and described" ("'623 Patent, claim").
• Context and Importance: The interpretation of the design's overall visual appearance is dispositive. The court's analysis will determine the scope of protection by identifying the ornamental features shown in solid lines while separating them from the functional or disclaimed aspects shown in broken lines. Practitioners may focus on which visual elements are most prominent and contribute most to the design's overall impression.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party seeking a broader scope may argue that the overall impression is defined by the combination of a rectangular housing with rounded top corners, textured side grips, and a trapezoidal connector port. They may contend that minor variations in proportion or the specific ribbing pattern do not alter this overall impression, and thus fall within the claim's scope. The general title, "Connector for Automobile," could be cited to support a focus on the general form rather than minute details ("'623 Patent, title").
  • Evidence for a Narrower Interpretation: A party seeking a narrower scope may argue that the design is defined by its precise details, including the specific radius of the corners, the exact number and spacing of the ribs on the side surfaces, and the specific proportions of the housing as shown in the figures ("'623 Patent, FIG. 5; '623 Patent, FIG. 6"). They could argue that any deviation from this specific depiction creates a different overall visual impression, thus avoiding infringement. The explicit disclaimer of elements in broken lines reinforces that the claim is limited to the specific visual features shown in solid lines ("'623 Patent, description").

VI. Other Allegations

• Indirect Infringement: The complaint's factual allegations focus on direct infringement by the Defendants for making, using, selling, offering for sale, and importing the accused products ("Compl. ¶34"). While the prayer for relief seeks to enjoin those "aiding, abetting, [or] contributing to" infringement, the complaint does not plead specific facts to support a standalone claim for either induced or contributory infringement ("Compl. ¶C, p. 9").
• Willful Infringement: Willfulness is alleged on the basis that Plaintiff provided public notice of its patent rights by "identifying U.S. Design Patent No. D1,068,623 S in product listing images and marketing materials associated with Plaintiff's commercial embodiment" ("Compl. ¶40"). The complaint asserts that despite this notice, Defendants continued their allegedly infringing activities ("Compl. ¶40"). This alleges pre-suit knowledge through constructive notice.

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

1. A Question of Visual Similarity: The case's outcome will hinge on the "ordinary observer" test. Does the overall ornamental appearance of the various accused products create an impression that is "substantially the same" as the design claimed in the "'623 Patent", or are there sufficient visual differences to distinguish them in the eyes of a typical consumer of aftermarket automotive parts?

2. A Question of Procedural Efficacy: A central procedural challenge will be managing a single design patent claim against a large and diverse group of "Schedule A" defendants. The court will need to address how to conduct infringement analysis across potentially numerous, distinct product variations and how to effectively provide due process to defendants who may be difficult to identify and serve.