DCT

1:26-cv-10788

Zhuang v. Hongkong Uking Trading Ltd

Key Events

Complaint

complaint Intelligence

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Penghang Zhuang (People's Republic of China)
- Defendant: HONGKONG UKING TRADING LIMITED (Hong Kong)
- Plaintiff’s Counsel: Law Office of Peilin Chen
Case Identification: 1:26-cv-10788, N.D. Ill., 09/08/2026
Venue Allegations: Venue is based on Defendant’s alleged commercial activities directed at consumers in Illinois, conducted through an interactive e-commerce store. The allegations are supported by a test purchase of the accused product that was shipped to Illinois.
Core Dispute: Plaintiff alleges that Defendant’s stadium seat product infringes a U.S. design patent covering the ornamental design for a stadium seat.
Technical Context: The dispute concerns portable stadium seats, a consumer product designed to provide cushioned seating and back support on bleachers or benches.
Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

Date	Event
2022-01-19	’123 Patent Priority Date
2023-03-21	’123 Patent Issue Date
2026-09-08	Complaint Filing Date

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

U.S. Design Patent No. D981,123 S - "CHAIR"

Patent Identification: U.S. Design Patent No. D981,123 S (the “’123 Patent”), "CHAIR", issued March 21, 2023.

The Invention Explained

Problem Addressed: Design patents protect the way an article looks, not how it works. This patent does not describe a technical problem but instead claims a new, original, and ornamental design for a chair ([’123](https://ai-lab.exparte.com/patent/D981123) Patent, Claim).
The Patented Solution: The patent protects the specific aesthetic appearance of a portable stadium seat as depicted in its figures ([’123](https://ai-lab.exparte.com/patent/D981123) Patent, Figs. 1-10). The claimed design consists of the visual features shown in solid lines, which include the overall configuration of the folding seat and backrest, the particular shape of the hinge covers, and a distinctive cylindrical mesh cup holder attached to the side of the seat base ([’123](https://ai-lab.exparte.com/patent/D981123) Patent, Fig. 1; [’123](https://ai-lab.exparte.com/patent/D981123) Patent, Fig. 10). Portions of the chair shown in broken lines, such as the carrying straps and parts of the underlying support frame, are explicitly not part of the claimed design ([’123](https://ai-lab.exparte.com/patent/D981123) Patent, Description, col. 1:65-68).
Technical Importance: The complaint alleges that the patented design has achieved commercial success and has been well received by consumers, suggesting its aesthetic appearance has market value ([Compl. ¶10](https://ex:cit:6)).

Key Claims at a Glance

Design patents contain a single claim. The asserted claim is for "The ornamental design for a chair, as shown and described" ([’123](https://ai-lab.exparte.com/patent/D981123) Patent, Claim).
The scope of the claim is defined by the solid lines in the patent's drawings. Key ornamental features include:
- The overall visual configuration of the seat and backrest assembly.
- The specific appearance of the hinge mechanisms connecting the seat and backrest.
- A hook-like feature on the underside of the seat.
- A cylindrical, mesh-textured cup holder affixed to the side of the seat cushion.

III. The Accused Instrumentality

Product Identification

The accused product is a stadium-seat product identified by Amazon Standard Identification Number (ASIN) B0GBW5PV29 (the "Accused Product") ([Compl. ¶1](https://ex:cit:7)).

Functionality and Market Context

The Accused Product is a portable stadium seat sold in the United States through an Amazon storefront named "UkingDirect" under the seller alias "Sekey" ([Compl. ¶1](https://ex:cit:7); [Compl. ¶5](https://ex:cit:8)).
The complaint alleges that the "overall appearance and configuration" of the Accused Product is "substantially similar" to the design claimed in the ’123 Patent ([Compl. ¶12](https://ex:cit:9)). The complaint provides a visual comparison showing side-by-side images of the patented design and photographs of the Accused Product from multiple angles ([Compl. ¶12](https://ex:cit:9)). This chart juxtaposes patent figures with corresponding product photos to highlight alleged similarities in the front, back, side, and detailed views ([Compl. ¶12](https://ex:cit:9)).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Product's design is "substantially the same" as the patented design, which is the standard for design patent infringement ([Compl. ¶17](https://ex:cit:10)). While the complaint refers to a "more detailed infringement analysis" in an Exhibit B, that exhibit was not attached to the publicly filed complaint ([Compl. ¶13](https://ex:cit:11)). The infringement theory is primarily presented through a series of side-by-side visual comparisons ([Compl. ¶12](https://ex:cit:9)).

D981,123 S Infringement Allegations

Key Ornamental Feature (from Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
The ornamental design for a chair, as shown and described, including its overall configuration as a folding stadium seat.	The Accused Product is a folding stadium seat with an overall configuration that the complaint alleges is substantially similar to the patented design.	¶12	col. 1:59-59
A cylindrical, mesh-textured cup holder attached to the side of the seat cushion.	The Accused Product includes a cylindrical, mesh-textured cup holder attached to the side of the seat, as shown in a detailed comparison view.	¶12	col. 1:63-64
The specific appearance of the hinge mechanism covers connecting the seat and backrest.	The Accused Product features hinge mechanism covers that the complaint's images suggest are visually similar in shape and placement to those in the patent figures.	¶12	col. 1:63-64
A hook feature located on the underside of the seat for attachment to a bleacher.	The Accused Product incorporates a hook on its underside that appears visually comparable to the hook shown in the patented design.	¶12	col. 1:60-60

Identified Points of Contention:
- Overall Appearance: The central legal test for design patent infringement is whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused device, believing it to be the patented one. The dispute will hinge on a comparison of the total ornamental appearance of the designs, not a simple checklist of features.
- Role of Prior Art: The scope of a design patent is viewed in the context of prior art. A key question for the court will be whether the similarities between the ’123 Patent and the Accused Product are limited to features that were already common in the field of stadium seats before the patent was filed.
- Disclaimed vs. Claimed Features: The ’123 Patent disclaims certain functional elements, like carrying straps, by showing them in broken lines ([’123](https://ai-lab.exparte.com/patent/D981123) Patent, Description). A potential point of contention is whether the perceived similarity between the products is driven by these unprotected, functional elements, which would not support a finding of infringement.

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings rather than textual limitations, so disputes over the construction of specific terms are less common and central than in utility patent cases. The primary analysis will focus on the overall visual appearance of the claimed design as depicted in the patent's figures, rather than the definition of any particular word in the single, boilerplate claim.

VI. Other Allegations

Indirect Infringement: The complaint does not plead a separate count for indirect (induced or contributory) infringement.
Willful Infringement: The complaint does not contain an explicit allegation of willful infringement, nor does it plead facts to suggest the Defendant had pre-suit knowledge of the ’123 Patent.

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

The resolution of this case will likely depend on the court's answers to two main questions:

The Ordinary Observer Test: From the perspective of an ordinary purchaser of stadium seats, is the overall ornamental design of the Accused Product substantially the same as the design claimed in the ’123 Patent? This will involve a holistic visual comparison by the fact-finder.
Scope of the Patented Design: A critical issue will be the scope of the design patent's protection in light of prior art. The court must determine whether the accused design appropriates the novel ornamental aspects of the ’123 Patent or whether the similarities between the two products are confined to functional elements or features that were already conventional in the marketplace.