General Motors LLC v. Quality Collision Parts Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: General Motors LLC (Delaware) and GM Global Technology Operations LLC (Delaware)
  • Defendant: Quality Collision Parts, Inc. (Michigan), Power Auto Parts Inc. (Michigan), AP Auto Parts Industrial Ltd. (Taiwanese), and Jiangsu Srumto Auto Parts Co., Ltd. (Chinese)
  • Plaintiff’s Counsel: Honigman LLP; Fish & Richardson P.C.
• Case Identification: 2:26-cv-10391, E.D. Mich., 02/03/2026
• Venue Allegations: Venue is based on Defendant Quality Collision Parts, Inc. having a regular and established place of business and having offered to sell or sold accused products within the Eastern District of Michigan. Venue for the foreign defendants, Srumto and AP, is alleged under 28 U.S.C. § 1391(c)(3).
• Core Dispute: Plaintiff alleges that Defendants’ aftermarket automotive components, such as bumpers, fenders, and hoods, infringe seventeen of Plaintiff's U.S. design patents covering the ornamental appearance of those vehicle parts.
• Technical Context: The dispute is set in the automotive collision repair and aftermarket parts industry, where the aesthetic and ornamental design of replacement parts is critical for matching the original appearance of a a vehicle.
• Key Procedural History: Plaintiff alleges compliance with patent marking statutes by providing notice via a public website, which lists the Asserted Patents and the products they cover. This allegation may be used to support claims for damages and willful infringement.

Case Timeline

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

U.S. Design Patent No. D749,997 - "Vehicle Rear Bumper"

• Issued: February 23, 2016

The Invention Explained

• Problem Addressed: The complaint asserts that Plaintiff invests heavily in creating "innovative and aesthetically beautiful designs" to distinguish its vehicles in the marketplace Compl. ¶18 The implicit problem is the need to protect the unique visual identity of vehicle components from imitation Compl. ¶¶2-3
• The Patented Solution: The ’997 Patent protects the specific ornamental design for a vehicle rear bumper (’997 Patent, claim). The design is defined by the solid lines in the patent's drawings, which depict a bumper with distinctive features such as integrated corner steps and a recessed central portion (’997 Patent, FIG. 1; ’997 Patent, FIG. 4). The broken lines in the drawings indicate portions of the bumper that are not part of the claimed design (’997 Patent, description).
• Technical Importance: An automotive part's ornamental design is a critical component of a vehicle's overall brand identity and aesthetic appeal, influencing consumer perception and purchasing decisions Compl. ¶18

Key Claims at a Glance

• The single asserted claim is: "The ornamental design for a vehicle rear bumper, as shown and described" (’997 Patent, claim).
• In a design patent, the claim protects the overall ornamental visual appearance of the object as depicted in the drawings. The essential elements are the specific shapes, contours, and surface ornamentation shown in solid lines in Figures 1-4 of the patent.

U.S. Design Patent No. D792,815 - "Vehicle Front Bumper"

• Issued: July 25, 2017

The Invention Explained

• Problem Addressed: As with the ’997 patent, the problem is protecting the unique aesthetic of a vehicle component to maintain brand distinctiveness Compl. ¶¶18-19
• The Patented Solution: The ’815 Patent protects the ornamental design for a vehicle front bumper (’815 Patent, claim). The claimed design, shown in solid lines in the drawings, is characterized by its overall shape, the configuration of a central recessed area, and the specific geometry of features at either end of the bumper (’815 Patent, FIG. 1; ’815 Patent, FIG. 2). Portions shown in broken lines are disclaimed and do not form part of the patented design (’815 Patent, description).
• Technical Importance: The front bumper is a primary visual element of a vehicle's "face" and is therefore fundamental to its design identity and market recognition Compl. ¶18

Key Claims at a Glance

• The single asserted claim is: "The ornamental design for a vehicle front bumper, as shown and described" (’815 Patent, claim).
• The claim covers the overall ornamental visual appearance of the front bumper as depicted in the patent's drawings, specifically the features rendered in solid lines.

U.S. Design Patent No. D792,816 - "Vehicle Front Bumper"

• Issued: July 25, 2017
• Technology Synopsis: This patent protects an ornamental design for a vehicle front bumper. The design is similar to the ’815 patent but appears to represent a different configuration or version of a front bumper design.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’816 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1002869 infringes the ’816 patent Compl. ¶¶48-49

U.S. Design Patent No. D793,301 - "Automobile Front Lower Fascia"

• Issued: August 1, 2017
• Technology Synopsis: This patent protects the ornamental design for the lower fascia portion of a vehicle's front end, characterized by its specific contours and openings.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’301 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1015135 infringes the ’301 patent Compl. ¶¶54-55

U.S. Design Patent No. D828,247 - "Vehicle Hood"

• Issued: September 11, 2018
• Technology Synopsis: This patent protects the ornamental design for a vehicle hood, defined by its surface sculpting, character lines, and overall shape.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’247 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1230475C infringes the ’247 patent Compl. ¶¶60-61

U.S. Design Patent No. D828,248 - "Vehicle Hood"

• Issued: September 11, 2018
• Technology Synopsis: This patent protects another distinct ornamental design for a vehicle hood, characterized by a different arrangement of contours and surface features compared to the ’247 patent.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’248 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1230477 infringes the ’248 patent Compl. ¶¶66-67

U.S. Design Patent No. D828,256 - "Vehicle Fender"

• Issued: September 11, 2018
• Technology Synopsis: This patent protects the ornamental design for a vehicle fender, notable for its specific wheel arch shape and surface character lines.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’256 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1240413 infringes the ’256 patent Compl. ¶¶72-73

U.S. Design Patent No. D847,703 - "Vehicle Rear Bumper"

• Issued: May 7, 2019
• Technology Synopsis: This patent protects an ornamental design for a vehicle rear bumper, distinct from the ’997 patent, featuring a different configuration of steps and recesses.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’703 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1102577 infringes the ’703 patent Compl. ¶¶78-79

U.S. Design Patent No. D848,318 - "Vehicle Front Upper Bumper Fascia"

• Issued: May 14, 2019
• Technology Synopsis: This patent protects the ornamental design for the upper fascia of a vehicle's front bumper, defined by its specific shape and interaction with headlamp and grille areas.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’318 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1014134 infringes the ’318 patent Compl. ¶¶84-85

U.S. Design Patent No. D856,874 - "Vehicle Bumper Bar"

• Issued: August 20, 2019
• Technology Synopsis: This patent protects the ornamental design for a vehicle bumper bar, focusing on the aesthetic appearance of this structural component.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’874 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1002875 infringes the ’874 patent Compl. ¶¶90-91

U.S. Design Patent No. D818,406 - "Vehicle Front Fender"

• Issued: May 22, 2018
• Technology Synopsis: This patent protects an ornamental design for a vehicle front fender, featuring a particular profile and character lines flowing from the hood and door seams.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’406 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1241409SF infringes the ’406 patent Compl. ¶¶96-97

U.S. Design Patent No. D883,155 - "Vehicle Fender"

• Issued: May 5, 2020
• Technology Synopsis: This patent protects another distinct ornamental design for a vehicle fender, characterized by different surface contours and wheel arch treatment.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’155 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1240422 infringes the ’155 patent Compl. ¶¶102-103

U.S. Design Patent No. D902,807 - "Vehicle Hood"

• Issued: November 24, 2020
• Technology Synopsis: This patent protects an ornamental design for a vehicle hood, notable for its pronounced central dome and flanking character lines.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’807 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1230483 infringes the ’807 patent Compl. ¶¶108-109

U.S. Design Patent No. D930,533 - "Vehicle Front Fender"

• Issued: September 14, 2021
• Technology Synopsis: This patent protects an ornamental design for a vehicle front fender, defined by a sharp upper character line and a sculpted lower section near the wheel arch.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’533 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1240418 infringes the ’533 patent Compl. ¶¶114-115

U.S. Design Patent No. D955,939 - "Vehicle Front Bumper"

• Issued: June 28, 2022
• Technology Synopsis: This patent protects an ornamental design for a vehicle front bumper, characterized by its integrated fog lamp housings and lower air dam configuration.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’939 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1002899 infringes the ’939 patent Compl. ¶¶120-121

U.S. Design Patent No. D859,239 - "Vehicle Rear Bumper"

• Issued: September 10, 2019
• Technology Synopsis: This patent protects an ornamental design for a vehicle rear bumper, featuring a specific configuration of corner steps, trailer hitch housing, and overall contours.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’239 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM1102570 infringes the ’239 patent Compl. ¶¶126-127

U.S. Design Patent No. D848,647 - "Vehicle Front Headlamp"

• Issued: May 14, 2019
• Technology Synopsis: This patent protects the ornamental design for a vehicle headlamp assembly, defined by its exterior shape and the arrangement of internal lighting elements.
• Asserted Claims: The single claim for the ornamental design "as shown and described" (’647 Patent, claim).
• Accused Features: The complaint alleges that aftermarket Part No. GM2502497 infringes the ’647 patent Compl. ¶¶132-133

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are aftermarket "replacement copy parts for automotive vehicles" Compl. ¶24 The complaint identifies specific exemplary parts by part number for each asserted patent, such as Part No. GM1103180 (a rear bumper) and Part No. GM1002861 (a front bumper) Compl. ¶36 Compl. ¶42

Functionality and Market Context

The complaint alleges that the Accused Products are manufactured, imported, and sold by the Defendants as direct replacements for "GM Genuine Parts" Compl. ¶¶24-25 Their function is to replace original equipment manufacturer (OEM) components on vehicles, particularly after a collision. The complaint asserts that the Defendants' business is "premised on offering replacement parts that match the ornamental appearance of genuine OEM components," indicating their market position as lower-cost aesthetic equivalents to GM's own parts Compl. ¶25

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products infringe the Asserted Patents under the "ordinary observer" test Compl. ¶27 This test for design patent infringement asks whether an ordinary observer, giving such attention as a purchaser usually gives, would be deceived into purchasing the accused product believing it to be the patented design. For each asserted patent, the complaint alleges that an exemplary accused part is "substantially similar" to the claimed design and references a corresponding claim chart attached as an exhibit Compl. ¶37 Compl. ¶43 As these exhibits are not included with the complaint, the specific visual comparisons are not detailed in the pleading itself.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Visual Similarity: The central dispute will be a visual one: does the overall ornamental appearance of each accused part create substantially the same visual impression as the corresponding patented design? The analysis will focus on similarities and differences in shapes, contours, and surface features.
• Scope of Protection vs. Prior Art: The scope of GM's design patents will be a key issue. Defendants may argue that the patented designs are not substantially different from prior art designs for similar vehicle parts, which could narrow the scope of protection and require a closer identity for a finding of infringement.
• Functionality: A potential point of contention is whether certain features of the patented designs are dictated by function rather than ornament. Design patents only protect non-functional, ornamental aspects of an article. Defendants may argue that aspects of the bumpers, hoods, or fenders are functional (e.g., for aerodynamics, cooling, or attachment to the vehicle frame) and therefore should be excluded from the infringement analysis, potentially weakening the claim of overall similarity.

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is the design itself as depicted in the drawings, rather than a set of text-based limitations. Therefore, claim construction focuses on interpreting the scope of the visual design.

The Term

"The ornamental design for a [vehicle part], as shown and described."

Context and Importance

The construction of this "term"—that is, the scope of the visual design—is the core of the case. The court's interpretation will define what is protected and set the parameters for the "ordinary observer" infringement test. Practitioners may focus on this issue because the perceived breadth of the design determines how different an accused product must be to avoid infringement.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: Plaintiff will likely point to the overall visual impression created by the combination of elements shown in solid lines in the patent figures (’997 Patent, FIG. 1; ’815 Patent, FIG. 1). The argument would be that the claim covers the novel aesthetic as a whole, and an accused design that copies this overall look infringes, even with minor variations.
• Evidence for a Narrower Interpretation: Defendants may argue for a narrower scope by emphasizing the specific details and contours shown in the drawings. They will also point to the broken lines in the figures, which explicitly disclaim those portions of the article from the scope of the claim (’997 Patent, description; ’815 Patent, description). Furthermore, they may argue that any features common to prior art vehicle parts or dictated by function should be given little weight, limiting the claim's scope to only the novel and purely ornamental aspects of the design.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement.

• Inducement (§ 271(b)): Plaintiff alleges Defendants induce infringement by providing the Accused Products to distributors, repair shops, and end users, thereby encouraging them to import, sell, and use parts that directly infringe the patented designs (Compl. ¶¶28-29, 31).
• Contributory (§ 271(c)): The complaint alleges that Defendants sell components of the accused parts (e.g., a step pad for a bumper) knowing they are material parts of the claimed design, are "especially made and especially adapted for use" in an infringing manner, and have no "substantial non-infringing use" Compl. ¶¶30-32

Willful Infringement

For each asserted patent, the complaint alleges that Defendants' infringement was and continues to be willful Compl. ¶38 Compl. ¶44 The basis for this allegation is Defendants' alleged pre-suit knowledge of the Asserted Patents, purportedly obtained via Plaintiff's virtual patent marking website Compl. ¶23, and their subsequent disregard for an "objectively high likelihood of infringement" Compl. ¶38

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

The resolution of this multi-patent dispute will likely depend on the court's determination of three central questions:

• Visual Equivalence: The primary question is a factual one of visual comparison: are the Defendants' aftermarket parts "substantially the same" as GM's patented designs from the perspective of an "ordinary observer" familiar with the prior art? This will require a side-by-side analysis for each of the seventeen asserted patents.
• Scope and Functionality: A critical legal question will be defining the proper scope of GM's design patents. This involves determining the extent to which the claimed designs are truly ornamental versus being dictated by function, which will in turn influence the degree of similarity required to prove infringement.
• Pre-Suit Knowledge and Willfulness: A key question for damages will be whether GM can prove that the Defendants had actual knowledge of the specific patents-in-suit prior to the lawsuit. The effectiveness of GM's virtual patent marking website as a means of providing legally sufficient notice will be a central element in the claim for willful infringement and potential enhanced damages.