DCT

1:26-cv-04075

Jackson Hole Jewelry Co LLC v. Baylink Internet LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-04075, E.D.N.Y., 07/08/2026
  • Venue Allegations: Venue is alleged to be proper in the Eastern District of New York because Defendants transact business and direct infringing activities toward New York, and Defendant Rose Pear Inc. is incorporated in New York.
  • Core Dispute: Plaintiff alleges that Defendants' online jewelry sales infringe a design patent and a copyright related to Plaintiff's "Teton Collection" of jewelry inspired by the Grand Tetons mountain range.
  • Technical Context: The dispute is set in the luxury and direct-to-consumer jewelry market, where distinctive ornamental designs serve as a primary basis for brand identity and commercial value.
  • Key Procedural History: The complaint alleges that in 2023, Plaintiff notified Defendant Baylink of its copyright claims and that Plaintiff subsequently submitted Digital Millennium Copyright Act (DMCA) Takedown Notices regarding the accused products.

Case Timeline

Date Event
2013-01-01 Inventor began designing the "Teton Stacking Rings" (approximate date)
2014-06-01 "Teton Stacking Rings Copyright" was published
2014-06-30 Plaintiff began selling pieces in the "Teton Collection" (approximate date)
2017-01-01 Inventor began designing the "Teton Outline Stacking Bracelet" (approximate date)
2017-03-31 Plaintiff began selling the "Teton Outline Stacking Bracelet" (approximate date)
2017-07-05 D830,875 Patent Priority Date (Application Filing Date)
2017-07-25 "Teton Stacking Rings Copyright" was registered with the U.S. Copyright Office
2018-10-16 U.S. Design Patent No. D830,875 issued
2023-01-01 Plaintiff notified Defendant Baylink of alleged copyright infringement (approximate date)
2024-01-01 Plaintiff discovered alleged infringement on additional Defendant websites (approximate date)
2026-06-05 Assignment of the D875 Patent was recorded in the USPTO
2026-07-08 Complaint Filing Date

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

U.S. Design Patent No. D830,875 - "Bracelet"

This patent was issued on October 16, 2018 (the "'875 Patent").

The Invention Explained

  • Problem Addressed: The complaint describes a market for original, luxury jewelry designs inspired by natural forms, specifically the Grand Tetons mountain range Compl. ¶¶2, 15 The patent addresses the need for a unique ornamental appearance for an article of jewelry to create a distinct and recognizable product.
  • The Patented Solution: The '875 Patent claims the ornamental design for a bracelet Compl. ¶24 '875 Patent, claim The design, depicted in the patent's figures, consists of a continuous band with a prominent jagged, mountain-like silhouette along its outer edges, creating a stylized representation of a mountain range '875 Patent, FIGS. 1-3
  • Technical Importance: In the context of jewelry design, the commercial importance of the patented design stems from its purported unique and aesthetic appearance, which allows it to serve as a signature element of a collection and a source of brand goodwill Compl. ¶¶15-16

Key Claims at a Glance

  • The complaint asserts infringement of the sole claim of the '875 Patent Compl. ¶39
  • The claim covers "The ornamental design for a bracelet, as shown and described" '875 Patent, claim The essential visual elements of the claim are the specific shapes and contours of the bracelet depicted in the solid lines of the patent's figures, including the perspective, front, rear, top, bottom, and side views '875 Patent, FIGS. 1-7

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Infringing Products," which are jewelry items sold by Defendants through e-commerce websites including www.37jewelry.com, www.37bracelets.com, and www.37necklaces.com Compl. ¶3 Specific accused products are depicted with names such as "Keep Climbing Stacking Mountain Ring - 3 Set" and "Thank you for being my rock Stack Ring" Compl. p. 10

Functionality and Market Context

The complaint alleges the accused products are "nearly identical, poorly-made knock-offs" of Plaintiff's "Teton Collection" designs Compl. ¶3 They are marketed and sold at a significantly lower price point ($29.99 to $45.80) than Plaintiff's authentic pieces ($249.00 to $19,300.00), allegedly to trade on the goodwill of Plaintiff's designs (Compl. ¶2; Compl. ¶3). The complaint provides a side-by-side visual comparison of Plaintiff's jewelry designs with what it labels as "Defendants' Infringing Products" Compl. p. 10

IV. Analysis of Infringement Allegations

D875 Patent Infringement Allegations

Claim Element (from Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
The ornamental design for a bracelet, as shown and described. The complaint alleges that the "Infringing Products" bear a design that is "substantially similar to the ornamental design of the D875 Patent." The primary visual evidence provided consists of side-by-side comparisons of Defendants' rings with Plaintiff's rings. ¶51; p. 10 col. 1:16-17
  • Identified Points of Contention:
    • Scope Questions: The most significant issue appears to be a potential mismatch between the claimed article of manufacture and the accused products. The case raises the question: can a design patent explicitly claiming an "ornamental design for a bracelet" be infringed by products that the complaint primarily identifies and depicts as finger rings? Compl. p. 10 '875 Patent, title
    • Technical Questions: Assuming the article of manufacture issue can be overcome, the central factual question for the infringement analysis will be whether an ordinary observer, giving the attention a purchaser usually gives, would be deceived into purchasing one of the accused products believing it to be the patented design. The court's application of this test may be influenced by the differences in scale, proportion, and typical use between a bracelet and a ring.

V. Key Claim Terms for Construction

  • The Term: "bracelet"
  • Context and Importance: This term defines the article of manufacture to which the ornamental design is applied. Its construction appears to be central to the infringement analysis. Practitioners may focus on this term because the complaint's allegations of patent infringement Compl. ¶51 are supported by visual evidence of accused products that appear to be finger rings Compl. p. 10, while the patent is expressly for a "bracelet" '875 Patent, title '875 Patent, claim If the accused rings are determined not to be "bracelets" within the meaning of the claim, the patent infringement cause of action may fail.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint does not present arguments for a broad interpretation. A plaintiff in such a position might argue that the core novelty is in the transferable surface ornamentation itself, but the intrinsic record offers little support for detaching the design from its stated article of manufacture.
    • Evidence for a Narrower Interpretation: The intrinsic evidence strongly points toward a narrow construction. The patent is explicitly titled "Bracelet" '875 Patent, (54), and the single claim is for "The ornamental design for a bracelet..." '875 Patent, col. 1:16-17 Furthermore, the figures depict an object consistent in shape and proportion with a bracelet designed to be worn on a wrist '875 Patent, FIGS. 1, 4, 8

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain specific allegations of indirect patent infringement (e.g., induced or contributory infringement). The Second Cause of Action pleads direct infringement under 35 U.S.C. § 271 Compl. ¶51
  • Willful Infringement: The complaint alleges that Defendants' infringement of the '875 Patent was committed "knowingly, willfully, and in reckless disregard" and "in total disregard of Plaintiff's intellectual property rights" Compl. ¶39 Compl. ¶52 While the complaint does not specify the basis for knowledge regarding the patent itself, it does allege that Plaintiff provided pre-suit notice to Defendant Baylink in 2023 concerning infringement of its copyrights for related jewelry designs Compl. ¶33

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

  • A core issue will be one of definitional scope: can the claim for an "ornamental design for a bracelet," as specified in the '875 Patent, be construed to read on the accused products, which the complaint's own evidence depicts as finger rings? The outcome of this "article of manufacture" question may be dispositive for the patent infringement claim.
  • A key evidentiary question will be one of visual identity: if the case proceeds past the article of manufacture issue, the analysis will turn on the "ordinary observer" test. The court will need to determine if an ordinary observer would be deceived by the similarity between the patented bracelet design and the accused ring designs, a comparison complicated by the inherent differences in scale, proportion, and application between the two types of jewelry.
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