Zeng v. Schedule A

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jian Zeng (Sichuan Province, China)
  • Defendant: The Individuals, Partnerships, and Unincorporated Associations Identified in Schedule "A" (Foreign Jurisdictions)
  • Plaintiff's Counsel: DNL Zito
• Case Identification: 2:26-cv-00469, W.D. Pa., 03/22/2026
• Venue Allegations: Venue is asserted on the basis that the defendants are foreign entities who do not reside in the United States and are therefore subject to venue in any judicial district. The complaint also alleges defendants direct business activities to and derive revenue from Pennsylvania.
• Core Dispute: Plaintiff alleges that Defendants' "Solar Stair Lamps," sold through various online marketplaces, infringe a U.S. design patent for the ornamental design of a solar stair lamp.
• Technical Context: The technology involves solar-powered lighting fixtures, a mature and competitive segment of the consumer electronics market focused on outdoor and landscape illumination.
• Key Procedural History: The complaint does not mention any prior litigation or administrative proceedings involving the patent-in-suit. The case targets numerous unidentified online sellers, a common enforcement strategy against diffuse infringement on e-commerce platforms.

Case Timeline

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

U.S. Design Patent No. D1,067,475 - "Solar Stair Lamp"

Issued March 18, 2025 (hereinafter "D'475 Patent").

The Invention Explained

• Problem Addressed: As a design patent, the D'475 Patent does not articulate a technical problem but instead provides a new, original, and ornamental design for an article of manufacture D'475 Patent, abstract
• The Patented Solution: The patent protects the specific visual appearance of a solar stair lamp. The design consists of a body with a right-triangular side profile, creating a wedge shape D'475 Patent, FIG. 5 The hypotenuse face of the wedge features a rectangular solar panel with a surface texture of horizontal lines, which is divided into three sections D'475 Patent, FIG. 1 D'475 Patent, FIG. 7 The rear vertical face incorporates mounting features D'475 Patent, FIG. 2 D'475 Patent, FIG. 6 The overall aesthetic is a compact, geometric form intended for mounting on a vertical surface like a stair riser.
• Technical Importance: The design provides a distinct visual identity for a solar-powered lighting product in a competitive consumer market Compl. ¶5

Key Claims at a Glance

• Design patents contain a single claim, which is asserted in the complaint Compl. ¶43 The claim of the D'475 Patent is for "The ornamental design for a solar stair lamp, as shown and described" D'475 Patent, Claim
• The essential visual elements of the claimed design are:
  • The overall configuration of a wedge-shaped body with a right-triangular profile.
  • The appearance of the front face, which includes a segmented, line-textured solar panel.
  • The specific proportions and arrangement of features as depicted in the solid lines of Figures 1-8 of the patent.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Solar Stair Lamps" sold by the defendants, collectively referred to as the "Infringing Products" Compl. p. 1

Functionality and Market Context

• The accused products are described as solar-powered lamps designed for lighting stairs Compl. ¶44 They are sold to consumers in the United States through online marketplaces, including Amazon.com, Walmart.com, and Temu.com Compl. ¶8 Compl. ¶23
• The complaint alleges these products are sold in direct competition with the plaintiff's authorized products and that the defendants engage in deceptive online sales tactics, such as concealing their identity and manipulating product reviews Compl. p. 1 Compl. ¶11 The complaint further alleges that the defendants are all believed to be importing and selling products made by the same unknown foreign manufacturer Compl. ¶27

IV. Analysis of Infringement Allegations

The complaint references an Exhibit B containing claim charts, but this exhibit was not attached to the publicly filed document Compl. ¶22 Compl. ¶43 The infringement theory is therefore summarized from the complaint's narrative allegations.

The core of the infringement allegation is that the accused Solar Stair Lamps are "substantially identical" to the ornamental design claimed in the D'475 Patent Compl. ¶22 Compl. ¶45 Design patent infringement is determined by the "ordinary observer" test, which asks whether an ordinary observer would believe the accused design is the same as the patented design. The complaint asserts that the Infringing Products are "structurally identical" and that any differences are "merely aesthetic such as the colors," which would not alter the overall visual impression Compl. ¶22 The plaintiff alleges this substantial identity is likely to cause consumer confusion and erode market confidence Compl. ¶22 No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The primary legal question in design patent cases is the application of the ordinary observer test. A point of contention may be whether an ordinary observer, taking into account the prior art, would find the overall visual impression of the accused products to be substantially the same as the design claimed in the D'475 Patent.
  • Technical Questions: The dispute is not technical in a functional sense but is based on a visual comparison. The central question will be factual: do the specific proportions, surface treatments, and overall shape of the accused products create a visual appearance that is substantially the same as that depicted in the figures of the D'475 patent? The complaint makes this allegation but does not provide visual evidence to support it Compl. ¶24

V. Key Claim Terms for Construction

Claim construction for design patents is not focused on textual terms but rather on the scope of the design as a whole, as depicted in the patent's drawings. The single claim recites "the ornamental design for a solar stair lamp, as shown and described" D'475 Patent, Claim There are no specific terms that are likely to require formal construction. The analysis will instead focus on the visual comparison of the accused products to the patented design drawings, viewed from the perspective of an ordinary observer.

VI. Other Allegations

• Indirect Infringement: The complaint makes a passing reference to indirect infringement but does not plead a separate count or provide specific factual allegations to support the required elements of knowledge and intent for either induced or contributory infringement Compl. ¶46 The focus of the suit is direct infringement.
• Willful Infringement: The complaint alleges that defendants' infringement is "knowingly and intentionally, or at least with reckless disregard or willful blindness to Plaintiff's rights" Compl. ¶37 It further alleges, upon information and belief, that defendants "are aware of Plaintiff and the Asserted Patent" Compl. ¶16(h) These allegations form the basis for the willfulness claim.

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

1. A core issue will be one of visual comparison: will an ordinary observer, giving the attention a purchaser usually gives, find the overall ornamental design of the defendants' "Solar Stair Lamps" to be substantially the same as the design claimed in the D'475 Patent? The outcome will depend on a direct comparison between the accused products and the patent's figures.

2. A significant procedural question will be whether the plaintiff can substantiate its allegation that the numerous, pseudo-anonymous defendants are sufficiently linked-either by selling identical products from a common source or by engaging in a coordinated scheme-to be properly joined in a single lawsuit Compl. ¶22(c) Compl. ¶27