The court held that Tonchean made and sold unauthorized products substantially similar to the patented design, violating U.S. Design Patent No. D986,339. The ruling grants a permanent injunction against further infringement but leaves the final damages award pending, requiring the plaintiff to submit a supplemental brief detailing its claim.
The dispute centers on U.S. Design Patent No. D986,339, which covers the ornamental design for a puzzle table. The patent was issued to inventor William Huang in May 2023 and subsequently assigned to the plaintiff, GZ Long Ya Trading Co., Ltd.
The defendant operates an e-commerce store on Wayfair owned by Ganzhou Tong Cheng An E-Commerce Co., Ltd. The court deemed the defendant to have admitted it sold at least 402 units of infringing puzzle tables, generating revenue of at least $55,300, after the defendant failed to timely respond to discovery and Requests for Admission.
The only difference the defendant identified between its products and the patented design was the presence of two additional drawers beneath the flipped tabletop. The court applied the "ordinary observer" test and concluded the designs were substantially similar enough to deceive a purchaser.
The defendant attempted to challenge the patent’s validity by arguing that features like drawers and tilting mechanisms were functional rather than ornamental. The court rejected this, noting that functionality does not preclude protectable ornamentation in design patents when alternative designs exist.
The defendant’s failure to timely respond to discovery and comply with local summary judgment rules led the court to deem many of its factual disputes admitted. The defendant also missed a deadline for Requests for Admission, which established that it sold products bearing the patented design.
The court granted a permanent injunction to prevent further infringement, relying on its prior findings that monetary damages alone were inadequate to address the harm to the plaintiff’s brand and goodwill.
The court denied the plaintiff’s request for attorneys’ fees, finding that while the defendant failed to comply with certain procedural rules, this did not rise to the level of an exceptional case warranting fee-shifting under 35 U.S.C. § 285.
The court ordered the plaintiff to submit a supplemental brief detailing its damages claim by May 8, 2026. The defendant has until May 22 to respond.