Design Patent Infringement Demand

Ornamental Design Protection – 35 U.S.C. § 171

Understanding Design Patents
35 U.S.C. § 171: "Whoever invents any new, original and ornamental design for an article of manufacture may obtain a patent therefor." Design patents protect the visual appearance of a product—its shape, configuration, surface ornamentation, or combination thereof.
What Design Patents Protect
  • Shape/Configuration: The three-dimensional form of an article (e.g., the curved body of a bottle, the shape of a chair)
  • Surface Ornamentation: Two-dimensional patterns, textures, or graphics applied to a surface (e.g., fabric pattern, GUI icons)
  • Combination: Both shape and surface ornamentation together
  • Partial Designs: Specific portions of an article shown in solid lines (broken lines indicate unclaimed portions)
Design Patent Basics
Aspect Design Patent
Patent Number Format Begins with "D" (e.g., D950,123)
Term 15 years from grant (no maintenance fees)
Claims Single claim: "The ornamental design for [article] as shown"
Scope Defined By Drawings (solid lines = claimed; broken lines = environment/context)
Requirements Novel, non-obvious, ornamental (not purely functional)
Cost to Obtain $2,000-$5,000 (simpler than utility patents)
Design vs. Utility Patents
Feature Design Patent Utility Patent
Protects How it looks (ornamental) How it works (functional)
Infringement Test Ordinary observer – visual similarity All-elements rule – claim chart
Claim Format Drawings define scope Written claims with elements
Damages Total profit from article (§ 289) Lost profits or reasonable royalty (§ 284)
Term 15 years from grant 20 years from filing
Maintenance Fees None Required at 3.5, 7.5, 11.5 years
Functionality Limitation: Design patents only protect ornamental aspects. If a design feature is dictated primarily by function (the article wouldn't work without that shape), it's not protectable by design patent. Functional features require utility patent protection.
Common Design Patent Categories
  • Consumer electronics: Smartphones, tablets, headphones, speakers
  • Furniture: Chairs, tables, lighting fixtures
  • Packaging: Bottles, containers, boxes
  • Vehicles: Automotive body designs, wheels
  • Apparel: Shoe designs, jewelry, handbags
  • GUIs: Icons, screen layouts, animated transitions
  • Housewares: Kitchen tools, appliances, decorative items
The Ordinary Observer Test
Egyptian Goddess, Inc. v. Swisa, Inc. (Fed. Cir. 2008): The test for design patent infringement is whether "an ordinary observer, familiar with the prior art designs, would be deceived into believing that the accused product is the same as the patented design."
Key Principles
  • Overall visual impression: Focus on the design as a whole, not individual features in isolation
  • Ordinary observer: A typical purchaser of the type of article, not an expert
  • Prior art context: The more crowded the field (many similar prior art designs), the smaller differences become significant
  • Deception standard: Would the observer believe the accused design is the same as the patented design?
  • Side-by-side not required: Comparison is from memory, as purchasers encounter products in marketplace
Conducting Visual Comparison

Step 1: Identify the Claimed Design

  • Review all drawing figures in the design patent
  • Solid lines = claimed design features
  • Broken/dashed lines = unclaimed context (article environment, not protected)
  • Consider all views together (front, back, side, top, bottom, perspective)

Step 2: Identify the Accused Design

  • Photograph accused product from same angles as patent drawings
  • Match perspectives for accurate comparison
  • Document the accused product as sold/marketed

Step 3: Compare Overall Visual Impression

  • Look at designs as a whole, not feature-by-feature
  • Identify similarities in shape, configuration, proportions
  • Note differences but evaluate their visual significance
  • Consider what an ordinary purchaser would notice

Step 4: Consider Prior Art

  • In crowded fields, small differences matter more
  • If prior art is sparse, broader similarities may suffice for infringement
  • Prior art defines the "design space" and what makes the patented design novel
Visual Comparison Example
[Patented Design Image]
Patented Design (D950,XXX)
[Accused Product Image]
Accused Product
Factors Supporting Infringement
  • Same overall shape and proportions
  • Similar curves, angles, and contours
  • Matching surface ornamentation or textures
  • Same visual "character" or impression
  • Differences are in minor or unnoticeable features
  • Defendant copied design after seeing patent
Factors Against Infringement
  • Substantially different overall impression
  • Differences in prominent visual features
  • Prior art designs are very similar to patented design (crowded field)
  • Accused design is closer to prior art than to patented design
  • Different proportions, shapes, or ornamentation visible to ordinary observer
Point of Novelty (Obsolete): Before Egyptian Goddess, courts required showing infringement of the "point of novelty." This is no longer required—focus solely on overall visual impression in light of prior art.
Design Patent Damages – 35 U.S.C. § 289
§ 289 Total Profit Disgorgement: "Whoever during the term of a patent for a design... applies the patented design... to any article of manufacture... shall be liable to the owner to the extent of his total profit, but not less than $250."
The § 289 Advantage

Design patent damages under § 289 can be more favorable than utility patent damages because:

  • Total profit, not apportionment: Unlike utility patents (reasonable royalty), § 289 allows recovery of the infringer's total profit from the article
  • No lost profits requirement: Don't need to prove you would have made the sale
  • Minimum $250: Statutory floor even without proving profits
  • Applies per article: Each infringing item can generate damages
Samsung v. Apple: "Article of Manufacture"
Samsung Electronics v. Apple Inc. (2016): The Supreme Court held that the "article of manufacture" for § 289 damages can be the whole product OR a component of the product. This matters when the design patent covers only part of a multi-component product. Key Factors:
  • Is the design applied to the whole product or just a component?
  • Can the component be sold separately?
  • Is the component physically or conceptually distinct?
  • What would a consumer identify as the article bearing the design?
Calculating § 289 Damages
Step Analysis
1. Identify Article of Manufacture The product (or component) to which the design is applied
2. Calculate Infringer's Revenue Total sales revenue from the article
3. Deduct Infringer's Costs Manufacturing, materials, direct labor (not overhead typically)
4. Result = Total Profit This amount is recoverable under § 289
Alternative Damages Under § 284

Design patent owners can also recover under the standard patent damages statute (§ 284):

  • Lost profits: If patent owner competes and would have made the sales
  • Reasonable royalty: What a willing licensor/licensee would agree to
  • Enhanced damages: Up to 3x for willful infringement
Strategic Choice: Patent owners can choose § 284 or § 289 damages (whichever is higher), but cannot double-recover. § 289's total profit approach is often more lucrative when infringer's margins are high.
Other Remedies
  • Injunctive relief (§ 283): Preliminary and permanent injunctions available
  • Attorney fees (§ 285): In exceptional cases
  • ITC exclusion orders: Block imports of infringing articles (Section 337)
  • Customs enforcement: Register design patent with CBP to detain infringing imports
Sample Design Patent Demand Letters
Sample 1: Standard Design Patent Demand
[Patent Owner / Law Firm] [Address] [Email / Phone] [Date] VIA CERTIFIED MAIL AND EMAIL [Defendant Company] [Address] Attn: Legal Department / CEO Re: Infringement of U.S. Design Patent No. D[XXX,XXX] – Demand for Cessation Dear [Recipient]: We represent [Patent Owner], owner of United States Design Patent No. D[XXX,XXX] (the "'XXX Design Patent"), which protects the ornamental design for [article description, e.g., "a beverage container"]. A copy of the design patent is enclosed. THE PATENTED DESIGN The 'XXX Design Patent was issued on [Date] and claims the ornamental design shown in the patent drawings. [Patent Owner] invested significant resources in creating this distinctive design, which has become associated with [Patent Owner]'s [product line/brand]. INFRINGEMENT [Defendant] is selling a product marketed as "[Accused Product Name]" that infringes the 'XXX Design Patent. Enclosed as Exhibit A is a visual comparison of [Defendant]'s product and the patented design. As the comparison demonstrates, [Defendant]'s product embodies substantially the same overall visual impression as the patented design: • Both designs feature [similar shape/contour description] • Both share [similar proportions/dimensions] • Both include [similar surface features or ornamentation] • The overall visual impression is substantially identical Under the "ordinary observer" test established in Egyptian Goddess, Inc. v. Swisa, Inc., an ordinary purchaser familiar with prior art designs would be deceived into believing [Defendant]'s product is the same as [Patent Owner]'s patented design. DAMAGES Design patent infringement subjects [Defendant] to significant liability under 35 U.S.C. § 289, including: • [Defendant]'s TOTAL PROFIT from all sales of the infringing product • Minimum statutory damages of $250 per article • Injunctive relief barring further sales Additionally, this letter provides actual notice of the design patent. Continued sales after receipt of this letter may constitute willful infringement, exposing [Defendant] to enhanced damages and attorney fees. DEMAND [Patent Owner] demands: 1. Immediate cessation of all manufacture, importation, sale, and offer for sale of [Accused Product] and any substantially similar products; 2. Recall or destruction of all infringing inventory; 3. A complete accounting of all [Accused Product] units manufactured, imported, and sold, along with revenue and profit figures; 4. Compensation for past infringement. Please respond within fourteen (14) days. If we do not receive a satisfactory response, [Patent Owner] will pursue all available legal remedies, including federal court litigation and ITC exclusion proceedings. Sincerely, [Attorney Name] Counsel for [Patent Owner] Enclosures: - U.S. Design Patent No. DXXX,XXX - Exhibit A: Visual Comparison
Sample 2: Design Patent Demand – Consumer Electronics
[Company / Law Firm] [Address] [Date] [Defendant] [Address] Attn: General Counsel Re: U.S. Design Patent No. D[XXX,XXX] – [Product Category] Design Dear Counsel: [Patent Owner] holds U.S. Design Patent No. D[XXX,XXX] covering the ornamental design for [electronic device type]. We have identified [Defendant]'s [Product Name] as an infringing product. DESIGN PATENT PROTECTION The 'XXX Design Patent protects the distinctive ornamental appearance of [Patent Owner]'s [product], including: • The overall form factor and proportions • The arrangement and styling of [buttons/ports/display elements] • The [curved edges/flat surfaces/specific contours] • The [surface textures/finishes/ornamentation] These design elements are shown in solid lines in the patent drawings (enclosed). Broken-line elements are not claimed. INFRINGEMENT ANALYSIS [Defendant]'s [Product] copies the protected ornamental features of the 'XXX Design Patent: Visual Similarity Analysis: ┌─────────────────────────┬─────────────────────────┐ │ Patented Design │ [Defendant]'s Product │ ├─────────────────────────┼─────────────────────────┤ │ [Shape feature] │ Substantially identical │ │ [Proportion feature] │ Substantially identical │ │ [Contour feature] │ Substantially identical │ │ [Surface feature] │ Substantially identical │ └─────────────────────────┴─────────────────────────┘ The differences between the patented design and [Defendant]'s product are minor and would not prevent an ordinary observer from being deceived into believing they are the same design. DAMAGES EXPOSURE Under 35 U.S.C. § 289, [Defendant] is liable for its TOTAL PROFIT from sales of the [Product]. Based on publicly available information, [Defendant] has sold approximately [X] units at approximately $[Y] per unit. [Defendant]'s profit exposure is substantial. RESOLUTION We propose: 1. [Defendant] immediately cease sales of [Product] in its current form; 2. [Defendant] provide sales data for damages calculation; 3. Parties negotiate licensing or settlement. Alternatively, [Defendant] may redesign [Product] to avoid infringement. We are willing to review proposed redesigns before implementation. Please respond by [Date]. We prefer resolution without litigation but will protect [Patent Owner]'s rights if necessary. Regards, [Name] [Title] Enclosure: U.S. Design Patent No. DXXX,XXX
Sample 3: Design Patent + Trade Dress Demand
[Patent Owner / Law Firm] [Address] [Date] [Defendant] [Address] Re: Design Patent Infringement (D[XXX,XXX]) and Trade Dress Infringement Dear [Recipient]: We represent [Patent Owner] regarding infringement of its intellectual property rights by [Defendant]'s [Product]. DESIGN PATENT CLAIM [Patent Owner] owns U.S. Design Patent No. D[XXX,XXX] covering the ornamental design for [article]. [Defendant]'s [Product] copies this protected design, as demonstrated in the enclosed visual comparison. TRADE DRESS CLAIM In addition to design patent protection, [Patent Owner]'s product design constitutes protectable trade dress under 15 U.S.C. § 1125(a). The distinctive [shape/configuration/appearance] of [Patent Owner]'s [product] has acquired secondary meaning through: • Over [X] years of exclusive use in commerce • $[X] million in advertising featuring the design • [X] million units sold • Media coverage and consumer recognition • Intentional copying by competitors (including [Defendant]) [Defendant]'s confusingly similar product is likely to cause consumer confusion as to source, sponsorship, or affiliation. COMBINED EXPOSURE [Defendant] faces liability under both claims: • Design Patent (§ 289): Total profits from infringing sales • Trade Dress (15 U.S.C. § 1117): Defendant's profits, plaintiff's damages, costs, and potentially attorney fees DEMAND [Defendant] must: 1. Cease all manufacture, sale, and marketing of [Product]; 2. Recall infringing products from distribution channels; 3. Provide accounting of sales and profits; 4. Compensate [Patent Owner] for infringement. Please respond within twenty-one (21) days. Sincerely, [Attorney Name] Enclosures: - U.S. Design Patent No. DXXX,XXX - Visual Comparison Exhibit - Evidence of Secondary Meaning

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