Federal Circuit Affirms in North Star v. Latham Design Patent Case

Updated on Dec. 3, 2025 | Written by Patsnap Team

Introduction

The Federal Circuit has affirmed the lower court’s decision in North Star Technology International Limited v. Latham Pool Products, Inc., concluding a nearly two-year design patent infringement dispute over fiberglass swimming pool designs. The appeal, docketed as Case No. 23-2138, ended on April 24, 2025, when the court issued a summary order: “AFFIRMED.”

This case centered on two ornamental design patents—USD0791966S and USD0794213S—allegedly infringed by Latham’s Corinthian 16 fiberglass pool. For IP professionals monitoring the recreational products sector, this ruling reinforces critical principles regarding design patent enforcement and appellate review standards.

Case Summary

Case Overview

The Parties

North Star Technology International Limited initiated this infringement action as patent holder. Latham Pool Products, Inc., a major fiberglass pool manufacturer, defended against claims that its Corinthian 16 model infringed North Star’s design patents.

The Design Patents at Issue

Two U.S. design patents formed the litigation basis:

• ⚖️ USD0791966S (App. No. 29/553,069)
• ⚖️ USD0794213S (App. No. 29/553,476)

Design patents protect ornamental appearance rather than functional features. Explore similar design patent cases on Patsnap Eureka IP to understand how courts analyze visual similarity in consumer products.

The Accused Product

The Corinthian 16 fiberglass swimming pool was alleged to infringe North Star’s protected designs. Fiberglass pools represent a substantial market segment where aesthetic differentiation drives purchasing decisions.

Litigation Timeline & Procedural History

📅 July 11, 2023: Appeal filed with Federal Circuit from District of Columbia proceedings

📅 April 24, 2025: Federal Circuit affirms lower court ruling

Duration: 653 days—consistent with standard Federal Circuit processing for design patent appeals involving claim construction and ordinary observer analysis.

The case proceeded through the Federal Circuit, which holds exclusive appellate jurisdiction over patent matters per 28 U.S.C. § 1295.

The Verdict & Legal Analysis

Outcome

💡 Key Insight: The summary affirmance—”ORDERED AND ADJUDGED: AFFIRMED”—signals strong appellate deference to the lower court’s factual findings and infringement analysis.

The ruling upheld judgment for defendant Latham Pool Products, Inc. No damages were awarded to plaintiff North Star Technology International Limited. Track litigation outcome trends on Patsnap Eureka IP for pattern analysis across design patent cases.

Legal Significance

Appellate Deference: Summary affirmances indicate substantial agreement with lower court claim construction and infringement determinations. Design patent infringement receives mixed review—claim construction de novo, infringement findings more deferential.

Design Patent Standards: Under Egyptian Goddess, Inc. v. Swisa, Inc., infringement requires proving an ordinary observer, familiar with prior art designs, would be deceived into believing the accused design matches the patented design.

Precedential Value: As non-precedential summary disposition, this ruling doesn’t establish binding precedent but reinforces that well-supported trial court findings survive appellate review.

Strategic Takeaways

⚖️ For Patent Holders:

• Design patent enforcement requires strong visual similarity evidence
• Prior art knowledge shapes the ordinary observer comparison
• Build robust trial records—appellate reversals are difficult

🔬 For R&D Teams:

• Conduct freedom-to-operate (FTO) analyses before product launches
• Document design evolution to establish independent creation
• Analyze patent landscapes on Patsnap Eureka IP during development

📊 For IP Professionals:

• Design-around strategies should focus on visible distinctions
• Prior art development remains a powerful defensive tool
• Monitor competitor design filings systematically

Industry & Competitive Implications

The swimming pool industry increasingly relies on design differentiation in mature markets. This ruling carries several implications:

Market Impact: Latham Pool Products, Inc. continues selling the Corinthian 16 without modification, preserving its competitive position.

Licensing Dynamics: Patent holders facing similar fact patterns may recalibrate enforcement strategies based on this affirmance outcome.

Design Investment: Manufacturers may invest more in distinctive design development while conducting thorough prior art searches. Research patent families on Patsnap Eureka IP to identify competitive design landscapes.

💡 Industry Insight: Companies in design-sensitive consumer markets should implement proactive clearance protocols and monitor competitor design patent portfolios continuously.

Key Takeaways

⚖️ For Patent Attorneys:

• Summary affirmances signal strong deference to trial court design patent findings
• Egyptian Goddess ordinary observer test remains controlling
• Claim construction and infringement findings receive different review standards

📊 For IP Professionals:

• Design portfolios require strategic enforcement decisions
• Prior art documentation essential for prosecution and defense
• Validity challenges remain viable defensive strategies

🔬 For R&D Leaders:

• Implement design clearance protocols pre-launch
• Maintain design evolution records
• Consider design patent filing for commercially significant aesthetics

Cases to Watch: Monitor Federal Circuit design patent rulings for evolving ordinary observer applications in consumer products.

FAQ

What patents were involved in North Star v. Latham Pool Products? Two U.S. design patents—USD0791966S and USD0794213S—covering ornamental swimming pool designs were at issue in this design patent infringement action.

What was the outcome of the Federal Circuit appeal? The Federal Circuit affirmed the lower court ruling in favor of defendant Latham Pool Products, Inc., dismissing North Star’s appeal after 653 days of proceedings. The basis of termination was recorded as “Appeal Dismissed.”

How does this case affect swimming pool design patent litigation? The ruling reinforces that design patent holders must establish clear visual similarity under the ordinary observer standard, and that well-supported trial court findings will likely survive appellate review. Companies should conduct thorough FTO analyses before product launches.

For comprehensive patent litigation monitoring and competitive intelligence, start your patent research on Patsnap Eureka IP.

Disclaimer: This article is for informational and educational purposes only and does not constitute legal advice. The information presented is limited to publicly available information as of April 2025, including court records, USPTO databases, and company websites. Readers should consult with qualified legal counsel for advice on specific legal matters. We will continue to update this information as it becomes available and welcome any feedback.