Galaxy Projector Patent Win: Default Judgment in Design IP Case Against Dongguan Zhirong

Case Overview

The Parties

The Patent at Issue

The central intellectual property at issue is **U.S. Design Patent No. USD964,636S** (Application No. 29/794,690). Design patents under 35 U.S.C. § 171 protect the ornamental appearance of a functional article — in this case, the distinctive visual design of a galaxy/planetarium projector device. Unlike utility patents, design patent infringement is assessed under the **ordinary observer test**: whether an ordinary consumer would find the accused product substantially similar in overall visual impression to the patented design.

• • US D964,636S — Ornamental design of a galaxy/planetarium projector

The Verdict & Legal Analysis

Outcome

The court granted **default judgment** in favor of Shenzhen Bolong Technology Co., Ltd. The civil case was formally terminated on **February 13, 2026**. Specific damages amounts were not disclosed in the available case record, which is not uncommon in default judgment proceedings where the court may address damages separately or where the parties resolve quantum post-judgment. Injunctive relief details similarly were not specified in the available termination order language.

Key Legal Issues

The basis for termination was an **infringement action** under the design patent statute. Because no defendant appeared, there was no adversarial claim construction proceeding, no invalidity challenge, and no contested infringement analysis. The default judgment mechanism under **Federal Rule of Civil Procedure 55** operates on the principle that a defendant’s failure to respond constitutes an admission of the plaintiff’s well-pleaded factual allegations. For design patent cases specifically, this matters significantly: the plaintiff’s complaint would have alleged that Dongguan Zhirong’s galaxy projector products were substantially similar in ornamental appearance to the USD964,636S design — and with no rebuttal, those allegations stood uncontested.