The complaint
The case is Ford Global Technologies, LLC v. Empire Auto Parts, LLC, No. 3:26-cv-03754 (N.D. Tex.), a complaint for design patent infringement filed October 26, 2026, in the Dallas Division, ECF No. 1. The case is assigned to Judge Kasdin M. Mitchell. The complaint says Ford Global Technologies is a Michigan limited liability company with its principal place of business in Dearborn, Michigan, and a wholly owned subsidiary of Ford Motor Company that owns and manages Ford's intellectual property. It alleges, upon information and belief, that Empire Auto Parts is a limited liability company with its principal place of business in Totowa, New Jersey, that operates warehouse and distribution facilities in Texas, North Carolina, Georgia, Florida, Massachusetts, Maryland and Tennessee. It says Empire maintains a North Texas Distribution Center in Dallas, Texas. The complaint is signed by Melissa Richards Smith of Gillam & Smith, LLP in Marshall, Texas, and also lists Marc Lorelli, Francesca Cusumano-Gibson and Garrett Fridline of Brooks Kushman P.C. in Royal Oak, Michigan, with admission requests forthcoming.
Jurisdiction and venue
The complaint pleads subject matter jurisdiction under 28 U.S.C. 1331 and 1338(a). It alleges, on information and belief, that Empire sells infringing parts nationwide and ships them from its North Texas Distribution Center, and it alleges that Empire also sells them directly to customers there. It pleads venue and personal jurisdiction under 28 U.S.C. 1400 because Empire has committed acts of infringement in the district and has a regular and established place of business there.
The design patents
The complaint says Ford Global Technologies owns each patent and that each is assigned to it. It identifies these five design patents:
U.S. Patent No. D735,623, "Vehicle grille," issued August 4, 2015, which the complaint ties to the 2015-2017 F-150.
U.S. Patent No. D721,314, "Vehicle fender," issued January 20, 2015, tied to the 2015-2020 F-150.
U.S. Patent No. D721,307, "Vehicle hood," issued January 20, 2015, tied to the 2015-2020 F-150.
U.S. Patent No. D904,652, "Vehicle headlight," issued December 8, 2020, tied to the 2021-2024 Bronco Sport.
U.S. Patent No. D902,453, "Vehicle tail lamp," issued November 17, 2020, tied to the 2021-2024 Bronco Sport.
The complaint also says Ford Global Technologies owns the design patents listed in a schedule attached as Exhibit 1.
What the USPTO records show
The three F-150 patents issued from applications filed December 3, 2013. Each names Ford Motor Company as applicant and assignee on its face, and USPTO assignment records list one recorded assignment for each of them, from the inventors to Ford Motor Company, recorded January 8, 2014. The two Bronco Sport patents issued from applications filed August 2, 2019. Each names Ford Global Technologies, LLC as applicant and assignee, and the inventors' assignments to Ford Global Technologies were recorded August 14, 2019.
Each F-150 patent states a 14-year term, which runs to January 20, 2029 for the '314 and '307 patents and to August 4, 2029 for the '623 patent. Each Bronco Sport patent states a 15-year term, which runs to November 17, 2035 for the '453 patent and to December 8, 2035 for the '652 patent.
The infringement allegations
The complaint alleges that Empire is involved in the manufacture and distribution of aftermarket automotive parts, including headlights, tail lamps, grilles, hoods and fenders, that embody designs protected by Ford Global Technologies' design patents. It alleges, on information and belief, that Empire requires buyers to purchase in person or create a customer account before viewing parts, pricing or product details, and that its listings carry a "Ref OE #" that correlates to the corresponding Ford part number. It alleges that in 2025 Empire sold a 2016 F-150 grille (Item #F5548), a 2023 Bronco Sport headlamp assembly (Item #F6309) and a 2023 Bronco Sport tail lamp assembly (Item #F8380), and that in 2026 it sold 2019 F-150 right and left fenders (Items #F7583 and #F7584) and a 2019 F-150 hood (Item #F6455) at its Dallas location.
The complaint pleads five counts, one for each patent, each under 35 U.S.C. 271(a), and each presents a side-by-side comparison of a patent figure with the accused part: the '623 patent with the grille, the '314 patent with the fenders, the '307 patent with the hood, the '652 patent with the headlight and the '453 patent with the tail lamp. It alleges, upon information and belief, that Empire knew of the asserted patents at least as of the filing of the complaint, including through its reference to Ford part numbers and its direct copying, and alleges willful and deliberate infringement under each count. It reserves the right under Rule 15 to amend to assert the Exhibit 1 patents and others.
The relief sought
The prayer asks for judgments that Empire infringed each of the five patents; injunctions for the full term of each patent against Empire, its officers, agents, attorneys and employees, those acting in privity or concert with them, and those that receive the infringing parts from them; damages under 35 U.S.C. 284 and/or Empire's profits under 35 U.S.C. 289 for each patent; a finding of willful infringement with trebled recovery; a declaration that the case is exceptional with attorneys' fees, disbursements and costs under 35 U.S.C. 285; prejudgment and post-judgment interest and costs; and other relief. The complaint demands a jury under Rule 38(b).
What to watch next
Watch for service on Empire Auto Parts, LLC, for admission of the Brooks Kushman lawyers, and for an answer or a Rule 12 motion.