Actually, this sounds to me exactly like they are the OEM and they are respecting the rules of the contract but not a step more. Having worked with more than a few OEMs in the scientific industry, American ones at that, this is the exact response you would get from them if you tried to get a product which matches ours. We give specifications and lock down what is important in the contract, they design the thing for us (through many revisions), at the end we lock down anything else that has shown up as important: you pay through the nose at this point so better to try to lock it down earlier. Once that's complete, the OEM knows exactly what they can and can't do for other companies that come to them.
1) it is a flashlight, there is no proprietary IP in these lights other than trade dress.
2)they explicitly state they will not sell this version. They know the contract and what parts snap-on locked down. Same with the OEMs I work with. They know what they can and can't do. It's up to snap-on to write their contact properly.
3) this is a lighting design company. They have to make a living too with their designs. There are only so many designs of lights. As long as it didn't look identical or infringe on something snap-on locked down in their contact then they have every right to earn their living.
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I understand what you are saying. I know they do that in China. I have an ATD light which is sold under many brand names. That fits your description.
Because these don't exist elsewhere on the market, and because Snap On typically owns their designs, my guess is this was a build to print job. In that case, Snap On probably owns the design, spec, and injection molds. Snap On wouldn't want clones to show up in trucks for warranty service.
To complicate matters, here in the US, there is a distinction between the manufacturer and the design owner. Most times, the manufacturer or OEM IS the design owner. But not always.
Apple is a good example. We all know Apple doesn't manufacture everything. But they own all their designs. They spec internals. There are no apple designed hard drives for example. Within an Apple computer, there may be different brands of hard drives present.
I doubt this company could reuse Snap On's shape/molds. The batteries Snap On specified or the magnets, could be substituted for cheaper versions. And that's likely what this company would do.