DCT
2:25-cv-02985
Shang Hai Ai Mu Bo Zhi Neng Ke Ji You Xian Gong Si v. NOCO Co
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SHANG HAI AI MU BO ZHI NENG KE JI YOU XIAN GONG SI dba LUCKFIRE, et al. (People's Republic of China)
- Defendant: The NOCO Company (Ohio)
- Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
- Case Identification: 2:25-cv-02985, D. Ariz., 10/08/2025
- Venue Allegations: Venue is asserted based on Defendant's alleged research and development office in Phoenix, Arizona, and its enforcement of the patent-in-suit against the Plaintiffs within the district.
- Core Dispute: Plaintiffs, a group of e-commerce sellers, seek a declaratory judgment that their vehicle battery jump starter products do not infringe Defendant’s patent, following Defendant's infringement complaints on the Amazon marketplace which resulted in the delisting of Plaintiffs' products.
- Technical Context: The technology concerns portable, multi-function devices that combine a lithium-ion battery jump starter for vehicles with an air compressor for inflating tires.
- Key Procedural History: The complaint alleges that this lawsuit was precipitated by Defendant lodging multiple infringement complaints against Plaintiffs on Amazon.com between June and August 2025, which led to the removal of Plaintiffs' product listings.
Case Timeline
| Date | Event |
|---|---|
| 2017-09-22 | U.S. Patent No. 11,611,222 Priority Date |
| 2018-12-14 | U.S. Patent No. 11,611,222 Filing Date |
| 2023-03-21 | U.S. Patent No. 11,611,222 Issue Date |
| 2025-06-01 | Defendant begins lodging Amazon infringement complaints (approximate date) |
| 2025-10-08 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,611,222 - PORTABLE VEHICLE BATTERY JUMP STARTER WITH AIR PUMP
Issued March 21, 2023. (’222 Patent)
The Invention Explained
- Problem Addressed: The patent's background section describes challenges with prior art jump starting devices, including the danger of improper connections, the inconvenience of devices requiring a second vehicle, and the lack of robust, multi-functional, portable solutions. (’222 Patent, col. 2:52-60). The patent also identifies a need for improved safety features, more rigid internal frames for durability, and better user interfaces. (’222 Patent, col. 4:26-40).
- The Patented Solution: The invention is a handheld apparatus integrating a rechargeable lithium-ion battery, a vehicle jump starter, and an air compressor into a single unit. (’222 Patent, Abstract). The device includes a microcontroller and various sensors to manage safety functions, such as detecting the presence and polarity of a connected vehicle battery to prevent damage from incorrect connections. (’222 Patent, col. 5:9-20). The specification describes embodiments where all components are contained within a single housing, providing a self-contained solution for roadside emergencies. (’222 Patent, col. 36:20-29).
- Technical Importance: The invention combines multiple emergency automotive tools into a compact, portable, and safer device, leveraging lithium-ion battery technology to reduce the size and weight compared to traditional lead-acid jump starters. (’222 Patent, Abstract).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1. (Compl. ¶43).
- The essential elements of independent claim 1 are:
- A vehicle battery jump starter with air pump device, comprising:
- a cover;
- an internal power supply disposed within the cover, the internal power supply comprises a rechargeable battery;
- a vehicle battery jump starter disposed within the cover, the vehicle battery jump starter configured to jump start a vehicle battery and for providing a power to the rechargeable battery during operation of the vehicle battery jump starter;
- an air pump disposed within the cover, the air pump configured to provide a supply of pressurized air, the air pump provided and powered by the rechargeable battery during operation of the air pump; and
- a USB input connector for charging the rechargeable battery.
- The complaint does not explicitly reserve the right to seek judgment on other claims but requests a declaration that the Accused Products do not infringe "any claims of the Patent." (Compl. ¶48).
III. The Accused Instrumentality
Product Identification
The Accused Products are various models of vehicle battery jump starters sold by Plaintiffs on the Amazon marketplace under numerous ASINs, including B0DW37C9MX and B0D3X1FR59. (Compl. ¶28).
Functionality and Market Context
- The complaint describes the Accused Products as multi-function devices that provide vehicle jump-starting and air compressing capabilities. (Compl. ¶28, ¶44).
- Plaintiffs allege key functional differences from the patented invention. Specifically, the complaint states the Accused Products are constructed with two separate and independently usable covers or housings: one for the battery and air pump, and another for the jump starter. (Compl. ¶44). It further alleges the jump starter delivers power directly to the vehicle's starter motor, bypassing the vehicle battery, and that the devices use a modern USB-C port for charging, which supports protocols like USB Power Delivery (PD). (Compl. ¶45, ¶46).
- The complaint alleges that listings on the Amazon marketplace are Plaintiffs' primary sales channel into the United States. (Compl. ¶29).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement. The following table summarizes the Plaintiffs' arguments for why their products do not meet the limitations of claim 1.
U.S. Patent No. 11,611,222 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cover | Plaintiffs allege the Accused Products do not have a single cover enclosing all components, but instead use two separate covers: "Cover A" for the battery and air pump, and "Cover B" for the jump starter, which are not structurally connected during use. | ¶44 | col. 52:1-2 |
| a vehicle battery jump starter...configured to jump start a vehicle battery | Plaintiffs allege the Accused Products jump-start the vehicle engine directly by delivering power to the starter motor, bypassing the vehicle's battery, which they contend is distinct from being "configured to jump start a vehicle battery." | ¶45 | col. 52:10-12 |
| a USB input connector for charging the rechargeable battery | Plaintiffs allege the Accused Products do not have a "USB input port" but instead include a "USB-C port" that performs different functions, such as enabling fast charging via the USB Power Delivery (PD) protocol, and has a different structural configuration. | ¶46 | col. 52:20-21 |
- Identified Points of Contention:
- Scope Questions: A central dispute may be whether the term "a cover" can be construed to read on a device comprised of two separate, non-connected housings. A related question is whether the claimed "USB input connector" is limited to older USB standards or if it is broad enough to encompass modern, multi-functional USB-C ports.
- Technical Questions: The complaint raises the question of whether there is a fundamental operational difference between "jump start[ing] a vehicle battery" and directly powering a vehicle's starter motor. The case may require expert testimony on the common understanding of the term "jump start" in the relevant art at the time of the invention.
V. Key Claim Terms for Construction
The Term: "a cover"
- Context and Importance: This term is critical because Plaintiffs' primary non-infringement argument is that their products use two separate, non-connected housings, whereas they contend the claim requires a single, unitary cover for all components. (Compl. ¶44). Practitioners may focus on whether the singular article "a" limits the claim to a single structure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of the indefinite article "a" could be argued to mean "at least one," which may not preclude multiple, cooperative structures forming a cover. The specification also discusses embodiments with multiple "coverings," such as "one covering resting within other cover." (’222 Patent, col. 50:49-52).
- Evidence for a Narrower Interpretation: The figures in the patent consistently depict a single, integrated housing for the device (e.g., ’222 Patent, FIG. 7, FIG. 81). The summary of the invention repeatedly describes the components as being "disposed within the cover," which may imply a single, shared enclosure. (’222 Patent, col. 26:1-6).
The Term: "configured to jump start a vehicle battery"
- Context and Importance: Plaintiffs argue their products do not meet this limitation because they allegedly jump-start the engine directly, bypassing the vehicle's battery. (Compl. ¶45). The interpretation of this phrase will determine whether such a bypass method falls within the scope of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to explicitly limit the mechanism of jump-starting. A party could argue that "jump start a vehicle battery" is a general phrase in the art that refers to the overall act of starting a vehicle with a dead battery, regardless of the precise electrical pathway.
- Evidence for a Narrower Interpretation: The plain language requires an interaction with the "vehicle battery" itself. The specification describes connecting the device's clamps to the battery terminals. (’222 Patent, col. 32:60-66). This could support an interpretation that the claimed device must provide power to or through the vehicle's battery, not bypass it entirely.
VI. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on several key claim construction and technical disputes. The central questions for the court will likely be:
- A core issue will be one of definitional scope: can the term "a cover," as used in Claim 1, be construed to read on a product comprised of two physically separate and independently operable housings?
- A key technical question will be one of operational meaning: does the phrase "configured to jump start a vehicle battery" encompass devices that directly power a vehicle's starter motor while bypassing the vehicle's battery, or is its scope limited to devices that provide power to the battery itself?
- A final question relates to technological distinction: does a modern, multi-protocol "USB-C port" fall within the scope of the claimed "USB input connector," or do its additional functionalities and different structure render it a non-infringing alternative?