Zhejiang Zhengte Co Ltd v. Ningbo Youren Intl Trade Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Zhejiang Zhengte Co. Ltd. (China)
  • Defendant: Ningbo Youren International Trade Co., Ltd. and Yiwu Youchang E Commerce Co., Ltd. (China)
  • Plaintiff’s Counsel: One LLP
• Case Identification: 2:24-cv-00535, C.D. Cal., 01/19/2024
• Venue Allegations: Plaintiff alleges venue is proper in the district because Defendants are foreign companies, which may be sued in any judicial district under the general venue statute.
• Core Dispute: Plaintiff alleges that Defendants’ outdoor louvered pergola infringes a patent related to a specific method of assembly and an integrated rainwater drainage system.
• Technical Context: The technology relates to the field of prefabricated outdoor structures, specifically adjustable pergolas designed for consumer assembly and all-weather use.
• Key Procedural History: The complaint alleges that Plaintiff’s commercial products are marked with the asserted patent number, which may be relevant to claims of willful infringement.

Case Timeline

Date	Event
2020-05-28	Earliest Priority Date for '187 Patent
2023-04-11	U.S. Patent No. 11,624,187 Issues
2024-01-19	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,624,187 - "Pergola," issued April 11, 2023

The Invention Explained

• Problem Addressed: The patent background describes a need for a multi-functional, easy-to-assemble pergola that improves upon existing designs. The complaint frames the problem as a need for a pergola that can be "easily and quickly assembled by purchasers using only simple tools" and includes an effective "internal gutter system" for water drainage (Compl. ¶12).
• The Patented Solution: The invention is a pergola structure featuring two primary innovations. First, it uses a unique assembly method where cross beams are attached to corner posts by sliding "securing bars" located at the beam ends into "internal beam securing slots" on the posts (Compl. ¶14). This creates a "clean and fastener-free outer surface" (’187 Patent, Fig. 2Q; Compl. ¶14). Second, it incorporates an integrated drainage system where rainwater is collected in gutters within the cross beams and channeled down through internal conduits inside the hollow corner posts, exiting at the bottom (Compl. ¶15; ’187 Patent, Fig. 3S).
• Technical Importance: The described solution aims to provide a pergola that is both aesthetically clean, by hiding assembly fasteners, and functionally superior, by managing rainwater internally to prevent staining and uncontrolled runoff (Compl. ¶12, ¶14).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶22).
• The essential elements of Claim 1 include:
  • A pergola with four corner posts and four beams.
  • Each corner post includes an "internal beam securing mechanism" and an "internal conduit."
  • Each beam has an "internal gutter" and a "securing bar" at each end.
  • The beams attach to the posts by "slidably attaching" the securing bar into a securing slot on the post.
  • The interconnected gutters and conduits form a system to channel and release captured rainwater.
  • The assembled structure has an "offset" between the outer surface of the beams and the outer surface of the corner posts.
  • A plurality of louvers is connected across the beams to form a cover.

III. The Accused Instrumentality

Product Identification

The "ONLYCTR Outdoor Louvered Pergola" and any other louvered pergolas sold by Defendants with "substantially the same construction" (Compl. ¶16).

Functionality and Market Context

The complaint alleges the accused product is an outdoor louvered pergola that incorporates a "Built-in Drainage System" (Compl. p. 7, left photo). Plaintiff asserts that the accused product is an "obvious knock-off" of its own patented pergola, alleging it directly copies the patented features (Compl. ¶17-18). The complaint includes a side-by-side photographic comparison of the accused product and Plaintiff’s patented product to support its claim of substantial similarity (Compl. p. 7). This image shows the accused product's drainage system and overall appearance, which the plaintiff alleges is infringing (Compl. p. 7).

IV. Analysis of Infringement Allegations

The complaint references an attached claim chart in Exhibit A to detail its infringement allegations; however, this exhibit was not included with the filed complaint (Compl. ¶16, ¶22). In lieu of a chart, the narrative infringement theory can be summarized.

Plaintiff alleges that the "ONLYCTR Outdoor Louvered Pergola" infringes at least Claim 1 of the ’187 Patent (Compl. ¶22). The core of the infringement allegation is that the accused product is a "blatant knock-off" that was "directly copied" from Plaintiff's patented pergola and therefore possesses the key features claimed in the patent (Compl. ¶18, ¶23). Specifically, the complaint points to the accused product having the same unique assembly system and internal drainage system as the invention (Compl. ¶14-16). The complaint provides visual evidence from the accused product's marketing, such as an image highlighting its "Built-in Drainage System," and technical diagrams from the patent, such as one showing the "cross beam/post offset," to illustrate the alleged infringement (Compl. p. 6, p. 7).

Identified Points of Contention

• Scope Questions: A central dispute may arise over the claim term "offset." The claim requires "an offset with the outer surface of each corner post." The interpretation of what constitutes a legally sufficient "offset"—for example, whether any non-coplanar alignment suffices or if the specific recessed configuration shown in the patent's figures is required—will be critical to the infringement analysis.
• Technical Questions: The complaint's allegations are based on external visual similarity and marketing materials. A key technical question will be whether the internal construction of the accused product actually meets the claim limitations. Evidence will be required to determine if the accused product's components function as a "slidably attaching" "securing bar" and "slot," and if its "internal conduit" follows the specific water drainage path described in the claim.

V. Key Claim Terms for Construction

• The Term: "offset with the outer surface of each corner post" (Claim 1)

  • Context and Importance: This term defines a key structural and aesthetic relationship between the pergola’s primary components. The infringement determination may hinge on whether the accused product's beam-to-post alignment falls within the court's construction of this term. Practitioners may focus on this term because the word "offset" appears in the claim but not explicitly in the patent's detailed description, which could create ambiguity.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue for the plain and ordinary meaning, suggesting that any configuration where the outer surfaces of the beam and post are not co-planar meets the limitation.
    • Evidence for a Narrower Interpretation: The patent figures, such as Figure 2Q (reproduced in Compl. p. 6), consistently depict a specific configuration where the cross beam is recessed inward from the outer face of the corner post. A party could argue the term should be limited to this disclosed embodiment, especially since the complaint links the offset to the specific assembly method (Compl. ¶14).

• The Term: "internal beam securing mechanism" (Claim 1)

  • Context and Importance: This phrase describes the core connection technology. The infringement analysis will depend on whether the defendant's method for joining beams to posts is covered by the definition of this mechanism.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff may argue the term should cover any internal connection system that secures the beam to the post, consistent with the overall goals of the invention.
    • Evidence for a Narrower Interpretation: The specification describes a specific structure comprising "gutter-beam-securing bars" (125) that slide into "gutter-beam-securing-bar slots" (135) (’187 Patent, col. 38:5-11). A defendant could argue that the term should be limited to this specific bar-and-slot structure, as it is the primary and enabling embodiment disclosed.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendants' infringement has been willful (Compl. ¶23; Prayer for Relief ¶a). This allegation is based on two premises: first, that Plaintiff’s commercial products are properly marked with the ’187 Patent number, providing constructive notice; and second, on "information and belief," that Defendants "secured a commercial copy of Plaintiff’s patented pergola and thereafter directly copied this pergola," suggesting actual knowledge and intent (Compl. ¶23).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of claim construction: how will the court define the term "offset"? Whether it is given a broad, plain-meaning interpretation or is limited to the specific recessed configuration shown in the patent's figures will be a dispositive question for infringement.
• A key evidentiary question will be one of structural identity: beyond the visual similarity alleged in the complaint, what evidence will emerge from discovery to prove or disprove that the internal assembly components and water drainage pathways of the accused product function in the specific manner required by Claim 1?
• The case may also turn on a question of actionable copying: can the plaintiff substantiate its allegation that the Defendants "directly copied" a marked product? Evidence supporting this claim would significantly strengthen the case for willfulness and could influence the broader infringement narrative.