DCT

2:24-cv-07020

Dongguanshi Zhibai Dianzi Shangwu Youxiangongsi v. Lili Wang

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-07020, C.D. Cal., 08/16/2024
  • Venue Allegations: Venue is alleged to be proper on the basis that both parties are foreign entities that market and conduct business in the district.
  • Core Dispute: Plaintiff, a product seller, seeks a declaratory judgment that its folding chair product does not infringe Defendant's patent and that the patent is invalid, following Defendant’s successful use of Amazon's infringement reporting process to have Plaintiff's product removed from sale.
  • Technical Context: The technology concerns collapsible folding chairs, a mature product category in the consumer market for outdoor and recreational goods.
  • Key Procedural History: The dispute began with the Defendant filing an infringement complaint with Amazon, which led to the takedown of the Plaintiff's product listing. The parties then engaged in Amazon's Neutral Patent Evaluation (NPE) process, which resulted in a non-binding finding that infringement of claim 1 was likely. The complaint notes that the NPE process does not consider invalidity defenses based on prior art, which the Plaintiff now raises in this court action.

Case Timeline

Date Event
2015-06-02 Foreign publication date of Engi Leisure prior art reference
2022-04-25 Priority Date for U.S. Patent No. 11,439,238
2022-09-13 U.S. Patent No. 11,439,238 Issues
2024-04-06 Plaintiff begins selling accused product on Amazon
2024-05-07 Defendant files infringement complaint with Amazon
2024-05-28 Plaintiff's counsel sends non-infringement/invalidity letter
2024-06-25 Parties begin participation in Amazon NPE process
2024-08-02 Amazon Neutral Evaluator issues non-binding decision
2024-08-16 Complaint for Declaratory Judgment filed

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

  • Patent Identification: U.S. Patent No. 11,439,238, "FOLDING CHAIR," issued September 13, 2022.
  • The Invention Explained:
    • Problem Addressed: The patent's background section identifies that "traditional folding chair has complex structure and is cumbersome to operate," which negatively impacts the user experience (U.S. Patent No. 11,439,238, col. 1:20-23).
    • The Patented Solution: To solve this, the patent discloses a folding chair with a "simple structure and easy operation" comprising upper and lower assemblies connected by a middle hub (’238 Patent, col. 1:30-32). The key features are "retractable" arms that can be shortened, and a "stop portion" on the upper hub that limits the rotational angle of the arms (’238 Patent, Abstract). This configuration is designed to allow the flexible seat to be in a "relaxed state" when the arms are retracted for easy folding, and a "tight state" for stability when the arms are extended for use, preventing the chair from overturning (’238 Patent, col. 3:49-54).
    • Technical Importance: The invention purports to improve portability and ease of use while maintaining the structural stability required for a functional chair (’238 Patent, col. 3:63-65).
  • Key Claims at a Glance:
    • The complaint identifies independent claim 1 as the focus of the pre-suit dispute (Compl. ¶13).
    • The essential elements of independent claim 1 are:
      • A lower assembly with a lower block and pivotally connected legs.
      • An upper assembly with an upper block and pivotally connected arms.
      • A middle assembly connecting the upper and lower assemblies.
      • A flexible seat with end portions arranged at the end of each arm.
      • A "stop portion" on the upper block to limit the rotation angle of the arms.
      • The arms are "retractable," allowing the flexible seat to be in a "relaxed state" when the arms are retracted and a "tight state" when they are extended.
    • The complaint seeks a declaration of non-infringement of "any claims of the ’238 Patent" (Compl. ¶25).

III. The Accused Instrumentality

  • Product Identification: Plaintiff’s folding chair, sold on Amazon under the brand name "RAYNESYS" and identified by ASIN# B0D12FFHGX (Compl. ¶10, p. 4).
  • Functionality and Market Context: The complaint describes the product as a "folding chair product" and provides a representative picture showing a portable chair with a fabric seat supported by a frame of legs and arms that meet at a central hub (Compl. ¶3, p. 4). A graphic overlay on one of the images indicates a "360°" rotational capability (Compl. p. 4). Plaintiff alleges that the delisting of this product from Amazon results in lost daily revenue between $2,500 and $5,000, suggesting it is a commercially significant product for the company (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement and therefore does not contain a detailed, element-by-element infringement analysis or claim chart. It makes the conclusory allegation that its product "does not infringe any claims of the ’238 Patent" (Compl. ¶25). The complaint alleges that the Amazon Neutral Evaluator's contrary finding was based on an improper construction of claim 1's limitations (Compl. ¶16).

  • Identified Points of Contention:
    • Scope Questions: A central dispute may involve the proper construction of the term "retractable" as applied to the chair arms. The question for the court will be whether this term requires a specific mechanism, such as telescoping arms that shorten in length as suggested by the patent's description (e.g., "shorten the arm first," col. 3:54-55), or if it can be read more broadly to cover other folding or collapsing configurations.
    • Technical Questions: The infringement analysis will likely require a factual determination of whether the accused product's structure includes a "stop portion" on its "upper block" that performs the function of limiting the arm's rotation, as claimed. The complaint provides a visual of the assembled accused product but does not include detailed views of its hub mechanism (Compl. p. 4). This image shows a folding chair of a common design, which raises the question of what evidence will be presented to show the presence or absence of this specific claimed feature.

V. Key Claim Terms for Construction

  • The Term: "retractable"

    • Context and Importance: This term is critical because it defines a key functional requirement for collapsing the chair as claimed. Whether the accused product's arms meet this limitation will be a primary issue. Practitioners may focus on this term because its definition—whether it means telescoping, folding, or something else—could be dispositive of infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "retractable," which could support an argument for applying its plain and ordinary meaning, potentially encompassing any method of drawing the arms in or back.
      • Evidence for a Narrower Interpretation: The specification repeatedly describes a process of actively shortening the arms, stating, "When retracting the folding chair, shorten the arm first" and "first shorten the four arms 32" (’238 Patent, col. 2:26-27, col. 3:54-55). This language suggests a mechanism that reduces the physical length of the arms, such as telescoping, rather than merely folding them.

  • The Term: "stop portion"

    • Context and Importance: This feature is described as preventing the chair's upper assembly from overturning, making it essential to the invention's claimed stability. The presence or absence of an equivalent structure in the accused product will be a key factual dispute.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term itself is functional, which could support a construction that covers any structure on the upper block that serves to "limit the rotation angle of the arms" (’238 Patent, cl. 1).
      • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the "stop portion includes two front stop 311 and two rear stop 312" (’238 Patent, col. 3:34-37). An argument could be made that the claim should be limited to such distinct, physical blocking structures as depicted in Figure 3.

VI. Other Allegations

The complaint is for a declaratory judgment of non-infringement and patent invalidity. As such, it does not contain allegations of indirect or willful infringement against the defendant. The complaint does include counts for tortious interference and unfair competition based on the Defendant's enforcement activities on the Amazon platform (Compl. ¶¶28-38).

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

  • A core issue will be one of definitional scope: can the claim term "retractable", described in the patent in the context of "shortening" the arms, be construed to read on the mechanism used in the accused chair? The answer will likely turn on whether the court adopts a narrow, length-based definition or a broader, more functional one.
  • The case will also present a central question of invalidity: the complaint places significant emphasis on prior art references that allegedly anticipate or render obvious the invention of the ’238 Patent (Compl. ¶¶41-43). A key focus for the court will be to assess this invalidity challenge, an issue the complaint notes was outside the scope of the prior Amazon NPE proceeding.
  • Finally, a key evidentiary question will be one of structural presence: does the accused product, as a matter of fact, contain a "stop portion" on its upper block that limits arm rotation as required by claim 1? The resolution of this will depend on detailed evidence of the product's construction that is not yet available in the complaint.