DCT

5:25-cv-01947

Ep Family Corp v. Cyclingdeal USA Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-01947, C.D. Cal., 07/29/2025
  • Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation with its principal place of business in the district, and a substantial part of the events giving rise to the claims occurred there.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its bicycle rack product does not infringe Defendant's patent and that the patent is invalid, following Defendant's filing of a patent infringement report with Amazon.
  • Technical Context: The dispute centers on the mechanical design of freestanding bicycle parking racks intended to provide stable, organized, and versatile storage for various bicycle types.
  • Key Procedural History: The complaint states that the action was precipitated by a notice from Amazon, issued on or around July 8, 2025, informing Plaintiff that Defendant had filed a report of patent infringement against Plaintiff's product. This notice allegedly created a justiciable controversy, compelling Plaintiff to file for declaratory relief.

Case Timeline

Date Event
2019-11-12 U.S. Patent No. 11,117,631 Priority Date
2021-09-14 U.S. Patent No. 11,117,631 Issue Date
2025-07-08 Plaintiff receives notice of infringement report from Amazon
2025-07-29 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,117,631 - “Bicycle Parking Rack”

  • Patent Identification: U.S. Patent No. 11,117,631, titled “Bicycle Parking Rack,” issued on September 14, 2021.

The Invention Explained

  • Problem Addressed: The patent background notes that bicycles parked using conventional kickstands can easily fall over. It also acknowledges existing bicycle parking racks but suggests a need for a design that can better restrict the bicycle wheel and accommodate tires of different sizes. (Compl. ¶1; ’631 Patent, col. 1:13-26).
  • The Patented Solution: The invention is a bicycle rack comprising a base, at least two U-shaped "restriction members" that hold the wheel upright, and at least two "support members" on which the tire rests. The patent describes specific geometries for these components: the restriction members include a "recessed area" to prevent contact with a bicycle's brake systems, and the support members feature a multi-width recess to fit different tire sizes (e.g., road vs. mountain bikes) and a non-planar structure to enhance their strength. (’631 Patent, Abstract; col. 2:40-63).
  • Technical Importance: The described design aims to create a more stable and versatile parking rack that is compatible with a wider range of bicycle designs and wheel dimensions. (’631 Patent, col. 2:2-5).

Key Claims at a Glance

  • The complaint identifies one independent claim (Claim 1) as being at issue (Compl. ¶8).
  • Independent Claim 1 requires, in part:
    • A base with two opposite sides, each having a "slot" on its top face.
    • At least two "restriction members" attached to the base, each having a specific five-part connection section (including first and second curved portions, first and second extension portions, and a third curved portion) that forms a "recessed area."
    • At least two "support members" with a bottom edge inserted into the slots of the base. Each support member must have a "first face and a second face" that are "not a continuous planar face" and include a "recessed zone" that forms a "protrusion" to reinforce its strength. The support members also have a "recess" to accommodate a bicycle wheel.
  • The complaint notes the patent also contains six dependent claims (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

  • The "Accused Product" is identified as Plaintiff's bicycle rack product sold on Amazon under ASIN B01NAWNYRK (Compl. ¶8).

Functionality and Market Context

  • The complaint does not provide a technical description of the Accused Product's features or operation. Its allegations are limited to identifying the product by its online retail listing and denying that it infringes the ’631 Patent (Compl. ¶¶8, 17).
    No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint is for a declaratory judgment of non-infringement and does not contain affirmative infringement allegations or a claim chart. It makes a broad assertion that "The Accused Product does not infringe, literally or under the doctrine of equivalents, any of the valid claims of the ’631 Patent" (Compl. ¶17). As such, a detailed claim-chart summary cannot be constructed from the pleading. The analysis below identifies potential points of contention based on the specific limitations of the asserted claim.

  • Identified Points of Contention:
    • Structural Questions: The primary dispute will likely concern whether the physical structure of the Accused Product meets the specific geometric limitations recited in Claim 1. Key questions include:
      • Does the Accused Product’s wheel support plate feature a "first face and a second face" that are "not a continuous planar face" and include a "recessed zone forming a protrusion" as claimed?
      • Do the upper tubes of the Accused Product contain a "recessed area" formed by the five specific structural elements (curved portions, extension portions) recited in Claim 1?
      • Does the base of the Accused Product connect to the support members via a "slot" into which a bottom edge is "inserted," as required by the claim?

V. Key Claim Terms for Construction

  • The Term: "not a continuous planar face"

    • Context and Importance: This negative limitation describes the structure of the support member. Its construction will be critical for determining whether the Accused Product's wheel support plate, which may have simple bends or ribs for strength, infringes.
    • Intrinsic Evidence for a Broader Interpretation: A party could argue the term's plain meaning covers any surface that is not perfectly flat.
    • Intrinsic Evidence for a Narrower Interpretation: The specification explicitly links this feature to a "recessed zone formed in the first face" which "simultaneously formed a protrusion from the second face so as to reinforce the strength of the support member" (’631 Patent, col. 3:27-34). A party could argue the term is limited to this specific reinforcing structure.

  • The Term: "recessed area"

    • Context and Importance: This term defines the shape of the upper restriction member, which is intended to provide clearance for bicycle components. Whether the Accused Product has this specific shape will be a core infringement question.
    • Intrinsic Evidence for a Broader Interpretation: The specification states the purpose is to "prevent the brake system or the quick-release of the bicycle from being hit" (’631 Patent, col. 2:62-64). This functional language may support a broader construction covering various shapes that achieve the same result.
    • Intrinsic Evidence for a Narrower Interpretation: Claim 1 defines this area as being formed by a specific combination of "the first extension portion, the second curved portion and the second extension portion" (’631 Patent, col. 4:12-14). This structural definition may support a narrower construction limited to the geometry shown in Figure 2A.

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaration that Plaintiff has not infringed "either directly or indirectly" (Compl. ¶19), but provides no specific facts related to indirect infringement, as its purpose is to deny liability rather than allege it.
  • Willful Infringement: This allegation is not applicable, as the complaint is for declaratory judgment of non-infringement and does not contain a claim for willfulness.

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

This case, initiated as a defensive declaratory judgment action, will likely center on two fundamental questions for the court:

  1. A core issue will be one of structural correspondence: Does the Plaintiff's accused bicycle rack embody the highly specific geometric limitations of Claim 1? The analysis will likely focus on whether the product includes a support member that is "not a continuous planar face" due to a "recessed zone forming a protrusion," and a restriction member with the claimed five-part "recessed area."
  2. A second key issue arises from the counterclaim for invalidity: Is Claim 1, with its combination of specific structural and geometric elements, non-obvious over the prior art? The court will have to determine whether the claimed features represent a patentable advance over existing bicycle rack designs.