DCT
8:24-cv-01814
Dongguanshi Zhibai Dianzi Shangwu Youxiangongsi v. Wang
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DONGGUANSHI ZHIBAI DIANZI SHANGWU YOUXIANGONGSI (A.K.A. KNOW WHITE) (China)
- Defendant: Lili Wang (China)
- Plaintiff’s Counsel: Rhema Law Group, P.C.
- Case Identification: 8:24-cv-01814, C.D. Cal., 08/16/2024
- Venue Allegations: Venue is asserted on the basis that both parties are foreign entities that have purposefully availed themselves of the district by marketing and conducting business there, and that the defendant has engaged in enforcement activities within the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its folding chair product does not infringe Defendant’s patent and that the patent is invalid, in response to Defendant’s enforcement actions on the Amazon e-commerce platform.
- Technical Context: The technology concerns portable, collapsible folding chairs, a mature product category in the consumer outdoor and recreational goods market.
- Key Procedural History: The dispute originated with an infringement complaint and takedown notice filed by Defendant with Amazon around May 7, 2024, leading to the removal of Plaintiff's product listing. The parties subsequently participated in Amazon's Neutral Patent Evaluation (NPE) program, which resulted in a non-binding decision on August 2, 2024, that Plaintiff's product was "likely to infringe claim 1." The complaint notes that the NPE process does not consider invalidity arguments based on prior art.
Case Timeline
| Date | Event |
|---|---|
| 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 the accused product on Amazon |
| 2024-05-07 | Defendant files infringement complaint/takedown with Amazon |
| 2024-08-02 | Amazon NPE finds likely infringement of claim 1 |
| 2024-08-16 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,439,238 - "FOLDING CHAIR"
- Patent Identification: U.S. Patent No. 11,439,238, “FOLDING CHAIR,” issued September 13, 2022.
The Invention Explained
- Problem Addressed: The patent identifies that traditional folding chairs can have a "complex structure and is cumbersome to operate, which seriously affects the experience of users" (’238 Patent, col. 1:20-23).
- The Patented Solution: The invention is a folding chair built around a central hub connecting an upper assembly (arms) and a lower assembly (legs). The solution centers on the interaction between "retractable" arms, a "stop portion" on the upper block that limits the rotation of the arms, and a flexible seat that becomes taut when the arms are extended. This combination is described as creating a stable seating structure that prevents the upper assembly from overturning, while also allowing the chair to be easily collapsed once the arms are shortened and the seat is relaxed (’238 Patent, col. 2:20-29; col. 3:54-65).
- Technical Importance: The design purports to offer a folding chair with a "simple structure and easy operation" compared to prior designs (’238 Patent, col. 1:28-29).
Key Claims at a Glance
- The complaint identifies independent claim 1 as the focus of the dispute (Compl. ¶10).
- The essential elements of independent claim 1 are:
- a lower assembly with a lower block and three or more legs pivotally connected to it;
- an upper assembly with an upper block and three or more arms pivotally connected to it;
- a middle assembly connecting the upper and lower assemblies;
- a flexible seat with end portions arranged at the ends of the arms;
- wherein the upper block has a stop portion to limit the rotation angle of the arms; and
- wherein the arms are retractable, and the flexible seat is in a relaxed state when the arms are retracted and a tight state when the arms are extended.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Plaintiff's folding chair, sold on Amazon under ASIN# B0D12FFHGX (Compl. ¶15). The product brand appears to be "RAYNESYS" (Compl. p. 4).
Functionality and Market Context
- The product is a portable folding chair designed for outdoor use, sold through the Amazon e-commerce platform (Compl. ¶¶3, 8). A representative picture of the plaintiff's folding chair shows a central hub with radiating legs and upper arms supporting a fabric seat, with an inset image highlighting a 360-degree rotation feature (Compl. p. 4). The complaint alleges that this type of product generates approximately $3,000 in daily revenue for the Plaintiff (Compl. ¶19).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement and does not contain a detailed infringement claim chart. The following table summarizes the elements of the asserted claim and the corresponding features of Plaintiff's product, based on the complaint's description and general denial of infringement (Compl. ¶25). Plaintiff contends that its product does not meet one or more of these limitations, asserting the Amazon Evaluator "failed to properly construe" them (Compl. ¶16).
'238 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a lower assembly comprising a lower block and three or more legs pivotally connected to the lower block; | The product features a lower assembly with legs connected to a central block or hub (Compl. p. 4). | ¶3, p. 4 | col. 4:46-48 |
| an upper assembly comprising an upper block and three or more arms pivotally connected to the upper block; | The product features an upper assembly with arms connected to a central block or hub to support a seat (Compl. p. 4). | ¶3, p. 4 | col. 4:49-51 |
| a middle assembly connecting the upper assembly and the lower assembly; | The product features a central connection between the upper and lower assemblies that allows for 360-degree rotation (Compl. p. 4). | ¶3, p. 4 | col. 4:52-53 |
| a flexible seat comprising the same number of end portions as the number of the arms... | The product utilizes a flexible fabric seat that attaches to the upper arms (Compl. p. 4). | ¶3, p. 4 | col. 4:54-57 |
| wherein the upper block is provided with a stop portion to limit the rotation angle of the arms, | The complaint does not provide specific details on the structure of its upper block or whether it contains a "stop portion." | -- | col. 4:58-60 |
| and wherein the arms are retractable, the flexible seat is arranged to be in a relaxed state... and in a tight state... | The complaint does not describe the mechanism of its arms or use the term "retractable," creating a potential point of dispute. The functionality relies on the seat being attached to the arms (Compl. p. 4). | p. 4 | col. 4:61-64 |
- Identified Points of Contention:
- Scope Questions: The primary dispute appears to center on claim construction (Compl. ¶16). A key question will be whether the plaintiff's chair includes a "stop portion to limit the rotation angle of the arms" and "retractable" arms as those terms are defined by the patent.
- Technical Questions: What is the specific mechanism of the arms on the plaintiff's chair? The complaint does not specify if they are telescoping, folding, or otherwise "retractable" in a manner consistent with the patent's disclosure, which describes a process of "shorten[ing] the arm first" to relax the seat (’238 Patent, col. 2:26-27). Evidence will be needed to determine if the plaintiff's product includes a structure that performs the function of the claimed "stop portion."
V. Key Claim Terms for Construction
The Term: "retractable"
Context and Importance: This term is critical to both infringement and validity. The patent links the "retractable" nature of the arms to the seat transitioning between a "relaxed state" and a "tight state," which is a core functional element of the invention (’238 Patent, col. 4:61-64). The plaintiff’s non-infringement case may depend on arguing its arms are not "retractable" in the claimed sense.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined, which could support an argument for its plain and ordinary meaning, potentially covering any method of shortening or collapsing the arms.
- Evidence for a Narrower Interpretation: The specification describes a specific sequence: "When the user wants to retract the folding chair 100, first shorten the four arms 32, and then the flexible seat 40 is released" (’238 Patent, col. 3:54-56). This could be used to argue "retractable" requires a specific length-adjusting mechanism (e.g., telescoping) rather than merely folding.
The Term: "stop portion"
Context and Importance: This limitation defines a specific functional component on the "upper block" that prevents the chair from overturning by limiting arm rotation (’238 Patent, col. 3:49-54). Practitioners may focus on this term because demonstrating the absence of such a structure in the accused product is a direct path to a non-infringement finding.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is functional: "to limit the rotation angle of the arms." This could be argued to cover any structure on the upper block that achieves this result.
- Evidence for a Narrower Interpretation: The patent discloses a specific embodiment with "two front stop 311 and two rear stop 312" (’238 Patent, col. 3:32-33; Fig. 3). A defendant could argue the term should be limited to a structure analogous to this disclosed embodiment, rather than any incidental feature that might limit rotation.
VI. Other Allegations
The complaint is for declaratory judgment and does not allege infringement. Instead, it includes counts for business torts against the patent holder.
- Tortious Interference with Economic Relations: Plaintiff alleges that Defendant intentionally disrupted its business relationships with Amazon and its customers by filing a bad-faith infringement notice with the specific intent to have Plaintiff's product listing removed (Compl. ¶¶29-31).
- Unfair Competition: Plaintiff alleges that Defendant’s act of "knowingly enforcing its '238 Patent against... a non-infringing product constitutes unfair competition" under California state law (Compl. ¶36). The basis for these claims is the allegation that the defendant knew or should have known the patent was invalid and/or not infringed when it initiated the takedown action on Amazon (Compl. ¶¶13, 21).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of validity: can the Defendant’s patent survive the challenge posed by the prior art references cited by the Plaintiff (e.g., Engi Leisure, Hoffman, Stump)? The complaint provides a detailed chart asserting that these references anticipate or render obvious every element of claim 1 (Compl. ¶¶41-43).
- A second core issue will be one of claim construction: can the term "retractable", as used in the patent, be construed to read on the arm mechanism of the Plaintiff's chair? The outcome of the non-infringement claim will likely hinge on whether "retractable" requires a specific telescoping function or can encompass a broader range of collapsing mechanisms.
- Finally, a key question for the business tort claims will be one of objective baselessness: can the Plaintiff prove that the Defendant’s enforcement action through Amazon’s NPE process was so lacking in merit that no reasonable litigant could have expected success, which is the high standard required to establish bad-faith enforcement.