DCT
8:25-cv-00452
Sichuan Qianli Beoka Medical Technology Inc v. Hyper Ice Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sichuan Qianli-Beoka Medical Technology Inc. (China)
- Defendant: Hyper Ice, Inc. (California) and Hyperice IP Subco, LLC (Delaware)
- Plaintiff’s Counsel: Martin J. Foley, a PLC; Law Office of Edward H. Rice, LLC
- Case Identification: 8:25-cv-00452, C.D. Cal., 03/07/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendants Hyper Ice, Inc. and Hyperice IP Subco, LLC both reside in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its massage gun products do not infringe, and that the claims are invalid, for three of Defendant’s patents related to percussive massage devices.
- Technical Context: The technology concerns handheld percussive massage guns, a popular category of consumer electronic devices used for muscle therapy and pain relief.
- Key Procedural History: The complaint notes that Defendant HYPERICE is involved in multiple other lawsuits in the same district involving two of the patents-in-suit (the ’482 and ’082 Patents). In that parallel litigation, a claim construction (Markman) hearing is scheduled for April 16, 2025, indicating that the meaning of key patent terms is already a point of active dispute.
Case Timeline
| Date | Event |
|---|---|
| 2013-07-01 | Earliest Priority Date for ’482, ’082, and ’826 Patents |
| 2024-01-02 | Issue Date for U.S. Patent No. 11,857,482 |
| 2024-03-26 | Issue Date for U.S. Patent No. 11,938,082 |
| 2024-11-05 | Issue Date for U.S. Patent No. 12,133,826 |
| 2025-02-21 | HYPERICE sends demand email to Renpho (Plaintiff's customer) |
| 2025-03-07 | HYPERICE's deadline for Renpho to enter a license agreement |
| 2025-03-07 | Complaint Filing Date |
| 2025-04-16 | Scheduled Markman hearing in related litigation |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,857,482 - "Massage Device Having Variable Stroke Length," issued Jan. 2, 2024
The Invention Explained
- Problem Addressed: The patent describes prior art massaging devices as being bulky, noisy, prone to overheating, and difficult to use for extended periods ( ’482 Patent, col. 1:26-30).
- The Patented Solution: The invention is a handheld percussive massager with an improved internal layout and, critically, a "quick-connect system" designed to allow for the rapid exchange of different massaging heads (’482 Patent, col. 2:5-9). The specification describes embodiments where magnets are used to hold the massaging head in place, allowing it to be easily attached and detached from the device's reciprocating piston (’482 Patent, col. 6:53-65).
- Technical Importance: By enabling users to easily swap massage heads, the invention allows for more versatile application of the device to different muscle groups or for different therapeutic purposes without significant interruption.
Key Claims at a Glance
- The complaint identifies independent claims 1, 32, and 34 as being asserted against Plaintiff’s products (Compl. ¶31).
- Independent Claim 1:
- a housing
- a piston with a substantially cylindrical bore
- a motor to reciprocate the piston
- a drive mechanism controlling a predetermined stroke length
- a quick-connect system comprising the piston's distal end and a massaging head, configured to secure the head by being "slid into the bore while the piston reciprocates"
- Independent Claim 32: A method of assembling a massager including positioning a motor and drive mechanism, and using a "quick release connector" to secure a massaging head "by sliding the first massaging head into the bore while the piston reciprocates."
- Independent Claim 34: A massager with a "quick release connector" where the massaging head has a "substantially cylindrical pocket to receive the quick release connector."
U.S. Patent No. 11,938,082 - "Massage Device Having Variable Stroke Length," issued Mar. 26, 2024
The Invention Explained
- Problem Addressed: This patent, from the same family as the ’482 Patent, addresses the same general deficiencies in prior art massagers, such as bulk and noise (’082 Patent, col. 1:29-33).
- The Patented Solution: The ’082 Patent also describes a handheld massager with a "quick-connect system," but the claims place particular emphasis on the ability to swap the heads while the device is operating. The claims describe a system where the massaging head can be "inserted into or removed from the bore while the piston reciprocates" (’082 Patent, col. 10:9-11). This suggests a system designed for on-the-fly interchangeability, which is supported by the specification's description of a magnetic connection that allows a tapered head to "easily slip into the opening" even while the piston is moving (’082 Patent, col. 7:8-12).
- Technical Importance: The ability to change heads without stopping the device could streamline the user experience, particularly for professional users like therapists who may need to switch applicators frequently during a session.
Key Claims at a Glance
- The complaint identifies independent claims 1 and 18 as being asserted against Plaintiff’s products (Compl. ¶35).
- Independent Claim 1:
- a housing
- a piston with a bore
- a motor to reciprocate the piston
- a drive mechanism controlling a predetermined stroke length
- a quick-connect system where the massaging head is "inserted into or removed from the bore while the piston reciprocates"
- Independent Claim 18: A method including providing a drive mechanism and a "quick-connect system" where the massaging head is "configured to be inserted into or removed from the bore while the piston reciprocates."
U.S. Patent No. 12,133,826 - "Massage Device with a Releasable Connection for a Massaging Head," issued Nov. 5, 2024
Technology Synopsis
As a member of the same patent family, the ’826 Patent is also directed to handheld percussive massagers. It similarly claims a "quick-connect system" that "allows a first massaging head to be connected or removed while the piston reciprocates" (’826 Patent, col. 10:16-20). The underlying technology, problem, and solution are consistent with the other asserted patents.
Asserted Claims
The complaint identifies independent claim 1 as being asserted (Compl. ¶38-39).
Accused Features
The complaint alleges that Plaintiff's products do not infringe because their "screw-mount head" mechanism is not a "quick-connect system" as required by the claims of the ’826 Patent (Compl. ¶¶ 46-47, 50).
III. The Accused Instrumentality
Product Identification
- The "Accused Beoka Massage Guns" sold by Plaintiff's customer, Renpho, on Amazon.com under specific ASINs (Compl. ¶¶ 2, 5).
Functionality and Market Context
- The relevant feature of the accused products is the mechanism for attaching the massage head to the device's piston. The complaint explicitly states that the Accused Beoka Massage Guns utilize a "screw-mount head," where the massage head has a threaded stem that screws into a threaded hole at the end of the piston (Compl. ¶28).
- The complaint includes two photographs illustrating this screw-mount mechanism, showing one massage head with external threads on its stem and another with a different shape but a similar threaded base (Compl. ¶28, p. 5).
IV. Analysis of Infringement Allegations
This is a declaratory judgment action in which the Plaintiff, Beoka, alleges its products do not infringe the Defendants' patents. The following tables summarize Beoka's primary non-infringement arguments.
’482 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Plaintiff's Allegation of Non-Infringement | Complaint Citation | Patent Citation |
|---|---|---|---|
| a quick-connect system ... configured to secure the first massaging head ... by a proximal end of the massaging head being slid into the bore while the piston reciprocates the predetermined stroke length at the first speed. | Plaintiff alleges its products do not have a "quick-connect system" because they use a "screw mount head." It further alleges this screw-mount mechanism is not "slid into the bore" but is screwed in, a fundamentally different attachment method. | ¶¶ 46-48 | col. 10:11-17 |
’082 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Plaintiff's Allegation of Non-Infringement | Complaint Citation | Patent Citation |
|---|---|---|---|
| a quick-connect system ... wherein the quick-connect system is configured to have a proximal end of the first massaging head inserted into or removed from the bore while the piston reciprocates the predetermined stroke length at the first speed. | Plaintiff alleges its products do not meet this limitation because their "screw mount head" is not a "quick-connect system" and cannot be inserted or removed while the piston is reciprocating, as screwing and unscrewing requires the device to be stationary. | ¶¶ 46-47, 49 | col. 10:6-11 |
Identified Points of Contention
- Scope Questions: The central dispute is whether the claim term "quick-connect system" (and the similar "quick release connector") can be construed broadly enough to read on the "screw-mount head" used by the accused products. The complaint argues they are not the same or equivalent (Compl. ¶47). This raises the question of whether a threaded connection, which requires multiple rotations to engage and disengage, falls within the ordinary meaning of "quick-connect."
- Technical Questions: A key functional question is whether the accused products' screw-mount mechanism can perform the actions required by the claims, specifically being "slid into the bore" or "inserted into or removed... while the piston reciprocates." The complaint's description and the visual evidence of a threaded stem suggest a rotational, rather than sliding, engagement that would be impractical, if not impossible, to perform while the piston is in motion (Compl. ¶28, p. 5).
V. Key Claim Terms for Construction
- The Term: "quick-connect system" / "quick release connector"
- Context and Importance: This term is the lynchpin of the non-infringement case. Plaintiff Beoka's entire argument rests on the premise that its screw-mount attachment is fundamentally different from the "quick-connect" system claimed in all three asserted patents. Practitioners may focus on this term because its construction will likely be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not point to any, and the patents do not appear to provide an explicit definition that would broaden the term to include conventional threaded fasteners. A party arguing for a broader scope might contend that "quick" is a relative term and that any system for connecting and disconnecting without separate tools could qualify.
- Evidence for a Narrower Interpretation: The specifications of the asserted patents provide strong evidence for a narrower meaning that excludes screw threads. The ’482 Patent describes the quick-connect system as using magnets to hold the head in place and shows this in Figures 6 and 6A (’482 Patent, col. 6:53-65). Furthermore, the claims in all three patents require functionality—such as being "slid into the bore" or removed "while the piston reciprocates"—that is consistent with a magnetic or detent-based system but inconsistent with a multi-turn screw mechanism (Compl. ¶¶ 32, 36, 39).
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement, as it is a declaratory judgment action focused on Plaintiff's non-infringement and the invalidity of the asserted patents.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case appears to hinge on three primary questions for the court:
A core issue will be one of definitional scope: How will the court construe the term "quick-connect system"? Can this term, which the patent specification illustrates with a magnetic embodiment, be interpreted to cover the conventional multi-turn "screw-mount head" used by the accused products?
A key dispute will be one of functional capability: Even if the term were construed broadly, does the accused screw-mount mechanism perform the specific functions recited in the claims, such as being "slid" into place or being connected/removed "while the piston reciprocates"?
An equally important question will be one of validity: Are the claims of the asserted patents, particularly the limitations directed to the "quick-connect" feature, valid in light of the extensive list of prior art references cited by the Plaintiff?