DCT
1:24-cv-01237
TIT Intl Ltd v. Sun Pleasure Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: TIT International Limited (Hong Kong)
- Defendant: Sun Pleasure Co. Limited (Hong Kong)
- Plaintiff’s Counsel: Rimon, P.C.
- Case Identification: 1:24-cv-01237, D. Del., 11/08/2024
- Venue Allegations: Plaintiff asserts that venue is proper in the District of Delaware because Defendant, a non-U.S. resident, may be sued in any judicial district. Personal jurisdiction is alleged based on Defendant’s submission of an infringement complaint to Amazon.com, which sought to remove Plaintiff's products from sale to customers in Delaware.
- Core Dispute: Plaintiff seeks a declaratory judgment that its air mattresses do not infringe Defendant’s patent related to inflatable mattress assembly designs.
- Technical Context: The technology concerns the structural design of inflatable air mattresses, specifically those incorporating a peripheral frame to mimic the appearance and feel of a traditional pillow-top mattress.
- Key Procedural History: This action was precipitated by Defendant's patent infringement complaint filed through the Amazon Patent Evaluation Procedure (APEX), which threatened the removal of Plaintiff’s products from Amazon.com. The complaint notes a prior, separate APEX proceeding where an evaluator concluded that similar products were "unlikely" to infringe the patent-in-suit on the same grounds asserted here. Separately, the patent-in-suit, U.S. Patent No. 7,353,555, was the subject of an Inter Partes Review (IPR2021-00080), which concluded with a certificate confirming the patentability of claims 1-9.
Case Timeline
| Date | Event |
|---|---|
| 2005-12-07 | ’555 Patent Priority Date |
| 2008-04-08 | ’555 Patent Issue Date |
| 2020-10-16 | IPR (IPR2021-00080) against ’555 Patent filed |
| 2024-10-22 | Amazon sends notice of infringement complaint to Plaintiff |
| 2024-11-08 | Complaint for Declaratory Judgment filed |
| 2024-11-21 | IPR Certificate confirming claims 1-9 of ’555 Patent issued |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,353,555 - "Inflatable Mattress Assembly"
- Patent Identification: U.S. Patent No. 7,353,555, "Inflatable Mattress Assembly", issued April 8, 2008.
The Invention Explained
- Problem Addressed: The patent addresses the problem of prior inflatable mattresses, which attempted to mimic two-layered, pillow-top mattresses but were often uncomfortable or unattractive due to deformation and creasing of the top peripheral frame ('555 Patent, col. 1:12-24).
- The Patented Solution: The invention is an inflatable mattress with a main body and a distinct "peripheral frame" that creates a stable, pillow-top-like border. This frame is secured to the mattress body along two separate seams—an upper seam and a lower seam—which prevents it from deforming or creasing when a user lies on it ('555 Patent, col. 2:58-63). A key component is an "internal wall" that connects the top panel of the mattress to the side panel, forming part of the peripheral frame structure ('555 Patent, col. 2:55-58; Fig. 3). This internal wall is designed to be in "substantial pressure equilibrium" with the main mattress body, ensuring stability ('555 Patent, col. 3:7-11).
- Technical Importance: The design provides a method to construct an inflatable mattress that more accurately replicates the aesthetic and functional characteristics of a traditional, high-quality spring mattress with a pillow-top ('555 Patent, col. 1:25-29).
Key Claims at a Glance
- The complaint identifies independent claims 1 and 6 as being at issue (Compl. ¶18).
- Independent Claim 1 recites the following essential elements:
- An inflatable mattress with top and bottom panels and a peripheral side panel.
- A peripheral frame forming an upper tubular periphery of the mattress.
- An internal wall interconnecting the top panel to the side panel, located within the interior volume of the mattress.
- The internal wall is connected to the side panel along a first peripheral seam and to the top panel along a second peripheral seam.
- An external wall interconnects the first and second seams.
- The internal wall includes a fluid passage therethrough, is in substantial pressure equilibrium with the interior volume, and has a substantially linear cross-section between the seams.
- The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement of "any claim of the '555 patent" (Compl. ¶24).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Accused Products" as specific air mattresses sold under the “Airefina,” “NatraCalm,” and “iDOO” brands, identified by four Amazon Standard Identification Numbers (ASINs) (Compl. ¶5). The complaint also extends its request for declaratory judgment to "Similar Products" sold by the Plaintiff (Compl. ¶8).
Functionality and Market Context
- The complaint describes the Accused Products as air mattresses with built-in pumps sold through Amazon.com (Compl. ¶5). It alleges sales of these products to customers throughout the United States, including in Delaware (Compl. ¶9). The complaint does not provide sufficient detail for analysis of the specific internal construction or technical operation of the Accused Products, focusing instead on what they allegedly lack.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's central argument for why its products do not infringe, as detailed in its complaint.
’555 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged (Non-)Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| said internal wall of said peripheral frame includes a fluid passage therethrough, said internal wall is in substantial pressure equilibrium within said interior volume, and said internal wall has a substantially linear cross-section between said first and second seams. | The complaint alleges that neither the Accused Products nor the Similar Products contain an "internal wall" with a "fluid passage" as required by the patent claims. | ¶20, ¶21 | col. 4:51-58 |
No probative visual evidence provided in complaint.
- Identified Points of Contention:
- Technical Question: The primary dispute appears to be factual: do the accused mattresses, when deconstructed and analyzed, contain an internal structure that meets the claim description of an "internal wall" with a "fluid passage"? The complaint's position is that they do not (Compl. ¶21).
- Scope Questions: The case will involve defining the scope of the claimed "internal wall." A key question is whether any internal tether or baffle that connects the top and side panels and allows for air movement could be construed as the claimed "internal wall," or if the term requires a specific structure with a discrete "fluid passage" and "linear cross-section" as depicted in the patent's figures.
V. Key Claim Terms for Construction
- The Term: "internal wall ... includes a fluid passage therethrough"
- Context and Importance: This term appears to be the lynchpin of the non-infringement argument. The Plaintiff’s complaint for declaratory judgment is predicated on the assertion that its products lack this specific feature (Compl. ¶20-21). Furthermore, the complaint alleges that a prior Amazon APEX evaluation found non-infringement based on the absence of this exact limitation, suggesting it has been a point of contention previously (Compl. ¶25). Practitioners may focus on this term because its construction could be dispositive of the entire infringement question.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function of the passage as ensuring the "internal wall 30 is in substantial pressure equilibrium within the interior volume 6 of the mattress" ('555 Patent, col. 3:9-11). A party could argue that any structure, including a porous membrane or a series of tethers with gaps, that achieves this pressure equalization meets the "fluid passage" limitation, even without a distinct, single hole.
- Evidence for a Narrower Interpretation: The patent figures, particularly Figure 3, show the internal wall (30) as a solid, continuous sheet of material connecting the top and side panels at a specific angle ('555 Patent, Fig. 3). The term "passage therethrough" could be interpreted to require a discrete, defined opening, not merely inherent material porosity or gaps between separate structural elements. The description of the internal wall having a "substantially linear cross-section" may also support a narrower interpretation requiring a specific planar geometry ('555 Patent, col. 4:56-58).
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration that Plaintiff does not indirectly infringe any claim of the patent, but it does not plead any specific facts related to inducement or contributory infringement beyond a general denial (Compl., Prayer for Relief ¶c).
- Willful Infringement: This being a declaratory judgment action, willfulness is not alleged against the Plaintiff. However, the Plaintiff does allege that this is an "exceptional case" under 35 U.S.C. § 285, which would entitle it to attorneys' fees (Compl. ¶25). The basis for this allegation is Defendant's pursuit of infringement claims via Amazon after a prior, non-binding APEX evaluation on similar products allegedly found that Defendant was "unlikely to be able to prove" infringement of the same claim limitations (Compl. ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: Can the phrase "internal wall... includes a fluid passage therethrough" be satisfied by any internal structure that allows for pressure equalization between the peripheral frame and the main mattress body, or does it require a specific, geometrically defined component with a discrete opening as arguably suggested by the patent's figures and description?
- A key evidentiary question will be one of technical fact: What is the actual internal construction of the "Airefina," "NatraCalm," and "iDOO" air mattresses? The case will likely depend on expert testimony and product teardowns to determine if any component of the accused products meets the construed definition of the disputed claim limitations.
- A significant procedural question will be the relevance of prior proceedings: What legal weight, if any, will the court assign to the non-precedential Amazon APEX evaluation that previously found non-infringement? While not binding, Plaintiff will likely use it to argue that Defendant’s continued assertions of infringement are objectively baseless, supporting its request for attorneys' fees. This is contrasted with the patent having survived a separate IPR challenge, which strengthens its presumption of validity and may frame the dispute as a good-faith disagreement over infringement.