DCT
1:25-cv-01471
Dongyingboruidianzikejiyouxiangongsi v. Minimaxit Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongyingboruidianzikejiyouxiangongsi (China)
- Defendant: Minimaxit Ltd. (Israel)
- Plaintiff’s Counsel: Rimon, P.C.
- Case Identification: 1:25-cv-01471, D. Del., 12/05/2025
- Venue Allegations: Plaintiff alleges venue is proper in any judicial district because the defendant, an Israeli company, is not a resident of the United States.
- Core Dispute: Plaintiff seeks a declaratory judgment that its collapsible stools do not infringe Defendant's patent related to foldable chairs, and that the patent is invalid.
- Technical Context: The technology at issue involves telescopic, height-adjustable, and collapsible stools designed for portability and compact storage.
- Key Procedural History: The complaint was filed in response to an email from Amazon, prompted by a notice from Defendant, alleging that Plaintiff's products infringe the patent-in-suit and threatening removal of the products from Amazon's marketplace. This notice forms the basis for the "justiciable controversy" required for a declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2018-05-13 | ’427 Patent Priority Date |
| 2020-12-01 | ’427 Patent Issue Date |
| 2025-11-17 | Amazon infringement notice received by Plaintiff |
| 2025-12-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,849,427 - "Foldable Chair and Foldable Table"
The patent-in-suit is U.S. Patent No. 10,849,427, issued December 1, 2020 (the "’427 Patent").
The Invention Explained
- Problem Addressed: The patent operates in the field of portable furniture and addresses the need for a chair or stool that is stable, height-adjustable, and can be collapsed into a highly compact form for transport and storage (’427 Patent, col. 1:5-7; col. 3:20-25).
- The Patented Solution: The invention is a telescopic stool constructed from a plurality of rings with varying diameters that nest within one another when collapsed (’427 Patent, col. 1:11-21). To achieve a desired height, the user extends the rings, and a "locking arrangement" on each ring engages with an adjacent ring to fix the structure (’427 Patent, col. 4:35-40). A central "security component," such as a spring or tensioned cable, runs through the height of the stool to secure these locking arrangements and provide stability, preventing unintentional collapse (’427 Patent, Abstract; col. 4:44-50).
- Technical Importance: This design allows for a single, lightweight product to serve as a stool of multiple, selectable heights while collapsing into a small, self-contained disc-like shape.
Key Claims at a Glance
The complaint identifies independent claims 1, 8, and 17 as being at issue (Compl. ¶16).
Independent Claim 1:
- A seat portion.
- A telescopic side wall with a plurality of rings of varying diameters.
- Each ring is configured with "features of a locking arrangement" to lock with an adjacent ring.
- A "security component" centrally disposed along the chair's height, comprising a spring "configured to secure the locking arrangement."
Independent Claim 8:
- A seat portion.
- A telescopic side wall with a plurality of rings of varying diameters.
- Each ring is configured with "features of a locking arrangement."
- A "security arrangement" including a "resilient tensioning element" centrally disposed to secure the locking arrangement.
Independent Claim 17:
- A seat portion.
- A telescopic side wall with a plurality of rings of varying diameters.
- Each ring is configured with "components of a locking arrangement."
- A "spring" centrally disposed to secure the locking arrangement by urging one component against another.
III. The Accused Instrumentality
Product Identification
The complaint identifies collapsible stools sold by Plaintiff Dongying Borui on Amazon.com under the "Boreeman" brand (Compl. ¶5). The primary example is identified by ASIN B083945P76 (the "Accused Product"), with other ASINs listed as "Identical Products" (Compl. ¶¶5, 7).
Functionality and Market Context
The products are described as "collapsible stools" offered for sale to customers in the United States (Compl. ¶¶5, 9). The complaint does not provide specific technical details about the construction or operation of the accused stools, beyond the general characterization that they are collapsible. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the specific bases for non-infringement alleged by the Plaintiff. The complaint does not provide sufficient detail for a complete claim chart analysis, but it highlights two primary points of dispute.
The first point of contention, applicable to all asserted independent claims, is the absence of a central security element.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a security component centrally disposed along a height of the foldable chair substantially perpendicular to the varying diameters of the rings, the security component comprising a spring configured to secure the locking arrangement | The complaint alleges that the Accused Product and Identical Products do not include a "security component" as claimed in the ’427 patent. | ¶18 | col. 7:21-27 |
The second point of contention relates to the number of features or components in the locking mechanism.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein each of the rings is configured with features of a locking arrangement that selectively lock each ring with respect to an adjacent ring | The complaint alleges the Accused Products do not have more than one "feature" or "component" of a locking arrangement on "each" of the rings. | ¶19 | col. 7:17-21 |
Identified Points of Contention
- Technical Question: The central factual dispute is whether the accused stools contain any internal structure that meets the functional and structural requirements of the claimed "security component," "security arrangement," or centrally disposed "spring."
- Scope Question: A key legal question will be whether the plural terms "features" (Claims 1, 8) and "components" (Claim 17) require multiple distinct locking mechanisms on each ring, or if a single integrated locking system (e.g., a pin-and-groove mechanism) can be considered to have multiple "features" or "components." The complaint suggests Plaintiff will advocate for the former, more restrictive interpretation (Compl. ¶19).
V. Key Claim Terms for Construction
"security component" (Claim 1) / "security arrangement" (Claim 8)
- Context and Importance: This term appears to be the primary basis for the non-infringement allegation (Compl. ¶18). The presence or absence of a structure meeting this limitation in the accused products may be dispositive of infringement. Practitioners may focus on this term because its construction will define whether a separate, dedicated stabilizing element is required by the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims define these terms functionally as being "configured to secure the locking arrangement" (’427 Patent, col. 7:26-27). This could support an interpretation where any centrally located element that performs this stabilizing function, regardless of its specific form, falls within the claim scope.
- Evidence for a Narrower Interpretation: The specification describes specific embodiments, such as a "security lock 60" comprising a "flexible cable 62 centrally disposed within a spring 63" that connects the seat portion to the bottommost ring (’427 Patent, col. 4:44-58). A party could argue that the claim term should be limited to such a distinct tensile element, rather than covering general structural properties of the stool.
"features" (Claims 1, 8) / "components" (Claim 17)
- Context and Importance: Plaintiff explicitly argues that its products lack the required plurality of "features" or "components" on each ring (Compl. ¶19). The construction of this term is therefore critical to this secondary non-infringement theory.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patentee may argue that a single pin-and-groove system inherently possesses multiple "features" or "components"—for instance, the pin itself is one feature, and the corresponding groove is another. The patent describes the locking arrangement as including a "pin 52" and a "groove 54," which could be characterized as distinct but cooperating features (’427 Patent, col. 5:19-25).
- Evidence for a Narrower Interpretation: Plaintiff's gloss on the claim language—"features [i.e., more than one feature]"—suggests it will argue for a reading that requires at least two distinct locking mechanisms on each ring (Compl. ¶19). The specification’s focus on a single pin-and-groove mechanism for each ring could be used to support the view that the "locking arrangement" is a single entity, not one with multiple "features."
VI. Other Allegations
The complaint also includes a claim for a declaratory judgment of invalidity and/or unenforceability of the ’427 Patent (Compl. ¶¶24-29).
Invalidity
The complaint makes a general allegation that the patent is invalid under 35 U.S.C. §§ 101, 102, 103, and 112 (Compl. ¶25). It specifically alleges, "upon information and belief," that products "the same or materially similar" to the patented invention were sold or in public use more than one year before the patent's priority date (Compl. ¶28). The complaint does not provide sufficient detail for analysis of this allegation, as no specific prior art is identified.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: how will the court construe the term "security component" / "security arrangement"? The case may turn on whether this limitation requires a distinct, centrally-disposed tensile element as shown in the patent's figures, or if it can be read more broadly to cover other methods of ensuring structural stability.
- A second key question will be one of claim interpretation: does the requirement for plural "features" or "components" in the locking arrangement on "each" ring mandate multiple, discrete locking mechanisms per ring, or can a single integrated system with multiple constituent parts (such as a pin and a groove) satisfy this limitation?
- A final dispositive question will be evidentiary: what prior art can the Plaintiff identify to support its allegation that "materially similar products" were on sale or in public use before the patent's priority date, and does that art in fact disclose all elements of the asserted claims?