DCT
0:25-cv-60629
Shenzhen Yihong Tech Co Ltd v. Nnovative Closet Accessories LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Yihong Tech Co., Ltd. (People's Republic of China)
- Defendant: Nnovative Closet Accessories LLC (Florida, U.S.)
- Plaintiff’s Counsel: Dinsmore & Shohl LLP; Glacier Law LLP
- Case Identification: 0:25-cv-60629, S.D. Fla., 04/01/2025
- Venue Allegations: Venue is alleged to be proper in the Southern District of Florida because the Defendant is a Florida limited liability company with its principal place of business within the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its headwear storage products do not infringe Defendant’s patent and/or that the patent is invalid, following Defendant’s infringement allegations made to Plaintiff and to Amazon.com.
- Technical Context: The technology concerns stackable, transparent storage containers designed specifically for displaying and accessing collections of headwear, such as baseball caps.
- Key Procedural History: The action was precipitated by Defendant sending messages to Plaintiff via Amazon's internal system, asserting patent infringement and threatening to have Plaintiff's products removed from the platform. The complaint alleges that Defendant subsequently filed a patent infringement complaint with Amazon. The complaint also notes that three prior art patents identified by the Plaintiff were not examined during the prosecution of the patent-in-suit, which may be relevant to the Plaintiff's invalidity contentions.
Case Timeline
| Date | Event |
|---|---|
| 2017-07-27 | '075 Patent Priority Date |
| 2019-04-30 | '075 Patent Issue Date |
| 2025-03-21 | Defendant allegedly sends infringement notice to Plaintiff via Amazon |
| 2025-03-22 | Defendant allegedly informs Plaintiff's counsel that an Amazon complaint has been filed |
| 2025-04-01 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,273,075 - "Stackable Storage Device for Headwear" (Issued Apr. 30, 2019)
The Invention Explained
- Problem Addressed: The patent's background section identifies a need for a storage device for headwear that allows for a clean, dust-free display, convenient access to the collection, and the ability for units to be "effectively stacked one on top of another" ('075 Patent, col. 2:4-12).
- The Patented Solution: The invention is a storage container with specific structural features designed to facilitate both stacking and access. A key aspect is the container's geometry, where the top surface is shorter than the bottom surface, causing the side walls to slope downward at an obtuse angle ('075 Patent, col. 4:4-14). This shape allows the door of a lower container, when opened, to be held open by the bottom of a container stacked on top of it, aided by magnets ('075 Patent, col. 4:15-25; col. 7:1-8). The device also includes an internal slidable drawer to hold the headwear ('075 Patent, Abstract).
- Technical Importance: The design purports to solve the problem of accessing items in a lower stacked container without having to unstack the containers above it, a common issue with conventional stacking boxes ('075 Patent, col. 2:18-22).
Key Claims at a Glance
- The complaint's non-infringement analysis focuses on independent claim 1 ('075 Patent, Compl. ¶28).
- Essential elements of independent claim 1 include:
- An elongated container with a top surface, a bottom surface, two side surfaces, and a moveable door.
- The top surface is "shorter in length than the bottom surface."
- An end of each of the side surfaces "slopes down from the top surface to the bottom surface at an obtuse angle."
- A slidable drawer located inside the container.
- A horizontal flange on each side surface positioned to contact the drawer's side walls when the drawer is raised.
- The complaint notes that the Defendant's infringement allegations may extend to all claims of the patent, though none are specified (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are Plaintiff's hat organizer products sold under the VTOPMART® brand (Compl. ¶¶ 12-13).
Functionality and Market Context
- The complaint describes the Accused Products as storage devices for headwear that are sold through Amazon.com, which constitutes Plaintiff's "primary sales channel in the United States" (Compl. ¶¶ 2, 21).
- Technically, the complaint alleges the Accused Product is "essentially a rectangular box with a top and bottom of equal length" (Compl. ¶33). An image in the complaint provides dimensions for the product, showing a length of 43cm and a width of 26.6cm, to support the allegation of a rectangular, rather than trapezoidal, shape (Compl. ¶33). Another image shows two of the Accused Products stacked on top of one another (Compl. ¶13).
IV. Analysis of Infringement Allegations
The complaint does not provide a formal claim chart from the Defendant, as none was allegedly provided pre-suit (Compl. ¶24). The following table summarizes the Plaintiff's non-infringement theory for claim 1, as articulated in the complaint.
'075 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an elongated container with a top surface, a bottom surface... wherein the top surface is shorter in length than the bottom surface | The Accused Product is alleged to have a top and bottom of "equal length." The complaint provides an image with dimensions indicating the top and bottom surfaces share the same length and width. | ¶¶ 29, 32-33 | col. 8:8-10 |
| an end of each of the side surfaces slopes down from the top surface to the bottom surface at an obtuse angle | The Accused Product is described as a "rectangular box," which suggests its sides are perpendicular (90 degrees) to the top and bottom surfaces, not sloped at an obtuse angle. | ¶¶ 29, 32-33 | col. 8:10-12 |
- Identified Points of Contention:
- Factual Questions: The central dispute appears to be factual and geometric. The primary question is whether the Accused Product's top surface is in fact "shorter in length than the bottom surface" as required by the claim. The complaint's visual evidence, showing a photograph of the Accused Product with labeled dimensions, directly counters this limitation (Compl. ¶33).
- Scope Questions: A related question is whether the term "slopes down... at an obtuse angle" can be read to cover the right-angled construction of what the Plaintiff alleges is a standard "rectangular box" (Compl. ¶33). The patent links this specific geometry to the function of allowing a stacked container to hold open the door of a lower container ('075 Patent, col. 4:15-25). The complaint includes an annotated figure from the patent explicitly highlighting the claimed shorter top surface, contrasting it with the accused product's alleged design (Compl. ¶31).
V. Key Claim Terms for Construction
The Term: "shorter in length than the bottom surface"
Context and Importance: This term is critical because the Plaintiff's primary non-infringement argument is that its product has top and bottom surfaces of equal length. The entire geometric and functional premise of the patent's stacking feature appears to rely on this "length discrepancy" ('075 Patent, col. 4:5-6).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of arguments for a broader interpretation.
- Evidence for a Narrower Interpretation: The specification explicitly states that "the elongated container feature a top surface that is shorter than the bottom surface. As a result of this length discrepancy, the side surfaces of the container slope downward" ('075 Patent, col. 4:4-8). This language directly links the "shorter" length to the creation of the sloped sides, suggesting the term should be given its plain, literal geometric meaning.
The Term: "slopes down... at an obtuse angle"
Context and Importance: This limitation defines the specific profile of the container's side walls, which is directly related to the "shorter" top surface limitation. Plaintiff contends its "rectangular box" does not meet this requirement (Compl. ¶33). Practitioners may focus on this term because the patent's functionality is tied to this specific geometry.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of arguments for a broader interpretation.
- Evidence for a Narrower Interpretation: The specification provides a specific example, stating "preferred embodiments of the device have side walls that slope downwards at an obtuse angle such as a 45 degree" ('075 Patent, col. 4:11-14). While a 45-degree slope itself is acute, the resulting interior angle between the sloped side and the bottom surface would be obtuse (135 degrees), supporting a specific, non-rectangular shape. The patent figures consistently depict this sloped, trapezoidal profile (e.g., '075 Patent, FIG. 1).
VI. Other Allegations
The complaint is for declaratory judgment and does not contain counts for indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of factual determination: Does the accused VTOPMART® product embody the specific geometry claimed in the '075 patent, namely a top surface that is demonstrably "shorter in length than the bottom surface" and sides that "slope... at an obtuse angle," or is it a simple rectangular container as the Plaintiff alleges? The outcome may depend heavily on straightforward measurement and comparison against the claim language.
- A key validity question will be whether the claims of the '075 patent are obvious in light of prior art that was not before the examiner. The complaint specifically identifies U.S. Patent No. 3,224,822 ("Kirby Patent"), which allegedly "discloses a stackable container having a top surface shorter in length than the bottom surface and where an end of each of the side surfaces slopes down" (Compl. ¶39), raising the question of whether this prior art teaches the core structural limitations of the asserted claims.