Shenzhen En De Chuang Technology Co Ltd v. Lewis Machining Engineering Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen En de chuang Technology Co., Ltd. and related entities (People's Republic of China)
  • Defendant: Lewis Machining & Engineering, Inc. (Georgia, USA)
  • Plaintiff’s Counsel: Wilson, Morton & Downs, LLC; Youngzeal LLP
• Case Identification: 7:25-cv-00193, M.D. Ga., 12/12/2025
• Venue Allegations: Plaintiffs allege venue is proper in the Middle District of Georgia because the Defendant is a Georgia corporation with its headquarters and a regular and established place of business in the district.
• Core Dispute: Plaintiffs seek a declaratory judgment that their bed sheet retention products do not infringe, and that the claims of Defendant’s U.S. Patent No. 12,390,016 are invalid, following Defendant's patent infringement complaints on the Amazon platform which resulted in the delisting of Plaintiffs' products.
• Technical Context: The dispute centers on mechanical devices designed to secure bed sheets to a mattress, a consumer product category focused on convenience and ease of use.
• Key Procedural History: The action was precipitated by Defendant's assertion of the patent-in-suit through Amazon's internal intellectual property complaint process, which led to the removal of Plaintiffs' product listings. Plaintiffs also bring a cause of action for tortious interference with business relationships based on these actions.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,390,016 - "Bed sheet retention systems, system components, and methods of making and using the same"

• Issued: August 19, 2025
• Short Name: The “’016 Patent”

The Invention Explained

• Problem Addressed: The patent's background describes conventional sheet tensioning systems, such as elastic bands and drawstrings, as "tedious," "labor intensive," and often frustrating for users, particularly when sheets fit tightly or come undone easily (’016 Patent, col. 2:40-58).
• The Patented Solution: The invention is a mechanical system comprising a bracket (typically for a corner) that is placed between the mattress and its support surface. This bracket features channels along its outer sides. A user tucks the bed sheet into a channel, and then inserts a separate, semi-rigid "sheet locking strip" into the same channel to secure the sheet material in place (’016 Patent, Abstract; Fig. 8). This two-part system of a bracket with a channel and a separate locking strip is central to the described solution.
• Technical Importance: The design aims to provide a more intuitive and effective method for securing sheets compared to prior art solutions by creating a positive mechanical lock that is easy to engage and disengage (’016 Patent, col. 2:54-58).

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 (Compl. ¶19).
• Essential elements of independent claim 1 include:
  • A bed sheet retention system comprising one or more corner brackets and one or more sheet locking strips.
  • Each corner bracket has a horizontally-extending component to go under the mattress.
  • The bracket has "two or more sheet-engaging channels" connected to the horizontal component, with two channels separated by a corner.
  • Each channel comprises an upper and a lower "sheet-locking channel member" designed to engage with the locking strips.
  • Each channel has a track profile with a height greater than its width.
  • The system includes separate "sheet locking strips" sized to engage with the channel members and having a width greater than their thickness.
• The complaint states the Accused Products do not infringe claim 1 "or any claims that depend on it" (Compl. ¶20).

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are "bed sheet retention systems" sold by Plaintiffs on Amazon storefronts including "EDCREATY," "Downoop," "AUKCLAX," and "KLBWWA" (Compl. ¶¶1, 13).

Functionality and Market Context

• The complaint identifies three distinct designs among the Accused Products, each employing a different sheet-locking mechanism: a "snap-fit locking design," a "plug-in locking design," and a "rotational locking design" (Compl. ¶15).
• Illustration 1 depicts the "Snap-Fit Locking Design," which appears to be a single-piece device that secures a sheet without a separate strip (Compl. p. 7). Illustration 2 shows the "Plug-in Locking Design," which involves a base piece and a separate insertable component (Compl. p. 7). Illustration 3 displays the "Rotational Locking Design," which appears to use a swiveling or rotating component to lock the sheet in place (Compl. p. 8).
• The complaint alleges that Defendant’s actions of reporting these products for infringement have harmed Plaintiffs' sales, product rankings, and reputation in the Amazon marketplace (Compl. ¶¶1, 40).

IV. Analysis of Infringement Allegations

As this is a complaint for declaratory judgment of non-infringement, the following table summarizes Plaintiffs' core allegations of how their products fail to meet the limitations of the asserted patent claim.

’016 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The central dispute appears to be one of claim scope. A primary question will be whether the locking mechanisms of the Accused Products—described as "snap-fit," "plug-in," and "rotational"—can be construed as meeting the claim limitations of "sheet-engaging channels" and separate "sheet locking strips."
• Technical Questions: The case will require a factual determination of how each of the three accused designs operates. For the "plug-in" and "rotational" designs, which appear to have multiple components, a key question may be whether one component functions as the claimed "bracket" with "channels" and the other as the claimed "strip," or if they constitute a fundamentally different mechanism not contemplated by the patent.

V. Key Claim Terms for Construction

"sheet locking strips"

• Context and Importance: This term is critical because Plaintiffs' core non-infringement argument is that their products lack this element (Compl. ¶20). The definition will determine whether the "plug-in" or "rotational" components of the Accused Products could be considered infringing equivalents.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires the strip to be "sized and designed to engage with" the channel members, which could potentially be read on any separate component that is inserted to create a lock (’016 Patent, col. 38:20-25).
  • Evidence for a Narrower Interpretation: The patent consistently depicts the "sheet locking strip" (30) as a distinct, elongated, relatively thin and flat component that slides into a channel (e.g., ’016 Patent, Figs. 8, 14, 20). The specification also describes its dimensions, such as having a "strip width Ws greater than a strip thickness Ts," which may limit the term to structures with a specific geometry (’016 Patent, col. 38:25-27).

"sheet-engaging channels"

• Context and Importance: This term is also central to Plaintiffs' non-infringement defense (Compl. ¶20). Its construction will define the required structure of the "bracket" component and whether the receiving portions of the Accused Products meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 describes the channels as comprising "an upper sheet-locking channel member" and "a lower sheet-locking channel member positioned below and spaced from" the upper member, a general structural description that could arguably read on various track-like configurations (’016 Patent, col. 37:6-9).
  • Evidence for a Narrower Interpretation: The patent figures consistently show a specific C-shaped or track-like profile for the channels, designed for a strip to slide into from one end (e.g., ’016 Patent, Figs. 2, 14). The requirement that the channel has a "track profile height HTP greater than a track profile width WTP" may further limit the scope to a specific tall and narrow geometry (’016 Patent, col. 37:11-14).

VI. Other Allegations

Indirect Infringement

• In their prayer for relief, Plaintiffs seek a declaration that they have not infringed "directly or indirectly, any claim of the '016 Patent" (Compl. ¶A, p. 14). The body of the complaint, however, focuses on direct non-infringement and does not provide specific facts relating to inducement or contributory infringement.

Willful Infringement

• No allegations of willful infringement are made by the patentee in the documents provided. This is a declaratory judgment action brought by the accused infringer.

Tortious Interference

• Plaintiffs allege that Defendant intentionally interfered with their business relationships with customers by making "baseless and improper complaints of patent infringement to Amazon" (Compl. ¶34). They allege Defendant knew or should have known the complaints lacked an objective basis due to the "significant differences" between the patented system and the Accused Products (Compl. ¶35).

VII. Analyst’s Conclusion: Key Questions for the Case

The resolution of this declaratory judgment action will likely depend on the court's determination of two primary issues:

• A core issue will be one of definitional scope: Will the terms "sheet-engaging channels" and "sheet locking strips", as defined by the patent's intrinsic evidence, be construed narrowly to cover only the slide-in strip embodiment shown in the figures, or broadly enough to encompass the "snap-fit," "plug-in," or "rotational" mechanisms of the Accused Products?
• A second key question will relate to the tortious interference claim: Did the patent holder's assertion of its rights through Amazon's platform lack an objective basis to the extent that it constitutes improper interference, or was it a legitimate, good-faith effort to enforce its patent rights?