The Schedule A

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Xiaobing Wang and Liangqing Li (People's Republic of China)
  • Defendant: Individuals, Partnerships, and Unincorporated Associations on Schedule “A”
  • Plaintiff’s Counsel: Getech Law
• Case Identification: 1:23-cv-15417, N.D. Ill., 10/30/2023
• Venue Allegations: Venue is alleged to be proper because Defendants sell and ship infringing products to residents of the Northern District of Illinois via online retail platforms. Additionally, Plaintiffs allege that because Defendants are foreign entities or individuals, they may be sued in any judicial district.
• Core Dispute: Plaintiffs, the inventors, allege that various online retailers' "magnetic suspension lamps" infringe a patent for a magnetic suspension device that uses wireless power transfer to illuminate the levitating object.
• Technical Context: The technology relates to decorative magnetic levitation devices, specifically improving their aesthetic effect by enabling illumination without the need for wires or batteries that would interfere with the suspension.
• Key Procedural History: The action is brought against a list of unidentified defendants ("Schedule A"), a procedural approach often used to target numerous, potentially anonymous online sellers of allegedly infringing goods. The filing is an Amended Complaint.

Case Timeline

Date	Event
2008-12-31	'542 Patent Priority Date
2012-10-23	'542 Patent Issue Date
2023-10-30	Amended Complaint Filing Date

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

U.S. Patent No. 8,294,542 - "MAGNETIC SUSPENSION DEVICE"

• Patent Identification: U.S. Patent No. 8,294,542, “MAGNETIC SUSPENSION DEVICE,” issued October 23, 2012.

The Invention Explained

• Problem Addressed: The patent describes a problem with existing magnetic suspension devices where adding a light source to the suspended object required either a power wire, which was aesthetically unpleasing and limited movement, or a battery, which added weight and could disrupt the delicate magnetic balance needed for levitation ('542 Patent, col. 1:24-41).
• The Patented Solution: The invention solves this problem by using wireless power transmission. A "transmitting coil" is placed in the magnetic base, and a "receiving coil" is placed in the levitating "suspension body." The base transmits an AC signal that the receiving coil converts into electricity to power a "luminous body" (like an LED) on the suspended object, eliminating the need for physical contact or batteries ('542 Patent, col. 1:50-65). This allows the object to be both suspended and illuminated without physical tethers.
• Technical Importance: This approach enabled the creation of more visually appealing and versatile decorative levitating products, such as lamps and toys, by integrating illumination without compromising the core suspension function ('542 Patent, col. 2:30-34).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 8.
• Independent Claim 1 recites a magnetic suspension device with elements for wireless power transfer, and includes a list of specific structural limitations for the suspension body, including:
  • A plurality of LED lamps
  • A permanent magnet arranged symmetrically inside
  • An upper case, a lower case, and a "mounting ring" arranged between them
  • A specific assembly wherein a cylindrical portion of the magnet passes through a hole in the receiving coil and is inserted into a fixing hole in the lower case ('542 Patent, col. 5:24-63).
• Independent Claim 8 recites a magnetic suspension device with elements for wireless power transfer, and includes a list of specific structural limitations for the magnetic base, including:
  • A transmitting circuit board
  • An "annular ferrite"
  • A plurality of "suspension system coils" and "magnetic heads"
  • A "magnetic suspension circuit board" to control the coils
  • System and central sensors to control the suspension ('542 Patent, col. 6:48-col. 7:2).
• The complaint notes that it also asserts dependent claims 2 and 3 (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "magnetic suspension lamps" offered for sale and sold by the Defendants through online storefronts on platforms such as Amazon.com, eBay.com, and Walmart (Compl. ¶¶ 5, 10).

Functionality and Market Context

• The complaint alleges these products are magnetic suspension devices that include a magnetic base and a levitating suspension body (Compl. ¶12). The key accused functionality is the use of a wireless power system, comprising a transmitting coil in the base and a receiving coil in the suspension body, to power luminous bodies (e.g., LEDs) on the levitating portion of the lamp (Compl. ¶¶ 12, 15). The complaint includes a photograph of an exemplary accused product, which shows a base and a levitating, illuminated light bulb object (Compl. ¶10, referencing Ex. A-1).

IV. Analysis of Infringement Allegations

'542 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A magnetic suspension device comprising a magnetic base and a suspension body; the suspension body being suspended above the magnetic base...	The accused products are magnetic suspension devices that include a magnetic base and a suspension body, with the suspension body suspended above the magnetic base.	¶12	col. 5:24-27
the suspension body being provided with a receiving coil and at least one luminous body; the magnetic base being provided with a transmitting coil...	The suspension body is provided with a receiving coil and at least one luminous body; the magnetic base is provided with a transmitting coil.	¶12	col. 5:27-30
the transmitting coil transmitting an AC signal to the receiving coil; the receiving coil converting the AC signal...into electric energy and supplying the electric energy to the luminous body for emitting light...	The transmitting coil transmits an AC signal to the receiving coil, which converts the signal into electric energy to supply the luminous body.	¶12	col. 5:30-35
wherein the suspension body is provided with a plurality of luminous bodies; the luminous bodies adopt LED lamps...	The suspension body is provided with a plurality of luminous bodies, which are LED lamps.	¶12	col. 5:36-41
wherein a permanent magnet is arranged inside the suspension body, and the permanent magnet is arranged symmetrically around the barycenter vertical of the suspension body...	A permanent magnet is arranged inside the suspension body and arranged symmetrically around its barycenter vertical.	¶12	col. 5:42-46
wherein the suspension body comprises an upper case, a lower case and a mounting ring arranged between the upper case and the lower case...	The accused product's suspension body comprises an upper case, lower case, and a mounting ring arranged between them.	¶12	col. 5:47-50
the permanent magnet is an assembly of magnets, of which the lower end is a cylindrical magnet...the middle of the receiving coil is provided with a through hole corresponding to the cylindrical magnet...	The complaint alleges the accused products' components match these specific magnet, coil, and case assembly structures.	¶12	col. 5:51-63

• Identified Points of Contention:
  • Technical Questions: The asserted claims contain numerous, highly specific structural limitations regarding the internal construction of both the suspension body (Claim 1) and the magnetic base (Claim 8). A central question will be one of evidence: has the Plaintiff conducted a teardown or other analysis to confirm that the accused products, sold by many different entities, actually contain the specific internal components as claimed, such as a "mounting ring" (Claim 1) or an "annular ferrite" and "magnetic heads" (Claim 8)? The complaint alleges these features exist but does not describe the basis for this knowledge (Compl. ¶¶ 12, 15).
  • Scope Questions: The infringement case may turn on whether the components in the accused products meet the specific definitions of the claimed terms. For example, a dispute could arise over whether a component in an accused device functions as the claimed "system sensor used to control the suspension of the suspension body" and the separate "central sensor used to control the work of the system sensor" as required by Claim 8 (Compl. ¶15; '542 Patent, col. 7:1-2).

V. Key Claim Terms for Construction

• The Term: "annular ferrite" (Claim 8)

• Context and Importance: This term appears in claim 8, which focuses on the base's internal structure. Infringement of this claim depends on the accused product's base containing this specific component. Practitioners may focus on this term because its construction could either limit the claim to a literal ring-shaped ferrite magnet or allow it to cover other magnetic structures.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that the ferrite "is not limited to a single annular permanent magnet, and it can also be an assembly of an elliptic and several cylindrical permanent magnets, etc." ('542 Patent, col. 5:2-6). Plaintiffs may argue this passage defines the term broadly to cover equivalents.
  • Evidence for a Narrower Interpretation: Defendants may argue that the claim language itself explicitly requires an "annular" (ring-shaped) component, and that the specification's description of alternatives cannot override the plain meaning of the term used in the claim itself. The primary embodiment depicts a ring-shaped ferrite (21) ('542 Patent, Fig. 4).

• The Term: "mounting ring" (Claim 1)

• Context and Importance: This is a specific structural element of the suspension body required by claim 1. The infringement analysis for this claim will require determining if the accused products contain a structure that meets this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term is not explicitly defined, so a party could argue for its plain and ordinary meaning as any ring-like structure used for mounting.
  • Evidence for a Narrower Interpretation: The patent figures show a specific implementation of the mounting ring (33) as a distinct, spoked, circular plate that sits between the upper (32) and lower (34) halves of the suspension body's casing and holds the luminous bodies (6) ('542 Patent, Fig. 3; col. 4:1-6). A party could argue the term should be limited to a structure with these characteristics.

VI. Other Allegations

• Indirect Infringement: The prayer for relief requests an injunction against inducement and contribution (Compl. p. 6, ¶2). However, the body of the complaint does not allege specific facts to support a claim for indirect infringement, such as identifying instructions or user manuals that would encourage infringing acts.
• Willful Infringement: The complaint alleges that "Defendants have been and are now infringing" the patent, which may form a basis for post-suit willfulness (Compl. ¶11). The prayer for relief also requests a determination that the case is "exceptional" under 35 U.S.C. § 285, which could lead to an award of attorney's fees (Compl. p. 6, ¶4). The complaint does not allege pre-suit knowledge of the patent.

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

• A core issue will be one of evidentiary sufficiency: Can the Plaintiffs produce evidence, likely from product teardowns, demonstrating that the diverse "magnetic suspension lamps" from numerous online sellers all contain the highly specific and detailed internal structures recited in independent claims 1 and 8? The complaint's conclusory recitation of the claim elements as infringing features will require substantial factual support.
• The case may also depend on claim construction: The viability of the infringement claims will hinge on how the court construes structurally-limiting terms such as "mounting ring," "annular ferrite," and "magnetic heads." The outcome will turn on whether the physical components within the accused products can be read upon by these claim terms, particularly in light of potentially broadening language in the specification.