Shenzhen Funsnap Technology Co Ltd v. Guilin Zhishen Information Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Funsnap Technology Co. Ltd. and related entities (China, Hong Kong)
  • Defendant: Guilin Zhishen Information Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 1:23-cv-17139, N.D. Ill., 12/28/2023
• Venue Allegations: Venue is based on Defendant’s alleged business activities targeting consumers in the United States and Illinois, including operating interactive e-commerce stores on Amazon, shipping to Illinois, and accepting payment in U.S. dollars.
• Core Dispute: Plaintiffs seek a declaratory judgment that their "Gimbal Products" do not infringe U.S. Patent No. 11,218,047 and/or that the patent is invalid.
• Technical Context: The technology concerns the design of electric motors for handheld camera stabilizers, specifically the use of plastic components to reduce cost and manufacturing complexity.
• Key Procedural History: The action was precipitated by an infringement notice Plaintiffs received through Amazon’s Patent Evaluation Express (“APEX”) Program. Plaintiffs also allege that a Chinese counterpart to the patent-in-suit has been found invalid.

Case Timeline

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

U.S. Patent No. 11,218,047 - Plastic Motor For Handheld Stabilizer

• Patent Identification: U.S. Patent No. 11,218,047, Plastic Motor For Handheld Stabilizer, issued January 4, 2022.

The Invention Explained

• Problem Addressed: The patent's background section describes conventional motors for handheld stabilizers as being made of metal, which leads to problems including long production cycles, high cost, heavy weight, and difficulty in wiring ('047 Patent, col. 1:26-34).
• The Patented Solution: The invention proposes a "plastic motor" where at least one key structural component—the iron core carrier, motor shell, or motor end cover—is made of plastic material ('047 Patent, Abstract). This design aims to solve the identified problems by simplifying manufacturing, reducing cost and weight, and improving design flexibility ('047 Patent, col. 3:26-32). The specification also highlights the use of specific high-performance plastics like polyaryl amides to maintain strength and stability ('047 Patent, col. 2:30-34).
• Technical Importance: This approach suggests a shift in manufacturing philosophy for consumer-grade stabilizers, prioritizing lower cost and mass-producibility over the traditional reliance on all-metal components ('047 Patent, col. 1:44-49).

Key Claims at a Glance

• The complaint asserts non-infringement and invalidity of independent claim 1 (Compl. ¶¶ 28-29, 34).
• Independent Claim 1 Elements:
  • a motor shell;
  • a hollow metal motor shaft, wherein one end...is fixedly connected to the motor shell;
  • a motor end cover;
  • motor iron cores;
  • an iron core carrier, wherein one end...is detachably connected to the motor end cover and the other end...carries the motor iron cores, and at least one of the iron core carrier, the motor shell and the motor end cover is made of plastic material;
  • an upper bearing and a lower bearing...fixed on the iron core carrier...;
  • wherein a stopping component fixedly connected with an inner side of the motor shell is provided on an outer side of one end of the hollow metal motor shaft; and
  • wherein the motor shell is made of plastic material, and the connection...is injection molding connection, glue connection or interference connection.
• Plaintiffs also seek a declaration of invalidity for dependent claims 2-19 (Compl. ¶¶ 49, 77).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "Gimbal Products" sold by the various Plaintiffs on Amazon.com under storefronts including "FUNSNAP Official," "iSleeky," "glorypeaceUS," and "AOCHUANGimbal" (Compl. ¶¶ 14-18). Specific products are identified by Amazon Standard Identification Numbers (ASINs) (Compl. ¶¶ 14-18).

Functionality and Market Context

• The products are handheld camera stabilizers. The complaint alleges that the Amazon marketplace is Plaintiffs' "primary sales channel into the United States" and that Illinois is a "significant sales market" (Compl. ¶19). The complaint does not provide detailed technical descriptions of the accused products' internal construction.

IV. Analysis of Infringement Allegations

This is a declaratory judgment action where Plaintiffs allege non-infringement. The complaint makes a general assertion that the Gimbal Products fail to meet one or more elements of claim 1, and one specific assertion of non-infringement (Compl. ¶¶ 28-29).

No probative visual evidence provided in complaint.

• '047 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The central factual question is how the iron core carrier and motor end cover are connected in the accused Gimbal Products. The complaint provides no information on this point, which will be a focus of discovery.
  • Scope Questions: The primary legal dispute identified in the complaint revolves around the meaning of "detachably connected." The case may turn on whether the connection method used in the accused products, once revealed, falls within the proper construction of this claim term.

V. Key Claim Terms for Construction

• The Term: "detachably connected"
• Context and Importance: This term is the only one for which Plaintiffs provide a specific non-infringement argument (Compl. ¶29). Its construction is therefore central to the non-infringement portion of the case. Practitioners may focus on this term because the patent contrasts a "detachably connected" iron core carrier with a "fixedly connected" motor shaft, suggesting the patentee intended a meaningful distinction between the types of connections.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue for the plain and ordinary meaning, i.e., any connection that allows for separation without destroying the components. The claims themselves do not further limit the term.
  • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the iron core carrier is connected to the motor end cover via nuts passing through holes in the cover and fastening into threaded holes in the carrier ('047 Patent, col. 5:47-54). A party could argue that "detachably connected" should be construed as being limited to this or similar types of mechanical fastening, particularly when contrasted with the "fixedly connected" limitation for the motor shaft, which is achieved via injection molding ('047 Patent, col. 6:25-30).

VI. Other Allegations

• Indirect Infringement: Plaintiffs seek a declaration that they do not infringe "either directly or indirectly" (Compl. ¶31). However, the complaint pleads no specific facts regarding indirect infringement, such as inducement or contributory infringement.
• Willful Infringement: This section is not applicable as the complaint does not allege willfulness.

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

The resolution of this declaratory judgment action appears to depend on two central questions:

1. A question of claim scope and fact: Does the connection mechanism used in Plaintiffs' Gimbal Products fall within the legally construed meaning of "detachably connected" as required by claim 1 of the ’047 patent? Answering this will require both claim construction by the court and discovery into the specific design of the accused products.

2. An evidentiary question of invalidity: Can Plaintiffs prove by clear and convincing evidence that at least one of the numerous prior art combinations cited in the complaint (Compl. ¶¶ 43-76) discloses every element of the asserted claims? The breadth of the invalidity contentions suggests a comprehensive challenge to the patent's novelty and non-obviousness.