DCT

1:24-cv-02120

Ningbo Tuoluhze Auto Accessories Co Ltd v. Individuals Partnerships Unincorp Associations

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-02120, N.D. Ill., 04/15/2024
  • Venue Allegations: Venue is asserted under 28 U.S.C. § 1391(b)(3) on the basis that the Defendants are not U.S. residents and thus may be sued in any district. Venue is also asserted under 28 U.S.C. § 1400(b) on the grounds that Defendants' agents may be found in the district.
  • Core Dispute: Plaintiff alleges that Defendants’ e-commerce sales of car latch pedal products infringe a patent for an auxiliary step designed to attach to a vehicle's door latch mechanism.
  • Technical Context: The technology concerns aftermarket automotive accessories, specifically a foldable step that provides a stable platform for accessing a vehicle's roof, a common need for owners of SUVs and trucks with roof racks.
  • Key Procedural History: The action is an Amended Complaint brought against a "Schedule A" list of largely anonymous e-commerce operators. Plaintiff alleges compliance with the patent marking statute and references an infringement opinion by a registered patent lawyer, attached as an exhibit to the complaint, to support its allegations.

Case Timeline

Date Event
2020-05-06 '736 Patent Priority Date
2022-05-24 '736 Patent Issue Date
2024-04-15 Amended Complaint Filing Date

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

U.S. Patent No. 11,338,736 - "CAR LATCH PEDAL" (Issued May 24, 2022)

The Invention Explained

  • Problem Addressed: The patent's background section identifies the inconvenience and potential for vehicle damage associated with using conventional aids like ladders or foldable chairs to load items onto a car roof. Such aids are described as being bulky, unstable, or lacking sufficient height and strength. (’736 Patent, col. 1:10-21).
  • The Patented Solution: The invention is a compact, portable pedal designed to securely engage a vehicle's door latch striker. It employs a hook that hangs on the latch and a "bottom clamp groove" that presses against the underside of the latch, using a pin as a pivot to create a stable connection. (’736 Patent, col. 2:36-43). The device also includes "elastic blocks" at its other end, which press against the door frame to provide stability and prevent damage to the vehicle's paint. (’736 Patent, Abstract; col. 4:12-18).
  • Technical Importance: The invention purports to offer a purpose-built solution that is more stable, secure, and less damaging to the vehicle than general-purpose steps or chairs. (’736 Patent, col. 1:26-32).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶65).
  • The essential elements of independent claim 1 are:
    • a pedal, with a bottom clamp groove and a first connecting hole at one end;
    • a bracket, with a hook on one side of one end and an adjusting hole on the other side of the same end, and the hook is hung on the car latch;
    • a first pin, fixed on a first connecting hole, the adjusting hole of the bracket is inserted in the first pin, and the bottom clamp groove is positioned beneath the car latch, pressed on the car latch by using the first pin as the pivot. The car latch is positioned between the hook and the bottom clamp groove;
    • the elastic blocks, fixed at the other end of the bracket.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as "Infringing Goods," further described as "car latch pedal products" that are promoted and sold by Defendants. (Compl. ¶¶64, 95).

Functionality and Market Context

The complaint alleges the accused products have "substantially the same technical features as the '736 Patent" and function as steps that attach to a car's door latch. (Compl. ¶64). A side-by-side photographic comparison shows the accused product as a foldable step visually similar to Plaintiff's product. (Compl. ¶67). This comparison depicts Plaintiff's orange branded product next to an allegedly infringing red product. (Compl. p. 11). The complaint alleges Defendants sell these products through various internet-based e-commerce stores, directly competing with Plaintiff and causing market confusion. (Compl. ¶¶30, 60-61).

IV. Analysis of Infringement Allegations

'736 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a pedal, with a bottom clamp groove and a first connecting hole at one end; The accused products are pedals that possess substantially the same technical features as the patented invention. ¶¶64, 65, 67 col. 4:50-52
a bracket, with a hook on one side of one end and an adjusting hole on the other side of the same end, and the hook is hung on the car latch; The accused products include a bracket with a hook for engaging a car latch, as depicted in photographic evidence. ¶¶64, 65, 67 col. 4:52-54
a first pin... the car latch is positioned between the hook and the bottom clamp groove; The accused products allegedly utilize a pivot pin and a clamping mechanism where the car latch is positioned between a hook and a groove. ¶¶64, 65 col. 4:55-62
the elastic blocks, fixed at the other end of the bracket. The accused products include blocks at the end of the bracket designed to press against the car's door frame for stability. ¶¶64, 65, 67 col. 4:62-63
  • Identified Points of Contention:
    • Scope Questions: The complaint's allegations are broad, stating the accused products have "substantially the same technical features." (Compl. ¶64). A central question for the court will be whether the specific structures of the various accused products fall within the scope of the claim terms. For example, does the structure on an accused product that engages the car latch meet the specific definition of a "bottom clamp groove" as contemplated by the patent?
    • Technical Questions: The complaint relies on a single representative image and a reference to an external infringement opinion (Exhibit 3) to support its technical allegations. (Compl. ¶¶66, 67). A key factual question will be whether the Defendants' products, upon inspection, actually operate in the manner required by the claims—for instance, whether the "elastic blocks" on the accused products perform the claimed functions of stabilizing and protecting the vehicle.

V. Key Claim Terms for Construction

  • The Term: "bottom clamp groove"

    • Context and Importance: This term defines the critical interface between the pedal and the vehicle's latch striker. The outcome of the infringement analysis for any given accused product may depend entirely on whether its latch-engaging feature is construed to be a "bottom clamp groove."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not specify a particular shape or dimension for the groove, which may support an interpretation covering any recess or channel that functions to clamp the bottom of the car latch.
      • Evidence for a Narrower Interpretation: The specification describes and illustrates a specific embodiment where the groove (31) is formed as part of both supporting plates (2) and reinforcing plates (3), suggesting a potentially more robust structure than a simple cutout. (’736 Patent, col. 4:51-52; col. 6:56-62; Fig. 3). A party could argue the term is limited to such a configuration.

  • The Term: "elastic blocks"

    • Context and Importance: This term is crucial for the stability and non-damaging aspects of the invention. Practitioners may focus on this term because its construction will determine whether a simple bumper meets the limitation or if more complex functionality is required.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the blocks can be made of materials like polyurethane or rubber, and their primary purpose is to protect the door frame. (’736 Patent, col. 4:12-18). This could support a reading that covers any resilient bumper.
      • Evidence for a Narrower Interpretation: The specification extensively describes embodiments where the elastic blocks are "rotationally installed" and have "at least two adjusting surfaces" to ensure the pedal remains horizontal regardless of the door frame's angle. (’736 Patent, col. 2:4-12; col. 4:45-48). A party may argue that the term "elastic blocks" should be limited to structures capable of this specific adjustability.

VI. Other Allegations

  • Indirect Infringement: The complaint includes allegations of contributory and induced infringement, asserting that Defendants' actions have caused injury to the Plaintiff. (Compl. ¶98). The pleading does not specify the factual basis for these claims, such as referencing user manuals or advertising that instruct on an infringing use.
  • Willful Infringement: The complaint alleges that Defendants' infringement has been "willful and deliberate" because they "had notice of or knew of the '736 Patent." (Compl. ¶99). The basis for willfulness is also asserted on the grounds that Defendants had "actual or constructive knowledge" of Plaintiff's patent rights and acted with "reckless disregard." (Compl. ¶¶63, 81).

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

  1. A core issue will be one of claim construction: can the term "elastic blocks" be construed to cover a simple, fixed rubber bumper, or does the patent's detailed description of rotational and adjustable surfaces limit the term to a block capable of such specific, angle-adjusting functionality?

  2. A second central question will be one of evidentiary sufficiency: given that this is a "Schedule A" case against numerous anonymous online sellers, can the Plaintiff, relying on a single representative image and broad allegations, provide sufficient evidence to prove that each of the distinct "Infringing Goods" sold by each Defendant practices every limitation of the asserted claim?