Shanghai XINQI Electronic Technology CO., LTD.

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shanghai Xinqi Electronic Technology Co., Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A (Allegedly China or other foreign jurisdictions)
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 1:24-cv-06100, N.D. Ill., 07/19/2024
• Venue Allegations: Venue is based on allegations that Defendants operate interactive e-commerce stores that directly target business activities and sales to consumers in the United States, including Illinois.
• Core Dispute: Plaintiff alleges that Defendants’ online sales of mason jar sealing products infringe a patent related to a multifunctional, self-contained vacuum sealing device.
• Technical Context: The technology concerns portable electronic devices for creating a vacuum seal on mason jars, a common method for home food preservation.
• Key Procedural History: This action is filed against numerous unidentified online sellers, listed on Schedule A, who allegedly sell the same or similar infringing products. The complaint asserts that joinder of these defendants is proper under 35 U.S.C. § 299, which permits aggregation of defendants in patent cases where infringement arises from the same transaction or occurrence related to the making, using, or selling of the same accused product.

Case Timeline

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

• Patent Identification: U.S. Patent 11,981,555, "MULTIFUNCTIONAL MASON JAR SEALING DEVICE", issued May 14, 2024.

The Invention Explained

• Problem Addressed: The patent describes conventional mason jar sealers as inconvenient because they require separate, external vacuum equipment. It also notes the lack of a single sealer that can handle both wide-mouth and standard-caliber mason jars, which have different diameters (’555 Patent, col. 1:21-33).
• The Patented Solution: The invention is a self-contained, portable sealing device with an integrated vacuum pump. It achieves adaptability through a modular design comprising a "mason jar main machine" and a "sealing converter." The main machine houses the pump and a "first sleeve" to fit one size of jar. The sealing converter is a detachable adapter with a "second sleeve" that allows the same main machine to seal a different-sized jar, thus providing a single, all-in-one device (’555 Patent, col. 1:41-54, Abstract).
• Technical Importance: The claimed invention aims to provide a single, portable device that can seal multiple common types of mason jars without needing external pumps or separate sealers for each jar size (’555 Patent, col. 1:34-40).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶25).
• The essential elements of independent claim 1 include:
  • A "mason jar main machine" and a "sealing converter."
  • The main machine includes an "isolation plate," a "first sleeve," a "receiving cavity," and a "vacuum pump" within the cavity.
  • The sealing converter has a "connecting part" to detachably connect to the first sleeve and a "second sleeve" to match a second mason jar body.
  • The main machine includes a "main board," an "air delivery pipe," and a "solenoid valve... used to input gas into the first sleeve when it is opened" to release the vacuum.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "mason jar sealing products" ("the Infringing Products") sold by the Defendants through various e-commerce storefronts (Compl. ¶4, Schedule A).

Functionality and Market Context

• The complaint alleges the Infringing Products are "the same or similar" to each other and embody the patented design (Compl. ¶3). The complaint includes an exploded-view diagram of the patented device to represent the features of the accused products, identifying components such as an isolation plate, a first sleeve, a receiving cavity, and a vacuum pump (Compl. ¶8, p. 4). This diagram, sourced from the patent, shows the key components of the main sealing unit (Compl. p. 4; ’555 Patent, Fig. 4). The complaint alleges Defendants are "online infringers who trade upon Xinqi's patented design" and operate through e-commerce stores to sell to "unknowing consumers" (Compl. ¶4-5).

IV. Analysis of Infringement Allegations

'555 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The case may turn on whether the accused products, alleged to be "the same or similar" (Compl. ¶3), all practice the highly specific limitations of Claim 1. A potential dispute is whether a product that achieves adaptability or vacuum release through a different mechanism (e.g., a manual valve instead of a "solenoid valve") falls within the claim's scope.
• Technical Questions: A key evidentiary question will be whether Plaintiff can demonstrate that the accused products sold by each Defendant contain every recited internal component, such as the "solenoid valve... connected to the main board" and the "air delivery pipe." The complaint does not provide specific evidence, such as product teardowns, to substantiate the presence of these internal features across all accused products.

V. Key Claim Terms for Construction

• The Term: "sealing converter"

  • Context and Importance: This term is central to the "multifunctional" aspect of the invention, as it describes the component that enables the device to seal jars of different sizes. The definition of this term will determine whether the claim covers only the specific adapter structure shown in the patent or a broader category of adapters.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 describes the converter functionally as having a "connecting part detachably connected with the first sleeve and a second sleeve matched with the second mason jar body" (’555 Patent, col. 7:60-65). A party could argue that any component meeting this structural and functional description falls within the claim's scope.
    • Evidence for a Narrower Interpretation: The specification consistently depicts the sealing converter as a specific component (12) that interfaces between the main machine (15) and a standard-caliber jar (’555 Patent, Fig. 4, col. 5:22-25). A party may argue the term should be limited to embodiments similar to the one explicitly described and shown.

• The Term: "solenoid valve"

  • Context and Importance: Claim 1 requires a "solenoid valve" for a specific purpose: to "input gas into the first sleeve when it is opened, so as to release the connection" (’555 Patent, col. 8:17-24). Infringement of Claim 1 requires the presence of this specific type of electro-mechanical valve. Practitioners may focus on this term because alternative, purely mechanical release mechanisms may exist in competing products.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself defines the valve's function. A party may argue that any electro-mechanical valve that opens to input gas for vacuum release meets the limitation, regardless of its precise design.
    • Evidence for a Narrower Interpretation: The patent specifies that the solenoid valve (156) is "connected to the main board" and the battery (’555 Patent, col. 6:41-47, col. 6:48-54). A party could argue that this requires an electronically controlled valve integrated into the device's circuitry, and a simple manual push-button or mechanical switch that physically breaks the seal would not meet this limitation.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement, stating Defendants "knowingly and willfully" offered for sale products that infringe "directly and/or indirectly" (Compl. ¶19, ¶24). It does not, however, plead specific facts to support a claim for either induced or contributory infringement, such as allegations related to user manuals or the non-staple nature of components.
• Willful Infringement: Willfulness is alleged based on Defendants "knowingly and willfully" manufacturing and selling infringing products (Compl. ¶20, ¶23). The basis appears to be the alleged intentional copying of a patented design for sale by anonymous online entities, rather than notice of the specific patent.

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

• A central issue will be one of evidentiary proof: can the Plaintiff produce sufficient evidence, such as product teardowns or testing, to demonstrate that the products sold by each of the numerous Schedule A Defendants practice every limitation of Claim 1, particularly the specific internal components like the "solenoid valve" and the "sealing converter" as claimed?
• The case also raises a key procedural question regarding joinder: will the court accept the allegation that all Defendants are selling the "same or similar" product (Compl. ¶3) as sufficient to satisfy 35 U.S.C. § 299, or will the Defendants’ use of separate e-commerce stores be seen as distinct "transactions or occurrences" requiring individualized analysis?