1:24-cv-07129
Shenzhen Tuko Technology Co Ltd v. Antennas Direct Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Tuko Technology Co., Ltd (People's Republic of China)
- Defendant: Antennas Direct, Inc. (Missouri, USA)
- Plaintiff’s Counsel: Alioth Law
- Case Identification: 1:24-cv-07129, N.D. Ill., 05/13/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant submitted to the court's jurisdiction by filing an answer and counterclaims in response to a previous complaint in the action.
- Core Dispute: Plaintiff seeks a declaratory judgment that its antenna products do not infringe Defendant's patent related to amplified television antennas, and that the patent is invalid and unenforceable.
- Technical Context: The technology concerns amplified over-the-air television antennas that draw power from a non-dedicated source, such as a television's USB port, rather than a dedicated AC wall adapter.
- Key Procedural History: The action was precipitated by Defendant sending patent infringement complaints to e-commerce platforms, including Amazon and Walmart, which resulted in the delisting of Plaintiff's products. Plaintiff states that Defendant has also filed a counterclaim for infringement in this litigation.
Case Timeline
| Date | Event |
|---|---|
| 2012-01-09 | U.S. Patent No. 8,884,839 Priority Date |
| 2014-11-11 | U.S. Patent No. 8,884,839 Issue Date |
| 2024-05-20 | Accused Product Delisting on Walmart (First Batch) |
| 2024-06-13 | Accused Product Delisting on Walmart (Second Batch) |
| 2024-06-17 | Accused Product Delisting on Walmart (Third Batch) |
| 2024-06-27 | Accused Product Delisting on Amazon (First Batch) |
| 2024-08-03 | Accused Product Delisting on Amazon (Second Batch) |
| 2025-05-13 | Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,884,839, "Amplified Television Antenna," issued November 11, 2014
The Invention Explained
- Problem Addressed: The patent describes prior art amplified television antennas as requiring a dedicated external "power brick" connected to an AC outlet. This configuration is described as creating waste heat and consuming energy continuously, regardless of whether the attached television is powered on (’839 Patent, col. 2:17-23).
- The Patented Solution: The invention is an amplified television antenna system that eliminates the need for a separate, dedicated AC power brick. Instead, it is designed to draw power from a non-dedicated source, such as a USB port on the television itself or another connected device (’839 Patent, Abstract; col. 5:50-54). This allows the antenna's amplifier to be powered on and off concurrently with the television, thereby conserving energy (’839 Patent, col. 5:9-15). The system architecture is depicted in Figure 3, which shows a power cable (304) connecting a television receiver (310) to a power injector circuit (303) that powers the antenna (’839 Patent, FIG. 3).
- Technical Importance: This approach simplifies the antenna system by reducing the number of components a consumer must install and eliminates the need for a dedicated AC outlet near the television for the antenna amplifier (’839 Patent, col. 6:25-29).
Key Claims at a Glance
The complaint does not specify which claims were asserted by the Defendant, but analysis centers on the patent's two independent claims.
- Independent Claim 1: An antenna system comprising:
- an OTA antenna element;
- an amplifier co-located with said OTA antenna element;
- a power injector suitably enabled to receive an amplified signal from an amplifier and further enabled to deliver an amplified signal to a display device;
- a power cable to connect said power injector to a power source; and
- a coaxial cable connecting the antenna/amplifier to the power injector, and a second coaxial cable connecting the power injector to a display device.
- Independent Claim 4: An antenna system comprising:
- an OTA antenna element;
- an amplifier;
- a power supply circuit integrated with said amplifier;
- a power cable to connect said power supply circuit of said amplifier to a power source; and
- a coaxial cable connecting said antenna element to said amplifier, and a second coaxial cable to connect said amplifier to a display device.
III. The Accused Instrumentality
Product Identification: The complaint identifies the accused instrumentalities as "antenna products" and "electronic components used to receive or transmit signals, namely antennas" that are manufactured by Plaintiff Shenzhen Tuko Technology Co., Ltd (Compl. ¶9, ¶10). These products are sold through various channels, including Plaintiff's own e-commerce website and third-party platforms like Amazon and Walmart (Compl. ¶7, ¶10).
Functionality and Market Context:
- The complaint provides minimal technical detail regarding the functionality of the accused products, stating only that they are "either self-designed or produced based on existing public technology" (Compl. ¶10, ¶23). Given the nature of the ’839 Patent, the dispute presumably centers on amplified antennas that are powered via a USB connection.
- The complaint alleges that Defendant’s infringement notices to Amazon and Walmart caused the delisting of Plaintiff's products, resulting in "significant financial loss" and harm to Plaintiff's business relationships (Compl. ¶7, ¶13).
IV. Analysis of Infringement Allegations
The complaint, being a declaratory judgment action for non-infringement, does not contain a detailed infringement analysis or claim chart. It summarily denies infringement, stating that Defendant's allegations are incorrect and that Plaintiff's products are based on its own design or publicly available art (Compl. ¶21, ¶23). The following table outlines the potential infringement theory for Claim 4, which would likely form the basis of Defendant's assertions, though the complaint itself does not provide this level of detail.
No probative visual evidence provided in complaint.
'839 Patent Infringement Allegations
| Claim Element (from Independent Claim 4) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an OTA antenna element; | The complaint does not provide sufficient detail for analysis of this element. | ¶21 | col. 6:51 |
| an amplifier; | The complaint does not provide sufficient detail for analysis of this element. | ¶21 | col. 6:52 |
| a power supply circuit integrated with said amplifier; | The complaint does not provide sufficient detail for analysis of this element. | ¶21 | col. 6:53 |
| a power cable to connect said power supply circuit of said amplifier to a power source; and | Based on the patent's subject matter, Defendant's infringement assertions are likely premised on Plaintiff's products including a USB cable to draw power from a television or other device. | ¶11, ¶21 | col. 6:54-56 |
| a coaxial cable connecting said antenna element to said amplifier, and a second coaxial cable to connect said amplifier to a display device. | The complaint does not provide sufficient detail for analysis of this element. | ¶21 | col. 6:57-60 |
- Identified Points of Contention:
- Technical Questions: The central infringement question is whether Plaintiff's antenna products practice every limitation of either Claim 1 or Claim 4. The complaint's defense that its products are "based on... public available prior art" (Compl. ¶23) is an invalidity argument, not a direct rebuttal of infringement. The court will need to determine if the accused products meet the specific structural arrangements of the claims, irrespective of the prior art.
- Scope Questions: A key distinction exists between Claim 1, which requires a separate "power injector," and Claim 4, which requires a "power supply circuit integrated with said amplifier." The specific design of Plaintiff's products will determine which, if any, of these claims could be read upon them.
V. Key Claim Terms for Construction
The Term: "power injector" (Claim 1)
- Context and Importance: The presence or absence of a distinct "power injector" component in the accused products appears to be a dispositive issue for infringement of Claim 1. The claim recites the injector as a separate element from the antenna/amplifier combination.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the term should be given its plain meaning, covering any circuit that injects power onto a coaxial line, regardless of its specific housing or form factor.
- Evidence for a Narrower Interpretation: The specification and Figure 3 depict the "power injector" (303) as a physically distinct component that sits between the antenna (301) and the television (310), connected to each by separate coaxial cables (’839 Patent, col. 5:21-33). This may support an interpretation requiring a separate physical housing.
The Term: "co-located with" (Claim 1) vs. "integrated with" (Claim 4)
- Context and Importance: Practitioners may focus on these terms because they define the physical relationship between the amplifier and another component, and the difference between them distinguishes the scope of the two independent claims. "Co-located" relates the amplifier to the antenna element, while "integrated" relates the power supply circuit to the amplifier.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (co-located): A party might argue "co-located" simply means in close proximity or within the same general housing, without requiring a single, unified structure.
- Evidence for a Narrower Interpretation (integrated): The term "integrated" often implies that components are combined into a single, inseparable unit. The specification describes an "amplifier with an integral power circuit" (’839 Patent, col. 5:58-59), which could support a construction that requires the power circuitry and amplifier to be part of the same circuit board or module, as opposed to merely being in the same box.
VI. Other Allegations
The complaint does not contain specific factual allegations to support indirect or willful infringement by the Plaintiff. These sections are therefore omitted.
VII. Analyst’s Conclusion: Key Questions for the Case
Invalidity vs. Infringement: A primary issue for the court will be to separately analyze Plaintiff's dual arguments for non-infringement and invalidity. The complaint's repeated assertion that its products are based on "public available prior art" (Compl. ¶14, ¶23) points to an invalidity defense under 35 U.S.C. §§ 102/103. The key question for the infringement count, however, will be a direct comparison of the accused products to the claim language, regardless of what the prior art discloses.
Definitional Scope and Structure: The outcome will likely depend on the construction of key structural terms that differentiate the patent's two independent claims. A central question will be whether the accused products embody the specific architecture of Claim 1 (with a distinct "power injector") or Claim 4 (with a "power supply circuit integrated with said amplifier"), or neither. The subtle but critical differences in these claim structures may be dispositive.