DCT

1:24-cv-07144

Shenzhen Wuyishi Technology Co Ltd v. Eagle Fan

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-07144, N.D. Ill., 12/31/2025
  • Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the events giving rise to the claim occurred in the district, as Defendant's complaint to Amazon allegedly disrupted Plaintiff's sales to Illinois customers. Further, as a non-U.S. resident, Defendant may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant committed tortious interference with its contractual relationship with Amazon by knowingly lodging a baseless patent infringement complaint against Plaintiff's product, causing Amazon to remove the product listing.
  • Technical Context: The dispute centers on portable mounting devices designed to hold smartphones, particularly for hands-free viewing in environments like airplane or train seats.
  • Key Procedural History: The central event is Defendant's use of Amazon's Patent Evaluation Express ("APEX") program, an internal Amazon process for patent holders to report infringement. Plaintiff alleges Defendant filed false infringement claims through this system, which does not adjudicate patent validity, leading to the "automatic removal" of Plaintiff's product listing without judicial review.

Case Timeline

Date Event
2018-10-26 ’847 Patent Priority Date
2019-04-30 ’847 Patent Issue Date
2024-02-24 Defendant files initial APEX complaint with Amazon
2024-05-08 Defendant renews or continues APEX complaint assertion
2024-07-22 Amazon removes Plaintiff's product listing
2025-12-31 Complaint Filing Date

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

U.S. Patent No. 10,272,847 - *"Foldable Clamping Device"*

  • Issued: April 30, 2019 (’847 Patent)

The Invention Explained

  • Problem Addressed: The patent addresses the problem of travelers on long-distance mass transit, like planes or trains, experiencing physical discomfort (e.g., cervical spine pain, arm pain) from holding a mobile phone for extended periods to watch videos or conduct business (’847 Patent, col. 1:15-29). Existing seat structures are not typically equipped with devices to hold such gadgets (’847 Patent, col. 1:25-29).
  • The Patented Solution: The invention is a compact, foldable clamping device that can be attached to surfaces like a seat-back dining tray. It uses a series of pivot members and support members to allow for adjustable positioning (’847 Patent, col. 1:33-40). The design features a first support member with a clamping unit for the phone, and a second support member with a clamp for attaching to a surface, connected by two T-shaped pivot members that rotate on a common axis to allow for folding and angle adjustment (’847 Patent, col. 3:33-49; Fig. 1).
  • Technical Importance: The device's technical contribution appears to be its specific multi-pivot design, which allows it to be both highly adjustable for viewing and collapsible into a small, portable size for travel (’847 Patent, col. 1:40-50).

Key Claims at a Glance

  • The complaint does not explicitly assert any claims, but bases its non-infringement argument on the patent generally (Compl. ¶13). The patent's sole independent claim, Claim 1, is the presumed focus of the dispute.
  • Essential elements of Independent Claim 1 include:
    • A first support member with a clamping unit for a mobile phone, having a pivot end.
    • A first pivot member being a T-shaped body with a middle portion formed with a first extension element.
    • A second pivot member being a T-shaped body with a middle portion formed with a second extension element, connected to the first extension element to be rotatable about a common axis.
    • A second support member with a pivot end, including a stationary clamp arm and a movable L-shaped clamp arm biased to provide a clamping force.
    • Wherein the support members can be folded toward each other into a storage position.

III. The Accused Instrumentality

Product Identification

  • Plaintiff’s "Airplane Phone Holder" product, sold on Amazon under ASIN B0CGZXBSV2 (Compl. ¶2).

Functionality and Market Context

  • The complaint describes the accused product only as an "Airplane Phone Holder" and a consumer electronics accessory (Compl. ¶3-4). It alleges the product is "materially different from the device claimed in the '847 Patent" but does not provide specific technical details about the product's structure or mechanism of operation (Compl. ¶13). The complaint positions the product as a direct competitor to the Defendant's products in the online marketplace for smartphone mounting devices (Compl. ¶4, 18).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain affirmative infringement allegations or a claim chart. Instead, it asserts that Defendant's accusations of infringement were "knowingly false" and "baseless" because Plaintiff's product is "materially different" from the patented device (Compl. ¶13). The analysis below frames the potential points of contention based on the patent's claim language and the plaintiff's general assertion of non-infringement.

Identified Points of Contention

  • The dispute over infringement will likely center on whether the specific structural elements recited in Claim 1 of the ’847 Patent are present in the Plaintiff's "Airplane Phone Holder."
    • Scope Questions:
      • A primary question may be whether the Plaintiff's product contains pivot members that meet the claim limitation of a "T-shaped body including a middle portion formed with a first [and second] extension element." The specific geometry of a "T-shaped body" may be a focal point of claim construction and infringement analysis.
      • Another scope question may be whether the accused product's mechanism for clamping onto a surface (e.g., a tray table) meets the limitation of a "movable L-shaped clamp arm" that is biased against a "stationary clamp arm." If the accused product uses a different clamping structure, it may not read on this element.
    • Technical Questions:
      • The complaint does not provide sufficient detail for analysis of the technical operation of the accused product. A central evidentiary question for the court will be a direct comparison of the accused product's physical structure against the limitations of Claim 1.

V. Key Claim Terms for Construction

"T-shaped body"

  • Context and Importance: This term appears in Claim 1 to define the structure of both the first and second pivot members. The infringement analysis may depend on how narrowly or broadly this geometric term is defined. Practitioners may focus on this term because if the accused device's pivot members do not have a "T-shape," it could be a straightforward basis for a non-infringement finding.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification does not appear to provide an explicit definition beyond the term itself, which may suggest the term should be given its ordinary and customary meaning.
    • Evidence for a Narrower Interpretation: The figures, particularly Figure 5, show a specific embodiment of the pivot members (2, 3) with a distinct T-shape where the extension elements (21, 31) form the stem of the 'T' and the pivoting ends form the cross-bar (’847 Patent, Fig. 5). A defendant could argue that the term should be limited to a structure conforming to this depicted embodiment.

"movable L-shaped clamp arm"

  • Context and Importance: This term in Claim 1 defines a key component of the mechanism that clamps the entire device to a surface. The specific "L-shape" is a structural limitation. The case may turn on whether the accused product's corresponding clamp has this specific shape, as opposed to another configuration (e.g., a simple sliding jaw, a screw clamp, or a spring clip).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function of this arm as moving "linearly away from the stationary clamp arm" to create a clamping force, which could support interpreting the "L-shape" as being less restrictive than its literal geometry, focusing instead on its function within the assembly (’847 Patent, col. 5:1-4).
    • Evidence for a Narrower Interpretation: Figure 4 clearly depicts the movable clamp arm (42) with a distinct right-angle or "L" shape (’847 Patent, Fig. 4). This depiction provides strong evidence for construing the term as requiring this specific geometry, potentially excluding other shapes that perform a similar clamping function.

VI. Other Allegations

The complaint does not allege patent infringement but rather a tort based on allegedly false accusations of infringement.

Bad-Faith Enforcement

  • The core of the complaint is the allegation that Defendant's infringement assertions to Amazon were made in bad faith. Plaintiff alleges Defendant knew the accusations were false or acted with reckless disregard for the truth, as the accused product is "materially different" from the patented device (Compl. ¶13). The complaint alleges this was done with the "sole intent to harm Plaintiff" and "suppress competition" (Compl. ¶18-19).

Willful Infringement

  • Not applicable, as Plaintiff is not alleging infringement. The complaint alleges Defendant's tortious conduct was "willful, malicious, and without justification" (Compl. ¶2).

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

This case presents not as a direct patent infringement suit, but as a tort action where the question of infringement is a predicate issue. The central questions for the court will likely be:

  1. A core issue will be one of claim scope and non-infringement: Was the Defendant's accusation of infringement through Amazon's APEX program "objectively baseless"? This will require the court to effectively conduct a non-infringement analysis, focusing on whether the Plaintiff's "Airplane Phone Holder" contains the specific structural limitations of the ’847 Patent's claims, such as the "T-shaped" pivot members and the "L-shaped" clamp arm.
  2. A second key question will be one of subjective bad faith: Even if non-infringement is established, Plaintiff must prove that Defendant made the infringement accusation to Amazon knowing it was false or with reckless disregard for its truth, rather than from a genuinely held (though incorrect) belief of infringement. The outcome will likely depend on the evidence presented regarding the objective differences between the product and the patent claims, and what that evidence implies about the Defendant's state of mind.