DCT
1:24-cv-08789
Shenzhen Huanyusheng Technology Co Ltd v. Mavir
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Huanyusheng Technology Co., Ltd. and 15 other entities (China & U.S.)
- Defendant: Mavir (China)
- Plaintiff’s Counsel: J. Zhang and Associates, P.C.
- Case Identification: 1:24-cv-08789, N.D. Ill., 09/26/2024
- Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign business, has allegedly committed tortious acts in Illinois, and has targeted businesses and individuals in the district.
- Core Dispute: A collective of e-commerce sellers seeks a declaratory judgment that their 360-degree photo booth products do not infringe the Defendant’s patent, following infringement complaints filed by the Defendant on the Amazon marketplace.
- Technical Context: The technology concerns the structural design of the standing platform for 360-degree photo booths, aiming to reduce weight and manufacturing cost while maintaining structural integrity.
- Key Procedural History: This action arises from infringement complaints filed by Defendant Mavir against the Plaintiffs on Amazon, leading to the delisting of Plaintiffs' products. The complaint alleges that Mavir is not the true owner of the patent-in-suit, which public records show is assigned to another entity, and that Mavir has engaged in bad faith conduct.
Case Timeline
| Date | Event |
|---|---|
| 2021-11-29 | Earliest Priority Date Claimed for '741 Patent |
| 2024-07-23 | U.S. Patent No. 12,042,741 Issues |
| 2024-08-22 | Defendant allegedly begins filing Amazon Infringement Complaints |
| 2024-09-26 | Plaintiffs file First Amended Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,042,741 - "Photo Booth Having Supporting Stage"
The Invention Explained
- Problem Addressed: The patent addresses the problem that stage upper covers for 360-degree photo booths are often manufactured to be thick and heavy to ensure structural strength. This makes the devices costly and difficult to transport (’741 Patent, col. 1:19-29).
- The Patented Solution: The invention proposes a two-part supporting stage: a potentially thin "upper cover" for the user to stand on, and a separate "reinforcement frame" underneath that provides the necessary structural support (’741 Patent, Abstract). This design, as illustrated in the exploded view of Figure 3, allows the upper cover to be lighter and potentially detachable for easier maintenance, which is described as a way to avoid waste, save energy, and protect the environment (’741 Patent, col. 2:14-33; Fig. 3).
- Technical Importance: This approach seeks to make 360-degree photo booths lighter, less expensive, and more modular for maintenance without compromising the safety and durability of the standing platform (’741 Patent, col. 2:20-28).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1 (Compl. ¶45).
- Essential elements of independent claim 1 include:
- A photo booth having a supporting stage, comprising:
- the supporting stage;
- a rotatable shooting stand; and
- a driving assembly;
- wherein the driving assembly is configured to drive the rotatable shooting stand to circumferentially rotate around the supporting stage; the supporting stage comprises an upper cover and a reinforcement frame; the reinforcement frame comprises a connecting portion and supporting rods; a first end of each of the supporting rods is connected to the connecting portion; and the supporting rods are disposed along a circumferential direction of the connecting portion.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as "photographic camera devices, including 360-degree photo booths," sold by the sixteen Plaintiffs on their respective Amazon storefronts (Compl. ¶21). The complaint collectively refers to them as the "Accused Products" (Compl. ¶21, p. 6).
Functionality and Market Context
- The Accused Products are 360-degree photo booths that Plaintiffs allege they sell with "considerable commercial success" on Amazon (Compl. ¶31). The complaint alleges that all Plaintiffs sell "identical photographic camera devices under different brand names" (Compl. ¶32). A key allegation regarding their technical functionality is that they utilize a different structural design for the base platform than what is claimed in the patent, specifically one that does not contain a "reinforcement frame" as a distinct component (Compl. ¶36, ¶47). A photograph provided in the complaint shows the base of an accused product as a single, molded piece with integrated ribbing on its underside (Compl. p. 6).
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment of non-infringement, the following table summarizes the Plaintiffs' primary arguments for why their products do not meet the limitations of the asserted patent claim.
- ’741 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| the supporting stage comprises an upper cover and a reinforcement frame | Plaintiffs allege their products "do not contain a reinforcement frame," stating they "lack this structure, regardless of how the term 'reinforcement frame' is construed." The product is described as having only a "supporting plate without the reinforcement frame." | ¶47, ¶49 | col. 6:0-4 |
| the reinforcement frame comprises a connecting portion and supporting rods | The complaint asserts that the Accused Products lack the entire reinforcement frame, and therefore necessarily lack its constituent parts like the connecting portion and supporting rods as described in the patent. | ¶47, ¶50 | col. 6:5-10 |
| [Implicit feature from embodiment] the upper cover comprises a supporting plate 111 and a ring edge 112 | The complaint alleges that, in contrast to the patent's embodiment, the Accused Products' design "does not feature this 'ring edge' (112)" and consists of a supporting plate without this additional structural feature. The complaint includes a visual comparison to support this point. (Compl. p. 14). | ¶49 | col. 4:40-43 |
- Identified Points of Contention:
- Scope Questions: A central question is whether the integrated ribbing on the underside of the Plaintiffs' single-piece platform constitutes a "reinforcement frame" that is part of a "supporting stage" which also has an "upper cover." The patent itself discloses an embodiment where "the upper cover and the reinforcement frame are integrally formed" (’741 Patent, Claim 3), a point not addressed by the complaint but which may support the Defendant's position that a single-piece construction can still infringe.
- Technical Questions: The dispute raises the question of whether the Plaintiffs' single-piece base is structurally and functionally distinct from the two-part system claimed in the patent. Evidence will be needed to compare the construction of the Accused Products with the patent's teachings, particularly the specific arrangement of a "connecting portion" and "supporting rods" within the claimed frame.
V. Key Claim Terms for Construction
- The Term: "reinforcement frame"
- Context and Importance: This term is the core of the non-infringement dispute. Plaintiffs' case hinges on their argument that their products completely lack this element (Compl. ¶47). The definition of what constitutes a "reinforcement frame"—specifically, whether it must be a structurally distinct component from the "upper cover"—will be dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant could point to claim 3, which explicitly claims a photo booth where "the upper cover and the reinforcement frame are integrally formed." This language suggests the two elements do not need to be separate, separable, or made of different materials to fall within the patent's scope. The term "reinforcement frame" could be construed to cover any system of ribbing or supports, even if molded as part of a single unit with the top surface.
- Evidence for a Narrower Interpretation: Plaintiffs may argue that the specification consistently describes the "reinforcement frame" (120) and "upper cover" (110) as two distinct components, as shown in the exploded diagram of Figure 3 (’741 Patent, Fig. 3). The patent’s summary emphasizes that the cover "detachably covers" the frame to provide "great convenience for maintenance," which supports the interpretation of two separate, interacting parts (’741 Patent, col. 2:27-32).
VI. Other Allegations
- Tortious Interference: The complaint includes formal counts for tortious interference with contract and prospective business expectancy (Compl. ¶52-62). Plaintiffs allege that the Defendant, with knowledge of Plaintiffs' contractual relationship with Amazon, intentionally filed "bad faith Amazon Infringement Complaints" with the knowledge that the patent was not infringed (Compl. ¶55, ¶61). These actions allegedly induced Amazon to breach its agreements by delisting Plaintiffs' products, causing economic harm (Compl. ¶56-57).
- Exceptional Case: Plaintiffs request a declaration that the case is exceptional under 35 U.S.C. § 285, which would entitle them to attorneys' fees (Compl., Prayer for Relief ¶G). The basis for this allegation appears to be the "bad faith" and "false" nature of the infringement complaints, particularly the assertion that the complaining party, MAVIR, is not the patent's recorded assignee (Compl. ¶39a, ¶55).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: does the term "reinforcement frame", when read in light of the entire patent, require a component that is structurally separate or separable from the "upper cover", or can it be construed to read on the integrated support ribbing of the Plaintiffs' single-piece platform, particularly given the patent's own disclosure of an "integrally formed" embodiment?
- A second critical issue concerns standing and bad faith: what is the legal significance of the allegation that the Defendant (MAVIR) who filed the Amazon complaints is not the patent's recorded assignee ("Marvel Technology (China) Co., Ltd.")? This raises threshold questions about the legitimacy of the initial enforcement actions and may heavily influence the court's analysis of the tortious interference and exceptional case claims.