DCT
1:24-cv-11570
Guangdong Aoyun Technology Co Ltd v. Partnerships Unincorp Associations
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangdong Aoyun Technology Co Ltd. (China)
- Defendant: The Partnerships and Unincorporated Associations Identified on Schedule “A” (Various foreign jurisdictions)
- Plaintiff’s Counsel: Palmer Law Group, P.A.
- Case Identification: 1:24-cv-11570, N.D. Ill., 11/10/2024
- Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendants target business activities to consumers in the United States, including Illinois, through interactive e-commerce stores.
- Core Dispute: Plaintiff alleges that Defendants’ “Combined Type Hand Warmer” products, sold through various online storefronts, infringe a patent related to a modular, separable hand warmer design.
- Technical Context: The technology concerns portable electronic hand warmers that can be separated into two distinct units for individual use or combined into a single larger unit.
- Key Procedural History: The complaint is filed against a schedule of unidentified defendants, a common procedural posture in actions targeting diffuse online sellers who allegedly operate under multiple aliases to conceal their identities. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2022-08-05 | ’334 Patent Priority Date |
| 2024-02-27 | ’334 Patent Issue Date |
| 2024-11-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 11,916,334, “Combined Type Hand Warmer,” issued February 27, 2024.
The Invention Explained
- Problem Addressed: The patent’s background section identifies a limitation in conventional hand warmers, which are typically single-unit devices, making it "difficult to warm both hands/multiple body parts at the same time" (’334 Patent, col. 1:17-20). This is particularly true when a user needs to perform different actions with each hand (’334 Patent, col. 1:20-23).
- The Patented Solution: The invention is a hand warmer composed of a "first hand warmer unit" and a "second hand warmer unit" that are "detachably connected" (’334 Patent, Abstract). This allows the user to either combine the units into a single, larger warmer or separate them for warming two hands or body parts independently, thereby satisfying a "plurality of use scenarios" (’334 Patent, col. 2:46-64; FIG. 2). The connection is achieved via corresponding mechanical parts on each unit (’334 Patent, col. 1:36-43).
- Technical Importance: The modular design aims to provide greater flexibility and user convenience compared to monolithic hand warmers (’334 Patent, col. 2:60-64).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶25).
- The essential elements of independent Claim 1 are:
- A combined type hand warmer, comprising a first hand warmer unit and a second hand warmer unit;
- a first connection part is arranged on the first hand warmer unit, and a second connection part is arranged on the second hand warmer unit;
- the first connection part is detachably connected to the second connection part such that the two units are combined into a whole;
- the first connection part comprises a first buckle, and the second connection part comprises a first buckle slot, where the first buckle is detachably plugged to the first buckle slot;
- the first connection part further comprises a second buckle slot, and the second connection part further comprises a second buckle;
- when the first buckle is plugged to the first buckle slot, the second buckle is detachably plugged to the second buckle slot.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused products are identified as the "Combined Type Hand Warmer" or the "Infringing Products" (Compl. ¶3).
Functionality and Market Context
The complaint alleges that Defendants are making, using, selling, and/or importing unauthorized products that practice the patented invention (Compl. ¶3, ¶25). These products are allegedly sold through numerous e-commerce stores operating under various "Seller Aliases" (Compl. ¶4). The complaint asserts that these stores share common features and that the sellers are interrelated, operating as part of a coordinated effort to sell infringing goods while concealing their identities (Compl. ¶19). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not provide a detailed claim chart or specific description of how the accused products operate. It makes a conclusory allegation that "[u]pon examination of the Infringing Product, each element of claim 1 of the ‘334 patent is met and practiced by the Infringing Products" (Compl. ¶25). The following table summarizes this general allegation against the elements of Claim 1.
’334 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A combined type hand warmer, comprising a first hand warmer unit and a second hand warmer unit... | The complaint alleges the Infringing Products are combined type hand warmers with two separable units. | ¶25 | col. 6:18-19 |
| a first connection part is arranged on the first hand warmer unit, and a second connection part is arranged on the second hand warmer unit... | The complaint alleges the Infringing Products possess corresponding connection parts on each unit. | ¶25 | col. 6:19-22 |
| the first connection part is detachably connected to the second connection part such that the first hand warmer unit and the second hand warmer unit are combined into a whole... | The complaint alleges the connection parts of the Infringing Products are detachably connected. | ¶25 | col. 6:22-25 |
| wherein the first connection part comprises a first buckle, and the second connection part comprises a first buckle slot; and the first buckle is detachably plugged to the first buckle slot... | The complaint alleges the Infringing Products possess a first buckle and first buckle slot mechanism. | ¶25 | col. 6:26-30 |
| wherein the first connection part further comprises a second buckle slot, and the second connection part further comprises a second buckle; and when the first buckle is detachably plugged to the first buckle slot, the second buckle is detachably plugged to the second buckle slot. | The complaint alleges the Infringing Products possess a second buckle and second buckle slot mechanism that engages concurrently with the first. | ¶25 | col. 6:30-34 |
Identified Points of Contention
- Evidentiary Question: As the complaint lacks any images or technical descriptions of the accused products, a threshold issue for the court will be whether the Plaintiff can produce an accused product and provide sufficient evidence to demonstrate that it practices each specific limitation of Claim 1.
- Technical Questions: A key question will concern the structure of the connection mechanism. The infringement analysis will depend on whether the accused products’ connection parts can be fairly characterized as having the dual "buckle" and "buckle slot" configuration required by Claim 1.
V. Key Claim Terms for Construction
- The Term: "buckle" and "buckle slot"
- Context and Importance: These terms are at the heart of the claimed invention, defining the specific mechanical means for the detachable connection. The construction of these terms will determine whether the claim scope is limited to a specific type of physical interlock or can read on a wider variety of connection mechanisms.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not recite additional structural details for the "buckle" or "buckle slot," which may support an interpretation based on their plain and ordinary meaning as a form of fastener (’334 Patent, col. 6:26-34).
- Evidence for a Narrower Interpretation: The specification describes a detailed embodiment where the connection involves not just buckles and slots, but also "positioning pillar[s]" (33, 44), "positioning hole[s]" (43, 34), and "guide slot[s]" (35, 45) that work in concert (’334 Patent, col. 4:36-65; FIGS. 4-5). A party could argue that these detailed descriptions in the sole embodiment inform and limit the meaning of "buckle" and "buckle slot" to the more complex interlocking system disclosed.
VI. Other Allegations
- Indirect Infringement: While the complaint’s single count is for direct infringement under 35 U.S.C. § 271 (Compl. ¶24-28), the prayer for relief seeks to enjoin Defendants from "aiding, abetting, contributing to, or otherwise assisting anyone" in making or selling the Infringing Products (Prayer for Relief, ¶1(b)). The factual basis for such a claim appears to rest on general allegations that Defendants are "working in active concert" (Compl. ¶22).
- Willful Infringement: The complaint alleges that Defendants' infringement was "willful" (Compl. ¶23) and that they acted "knowingly and willfully" (Compl. ¶22). The asserted basis for this claim is not a specific pre-suit notice but rather the allegation that Defendants are part of a coordinated network that intentionally uses tactics like fictitious aliases to sell unauthorized goods and evade detection (Compl. ¶17-21).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of linkage and proof: can the Plaintiff connect the generic "Infringing Products" to the specific, unnamed "Schedule A" defendants and produce evidence demonstrating that the products sold by those entities practice the dual buckle-and-slot mechanism required by Claim 1?
- A core issue will be one of claim scope: will the terms "buckle" and "buckle slot" be construed broadly to cover any corresponding mechanical clasp, or will their meaning be limited by the specification’s detailed disclosure of a system that also includes positioning pillars and guide slots, potentially narrowing the scope of infringement?