Shenzhen Liqiu Sanhou Technology Co Ltd v. Xiaoling Che

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Liqiu Sanhou Technology Co., Ltd. (People's Republic of China)
  • Defendant: Xiaoling Che (People's Republic of China)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 1:24-cv-11980, N.D. Ill., 11/20/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant targets business activities toward consumers in the district through Amazon's e-commerce store and has purposefully availed himself of the forum by previously filing a patent infringement lawsuit against other Amazon sellers in the same district.
• Core Dispute: This is a declaratory judgment action in which Plaintiff seeks a ruling that its "Puzzle Boards" do not infringe Defendant’s patent directed to a movable puzzle platform, and that the patent is invalid.
• Technical Context: The technology concerns apparatuses, specifically rotating platforms, designed to make assembling large jigsaw puzzles more convenient for users.
• Key Procedural History: The action was precipitated by a patent infringement complaint filed by the Defendant with Amazon.com, which resulted in the removal of Plaintiff's product listings. Plaintiff alleges this infringement complaint is "objectively baseless." The complaint notes Defendant has previously filed patent litigation in this district, which Plaintiff cites to support personal jurisdiction.

Case Timeline

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

U.S. Patent No. 11,890,551 - "Movable Puzzle Platform," Issued Feb. 6, 2024

The Invention Explained

• Problem Addressed: The patent's background section describes the logistical challenges of assembling large jigsaw puzzles, which require a large playing surface often exceeding a player's arm reach. This forces the player to physically move around the puzzle, and creates a risk of losing puzzle pieces over the extended time it may take to complete the puzzle (’551 Patent, col. 1:35-61).
• The Patented Solution: The invention is a platform for puzzle assembly that features a "board accessible unit" coupled to the bottom of the main puzzle board. This unit allows the entire puzzle board to slide and, critically, to self-rotate up to 360 degrees on a playing surface (’551 Patent, Abstract; col. 5:20-24). This design allows the player to remain stationary and simply move or rotate the board to work on different sections. The patent also describes embodiments with integrated drawers for storing unused pieces (’551 Patent, col. 6:61-65).
• Technical Importance: The patent purports to provide an "economic and efficient solution" that creates a more convenient tool for users to assemble large-scale puzzles without needing to move around the table or risk losing pieces (’551 Patent, col. 2:59-64).

Key Claims at a Glance

• The complaint focuses its non-infringement analysis on the sole independent claim, Claim 1.
• The essential elements of Claim 1 are:
  • A puzzle board with a top surface for placing puzzle pieces.
  • A board accessible unit comprising a first moving member coupled with the puzzle board, a second moving member, and a first bearing unit coupled between the first and second moving members.
  • The first moving member is rotatably mounted to the second moving member by the first bearing unit, enabling the puzzle board to be self-rotated on the playing surface.
  • The second moving member has a flat base and a protrusion from the center of the flat base toward the first moving member for engaging with the first bearing unit.
  • An outer circumferential surface of the first moving member is engaged with an inner circumferential surface of the second moving member via the first bearing unit to enable coaxial rotation.
• The complaint notes that if Claim 1 is not infringed, then dependent claims 2-6 cannot be infringed (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

• The accused products are Plaintiff's "Puzzle Boards," sold on Amazon under ASINs B0CQSZMJBS and B0C7QFLV8L (Compl. ¶1, 11).

Functionality and Market Context

• The complaint describes the accused Puzzle Boards as also featuring a turntable mechanism for rotation. However, Plaintiff alleges key structural differences from the patented invention. Specifically, Plaintiff asserts that its product's turntable is a separate, free-standing component that is "free and not coupled with the main body of puzzle board" (Compl. ¶20). Further, it is alleged to use a "snap-fit structure" for engagement between its moving members, rather than engagement between circumferential surfaces via a bearing unit (Compl. ¶22). The products are sold through the Amazon marketplace, which the Plaintiff describes as its "primary sales channel into the United States" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The following table summarizes the Plaintiff's (Sanhou-SH's) arguments for why its product does not infringe the Defendant's patent. This is a declaratory judgment action, so the "allegations" are contentions of non-infringement.

’551 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute will concern the meaning of "coupled with." Does this term require a physical attachment (e.g., via screws, adhesive, or magnets as described in the patent's specification), or could it be construed to cover a system where the board simply rests on top of a separate, unattached rotating base as allegedly implemented in the accused product?
  • Technical Questions: The complaint raises the question of whether the accused product's "snap-fit" mechanism performs the same function in the same way as the claimed engagement "via said first bearing unit." Evidence will be needed to determine if the load-bearing and rotational functions in the accused product are achieved through the snap-fit arms, the bearing balls, or a combination, and how that compares to the specific mechanism claimed in the patent. The allegation that the accused product lacks a "flat base" will also be a point of factual dispute.

V. Key Claim Terms for Construction

• The Term: "coupled with"

  • Context and Importance: This term is critical because the Plaintiff’s core non-infringement argument rests on its assertion that its puzzle board and turntable are separate, unattached components. The outcome of the case may depend on whether placing a board on top of a base unit satisfies the "coupled with" limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The parties may dispute the breadth of the term. A defendant might argue that the general meaning of "coupled" can include a close, functional relationship without permanent attachment.
    • Evidence for a Narrower Interpretation: The patent specification repeatedly describes methods of attachment, such as using screws, magnetic elements, or self-adhering film to "detachably couple" the accessible unit to the puzzle board, which may support an interpretation requiring some form of physical connection (e.g., ’551 Patent, col. 6:8-23, col. 6:24-41, col. 6:42-59).

• The Term: "engaged with ... via said first bearing unit"

  • Context and Importance: Plaintiff argues its moving members are engaged via snap-fit arms and that the circumferential surfaces themselves do not touch, creating a "gap" (Compl. ¶22, p. 8). The construction of this entire phrase will determine whether the accused product's mechanism falls within the claim scope. Practitioners may focus on this term because it defines the specific mechanism of rotation, which the Plaintiff has highlighted as a key structural difference.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A patentee could argue that "via" does not require the bearing unit to be the sole point of contact, but rather the means by which the engagement facilitates rotation, even if other structures are present.
    • Evidence for a Narrower Interpretation: The claim requires engagement of the circumferential surfaces and specifies this engagement happens via the bearing unit. The patent describes the bearing unit as being "rotatably sandwiched between the first and second moving members" (’551 Patent, col. 10:4-7). This language may support an interpretation where the bearings are the direct interface facilitating the rotational engagement of the surfaces, a structure Plaintiff alleges its product lacks.

• The Term: "flat base"

  • Context and Importance: Plaintiff explicitly alleges its product's second moving member has an "uneven base," not a "flat base" (Compl. ¶21). This presents a direct factual conflict with the claim language.
  • Intrinsic evidence for Interpretation:
    • Evidence for a Broader Interpretation: A patentee might argue that "flat" should be interpreted relative to the overall structure and that minor grooves or contours for bearings do not negate its essential flatness.
    • Evidence for a Narrower Interpretation: The complaint's visual evidence shows a distinct, grooved channel for the bearing balls (Compl. p. 6). Plaintiff will likely argue that in the context of mechanical components, "flat" has a plain and ordinary meaning that excludes such features.

VI. Other Allegations

• Invalidity: The complaint seeks a declaratory judgment that all claims of the '551 Patent are invalid under 35 U.S.C. §§ 102, 103, and 112 (Compl. ¶29). It specifically alleges that claim limitations such as "a protrusion ... for engaging with the first bearing unit" and the mechanism for engagement between the circumferential surfaces are indefinite under § 112(b) and lack adequate written description and enablement under § 112(a) (Compl. ¶36-39).
• Tortious Interference: The complaint includes counts for Tortious Interference with Contractual Relations and Prospective Economic Advantage (Compl. ¶42-62). Plaintiff alleges that Defendant knew of its contractual relationship with Amazon and intentionally interfered by making "materially false allegations of patent infringement" in order to have Plaintiff's product listings removed and to eliminate competition (Compl. ¶46, 56).

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

• A core issue will be one of structural definition: Does the claim term "coupled with" require physical attachment, as suggested by the patent’s embodiments, or can it be construed to read on the accused product's two-piece system where the board merely rests on a separate, unattached turntable?
• A key evidentiary question will be one of mechanical function: Does the accused product's alleged "snap-fit" engagement mechanism, which allegedly creates a "gap" between circumferential surfaces, function in a manner consistent with the claim limitation requiring the surfaces to be "engaged with ... via said first bearing unit"?
• Should the non-infringement arguments falter, the focus will shift to validity: Does the patent's specification provide sufficient detail for a person of ordinary skill in the art to understand and practice the claimed "protrusion" and its engagement with the bearing unit, or is the claim language fatally indefinite or inadequately described as the complaint alleges?