DCT

1:25-cv-04946

Xiaoling Che v. Shen Zhen Nuo BEI Shi Chuang Yi Fa Zhan Co Ltd

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-04946, N.D. Ill., 05/05/2025
  • Venue Allegations: Plaintiffs allege venue is proper because the defendants are not residents of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s puzzle boards, sold in the U.S. via Amazon.com, infringe a patent related to a movable puzzle platform with integrated storage drawers.
  • Technical Context: The technology at issue addresses accessories for jigsaw puzzle hobbyists, specifically integrated platforms that provide a work surface and storage for puzzle pieces, enhancing convenience for large or long-term projects.
  • Key Procedural History: The complaint references a prior case (1:25-cv-00845) in the same district, involving one of the current defendants and a related patent. Plaintiff alleges that the defendant in that case ignored a court order, which Plaintiff frames as a basis for establishing pre-suit knowledge and willfulness in the current litigation.

Case Timeline

Date Event
2021-09-26 U.S. Patent No. 12,220,648 Priority Date
2025-01-24 Related litigation filed (Case No. 1:25-cv-00845)
2025-02-11 U.S. Patent No. 12,220,648 Issued
2025-04-25 Court order issued in related litigation
2025-05-05 Complaint filed

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

U.S. Patent No. 12,220,648 - “Movable Puzzle Platform”

  • Patent Identification: U.S. Patent No. 12,220,648 (“Movable Puzzle Platform”), issued February 11, 2025 (the “’648 Patent”).

The Invention Explained

  • Problem Addressed: The patent background describes the challenges faced by individuals working on large-scale jigsaw puzzles, which require a significant, dedicated surface area. Key problems include the difficulty of reaching all parts of the puzzle, the need to sort and store numerous unused pieces, and the risk of losing pieces over the extended time it may take to complete the project (’648 Patent, col. 1:39-67).
  • The Patented Solution: The invention is a self-contained puzzle platform designed to solve these issues. It consists of a main puzzle board with a raised peripheral edge ("restricting wall") to contain the pieces, integrated with an underlying "supplement arrangement" that forms cavities for multiple sliding drawers (’648 Patent, Abstract). These drawers allow for the sorting and secure storage of unused puzzle pieces. Some embodiments also include a rotating assembly to allow the user to easily turn the entire board, improving access to all sections of the puzzle (’648 Patent, Fig. 3; col. 6:1-17).
  • Technical Importance: The patented solution combines a stable work surface, piece-sorting and storage capabilities, and mobility into a single, integrated apparatus, addressing several common frustrations for puzzle hobbyists (’648 Patent, col. 2:1-4).

Key Claims at a Glance

  • The complaint asserts independent claims 10 and 17 (’648 Patent, col. 25:20-26:54; Compl. ¶14).
  • Independent Claim 10 requires:
    • A board assembly with a puzzle board, a supplement arrangement, and a restricting wall.
    • The supplement arrangement includes a "first main supporting wall."
    • The assembly includes "at least two puzzle drawers" that slide in and out of a cavity formed by the supplement arrangement.
    • Critically, the claim requires a "rotating assembly attached on the board assembly."
  • Independent Claim 17 requires:
    • A puzzle board, a supplement arrangement, and a restricting wall.
    • The supplement arrangement includes a "first main supporting wall" and a "first dividing supporting wall."
    • The arrangement also includes a "first inner supporting wall...for improving the structural strength of the puzzle board."
    • The assembly includes "at least one puzzle drawer."
    • This claim does not require a rotating assembly.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies several "Accused Products," which are puzzle boards sold by the defendants on Amazon.com under various store names and Amazon Standard Identification Numbers (ASINs) (Compl. ¶14).

Functionality and Market Context

  • The accused products are described as materially identical puzzle boards designed for 1,000 or 1,500-piece puzzles (Compl. ¶16). Their core function is to provide a surface for puzzle assembly while incorporating drawers for storing puzzle pieces. The complaint alleges all accused products are sourced from the same supplier and ship with identical assembly instructions (Compl. ¶15). The primary difference noted between the product versions is their size and the shape of their drawers (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references an infringement claim chart in Exhibit C, which was not available for this analysis (Compl. ¶16). The narrative infringement theory alleges that the defendants' puzzle boards directly map onto the structural elements of the asserted claims. The complaint asserts that the defendants have directly infringed by making, using, and selling these products in the United States (Compl. ¶14). For indirect infringement, the plaintiff alleges that the defendants induce infringement by providing customers with assembly instructions (Compl. ¶21).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A primary point of contention for claim 10 will be whether the accused products include a "rotating assembly." The complaint does not specify if the accused products have this feature. If they lack a component that meets the legal definition of a "rotating assembly," they cannot infringe claim 10.
    • Technical Questions: Claim 17 requires a "first inner supporting wall" that serves the function of "improving the structural strength of the puzzle board." A potential dispute is whether any internal dividers in the accused products meet this functional requirement, or if they merely serve as partitions to create drawer cavities without contributing meaningfully to the board's structural integrity.

V. Key Claim Terms for Construction

The Term: "rotating assembly" (Claim 10)

  • Context and Importance: This term appears to be a critical limitation differentiating claim 10 from claim 17. The presence or absence of a feature meeting this definition in the accused products could be dispositive for infringement of claim 10. Practitioners may focus on this term because its construction will determine whether a simple feature like casters, or only a more complex mechanism, falls within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, not specifying any particular structure for the "rotating assembly." The specification describes the assembly's function as enabling the user to "selectively rotate the board assembly 90" without walking around it (’648 Patent, col. 12:58-64), which could support construing the term to cover any mechanism achieving this result.
    • Evidence for a Narrower Interpretation: The patent discloses specific embodiments of the "rotating assembly" (20) comprising "a first moving member 21," "a second moving member 22," and a "bearing unit 23" (’648 Patent, col. 12:46-54; Figs. 13-14). A defendant may argue that the term should be construed to require, at a minimum, a multi-component mechanism engineered for rotation, rather than any feature that simply reduces friction.

The Term: "supporting wall...for improving the structural strength" (Claim 17)

  • Context and Importance: This term recites a function, which requires that the accused structure not only exist but also perform the stated role. The dispute will likely center on whether the internal partitions of the accused products are merely dividers or if they are structurally significant.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the "supporting portion 301 is configured for improving the structural strength" because the puzzle board is of a "thin and big size" (’648 Patent, col. 8:31-38). This context suggests that any internal webbing or partitioning added to such a board would inherently improve its resistance to flexing and thus meet the functional requirement.
    • Evidence for a Narrower Interpretation: The patent describes a detailed framework of "first main supporting wall," "first dividing supporting wall," and "first inner supporting wall," implying a robust, engineered structure (’648 Patent, col. 26:22-44). A defendant could argue that this language requires a structure specifically designed and necessary for structural support, beyond any incidental stiffening provided by simple drawer dividers.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement to infringe, stating that defendants provide assembly instructions that "instruct and otherwise encourage their customers to... use the Accused Products" in an infringing manner (Compl. ¶21). The allegations specifically mention instructions to install wheels, suggesting this user-completed assembly step may be necessary to meet certain claim limitations (Compl. ¶21).
  • Willful Infringement: Willfulness allegations are based on purported pre-suit knowledge of the ’648 Patent (Compl. ¶23). This knowledge is inferred from prior litigation (Case No. 1:25-cv-00845) involving a patent from the same family and at least one of the same defendants (Compl. ¶¶18, 20). The complaint contends that because the patents are related and the products are from the same supplier, all defendants had or should have had knowledge, and that their continued infringement is egregious and willful (Compl. ¶¶23-24).

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

  • A core issue will be one of structural correspondence: Do the accused products incorporate the specific, multi-part internal framework recited in Claim 17, including distinct "main," "dividing," and "inner" supporting walls, or is their construction simpler in a way that avoids this limitation?
  • A key evidentiary question will be one of functional performance: Does the internal structure of the accused products perform the claimed function of "improving the structural strength" as required by Claim 17, or does it merely partition space for drawers? Resolution will likely require expert analysis of the accused products' design and materials.
  • For Claim 10, the case may turn on a question of definitional scope: Assuming the accused products have a feature enabling them to be turned, does that feature rise to the level of a "rotating assembly" as the term is properly construed in light of the patent's specification and figures?