Xiaoling Che v. Shenzhen Mumuwan Maoyi Youxian Gong Si

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Xiaoling Che and Jinyan Duan (China)
  • Defendant: Shenzhen Ximeikeji Youxian Gongsi; Shenzhen Mumuwan Maoyi Youxian Gong Si; QingYunXianGeSiWeiShangMaoYouxianGongSi; and Shenzhen Mengdudu Chongwu Yongpin Youxian Gongsi (China)
  • Plaintiff’s Counsel: RIMON P.C.
• Case Identification: 1:25-cv-04946, N.D. Ill., 05/08/2025
• Venue Allegations: Venue is asserted on the basis that none of the defendants are residents of the United States, and therefore may be sued in any judicial district.
• Core Dispute: Plaintiffs allege that Defendants’ puzzle boards, sold in the United States through Amazon.com, infringe a patent related to a movable puzzle platform with integrated storage drawers.
• Technical Context: The technology concerns puzzle accessories, specifically large platforms designed to facilitate the assembly and storage of jigsaw puzzles, a significant niche in the hobby and games market.
• Key Procedural History: The complaint references a prior case (1:25-cv-00845) filed by one of the current defendants, *Xiaoling Che v. Shenzhen Mumuwan Maoyi Youxian Gong Si*, concerning a related U.S. Patent No. 12,048,885. Plaintiffs allege that the defendant in that case ignored a court order, which Plaintiffs characterize as a tacit admission of infringement and a basis for knowledge of the patent family.

Case Timeline

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 (’648 Patent).

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of working on large jigsaw puzzles, which require a large, dedicated surface and often take days or months to complete. During this time, puzzle pieces can be easily lost, and the large board can be cumbersome to move or store (’648 Patent, col. 1:40-66).
• The Patented Solution: The invention is a platform for puzzle assembly that incorporates a main puzzle board with an underlying support structure that forms multiple drawer cavities. Puzzle drawers slide into these cavities, allowing for the storage and sorting of unused pieces. The entire platform is supported by a rotating assembly, allowing the user to rotate the board to access different sections of the puzzle without moving around the table (’648 Patent, col. 6:1-17; Fig. 3).
• Technical Importance: This integrated approach of a large, rotatable work surface with built-in piece storage addresses key usability issues for serious puzzle enthusiasts, combining organization, workspace management, and ergonomics in a single product (’648 Patent, col. 2:1-4).

Key Claims at a Glance

• The complaint asserts independent claims 10 and 17 (Compl. ¶14).
• Independent Claim 10:
  • a board assembly comprising a puzzle board and a supplement arrangement with a supporting wall;
  • a restricting wall extending upwardly from the puzzle board;
  • at least two puzzle drawers;
  • a rotating assembly attached on the board assembly;
  • wherein a fixing portion of the puzzle board is stacked on the supporting wall; and
  • wherein the supplement arrangement and puzzle board cooperate to form at least one drawer cavity for the puzzle drawers.
• Independent Claim 17:
  • a puzzle board with a fixing portion;
  • a supplement arrangement with a first main supporting wall and a first dividing supporting wall;
  • a restricting wall with a first extending wall;
  • at least one puzzle drawer;
  • wherein the first extending wall and fixing portion are successively stacked on the first main supporting wall; and
  • the supplement arrangement includes a first inner supporting wall for improving structural strength.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The Accused Products are puzzle boards sold under various Amazon store names, including "XM Official," "Woodever Direct," "GeSiWeiShangMao," and "PetMagic Shop" (Compl. ¶14).

Functionality and Market Context

• The complaint alleges that all Accused Products are materially identical puzzle boards, sourced from the same supplier, and are designed for either 1,000 or 1,500 piece puzzles (Compl. ¶¶15-16). The primary difference between the versions is size and the shape of the puzzle drawers (Compl. ¶16). The complaint identifies specific Amazon Standard Identification Numbers (ASINs) for each defendant's products in a table. This table visually links each named defendant to a specific product listing (Compl. ¶14, p. 4). The products are marketed and sold to residents in the Northern District of Illinois through Amazon.com (Compl. ¶10).

IV. Analysis of Infringement Allegations

The complaint references an infringement claim chart as Exhibit C but does not attach it to the pleading provided for analysis (Compl. ¶16). Therefore, the infringement theory is summarized below in prose based on the complaint's narrative allegations.

’648 Patent Infringement Allegations

The complaint alleges that the Accused Products directly infringe at least claims 10 and 17 of the ’648 Patent (Compl. ¶14). The narrative suggests that the Accused Products embody the key features of the asserted claims: they are puzzle boards that include a main work surface, an underlying structure that forms cavities, and drawers that slide into those cavities for piece storage (Compl. ¶¶14, 16). The complaint's assertion of claim 10 further suggests an allegation that the products include a rotating assembly (Compl. ¶14). The allegation of infringement is supported by reference to a representative claim chart, which is not included in the complaint itself (Compl. ¶16).

• Identified Points of Contention:
  • Scope Questions: A potential issue may be whether the structure of the Accused Products meets the specific structural definitions in the claims. For example, does the accused structure have a "first main supporting wall" and a separate "first dividing supporting wall" as required by claim 17, or do these functions merge into a single component?
  • Technical Questions: For claim 10, a key factual question will be whether all Accused Products include a "rotating assembly attached on the board assembly." The complaint's general description does not detail this component, which is a specific limitation of claim 10. The complaint also alleges infringement under the doctrine of equivalents, which may become relevant if there are technical differences in how the accused drawers, support walls, or rotating mechanisms are constructed compared to the literal claim language (Compl. ¶14).

V. Key Claim Terms for Construction

• The Term: "a rotating assembly attached on the board assembly" (Claim 10)

  • Context and Importance: This term is central to claim 10. The nature of the "attachment" will be a key point of dispute. Practitioners may focus on this term because if the rotating assembly is, for example, a separate, unattached lazy-susan base that the board simply rests upon, it may not meet the "attached on" limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the rotating assembly as being "attached on the board assembly 90" and "coupled at the base 40," which could suggest that attachment to any part of the overall structure, including the base, satisfies the limitation (’648 Patent, col. 6:8, col. 13:3-4).
    • Evidence for a Narrower Interpretation: The figures and detailed description consistently show the rotating assembly (20) as a distinct component mechanically fastened to the supplement arrangement (30) or base (40) which are, in turn, fixed to the puzzle board (10) (’648 Patent, Fig. 2; col. 12:43-54). This could support an argument that "attached on" requires a direct or indirect fixed connection, not merely resting upon.

• The Term: "a first dividing supporting wall" (Claim 17)

  • Context and Importance: Claim 17 recites multiple distinct wall structures: a "first main supporting wall," a "first dividing supporting wall," and a "first inner supporting wall." The infringement analysis for this claim will depend on whether the Accused Products contain these distinct, separately identifiable structures.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "wall" is used generally, and one could argue that any vertical member that serves to both support the puzzle board and divide a drawer cavity meets the definition, even if it is part of a larger, unitary structure.
    • Evidence for a Narrower Interpretation: The patent specification and figures depict these walls as distinct elements with specific locations and connections (e.g., "first dividing supporting wall 313" and "first main supporting wall 311" in Fig. 5). This suggests that the claim requires structurally separate components, and a defendant may argue that its product, which might use a monolithic molded base, does not have the claimed plurality of distinct walls (’648 Patent, col. 8:1-15).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that to the extent wheels are not pre-assembled, Defendants instruct customers to install them via assembly instructions, thereby encouraging customers to make and use the infringing product (Compl. ¶21).
• Willful Infringement: Willfulness is alleged based on pre-suit knowledge. The complaint argues that Defendants knew of the ’648 patent because it is related to U.S. Patent No. 12,048,885, which was the subject of a prior lawsuit involving one of the defendants. Plaintiffs allege that the defendant's failure to litigate the prior case constitutes a "tacit admission" of infringement for the related patent family, thus establishing knowledge (Compl. ¶¶18-20, 23-24).

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

• A core issue will be one of structural correspondence: Do the accused puzzle boards, allegedly sourced from a single manufacturer, possess the specific, multi-part wall and support architecture recited in the independent claims (e.g., distinct "main," "dividing," and "inner" supporting walls), or does their construction differ in a way that avoids literal infringement?
• A key evidentiary question will be one of pre-suit knowledge: Can knowledge of a related patent, combined with a party's litigation conduct in a separate case involving that patent, be sufficient to establish the knowledge and intent required for willful and induced infringement of the patent-in-suit?
• A dispositive technical question for claim 10 will be one of component presence and attachment: Do all of the Accused Products in fact include a "rotating assembly," and if so, is that assembly "attached on" the board assembly in the manner required by the claim, or does it function as a separate, unattached base?