Sichuan Maichuhai Intl Trading Co Ltd v. Wang

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sichuan Maichuhai International Trading Co., Ltd. (China)
  • Defendant: Lei Wang (China)
  • Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:25-cv-06070, N.D. Ill., 05/30/2025
• Venue Allegations: Plaintiff, the accused infringer, alleges venue is proper because the Defendant patent holder targets business activities toward Illinois customers via e-commerce platforms and directed its patent enforcement campaign at Plaintiff, causing harm in the district.
• Core Dispute: Plaintiff seeks a declaratory judgment of non-infringement and invalidity of Defendant's patent for a rechargeable luminous ball, following Defendant's submission of a patent infringement complaint against Plaintiff via Amazon's intellectual property enforcement program.
• Technical Context: The technology concerns recreational products, specifically sports balls that incorporate an internal, rechargeable light source for illumination.
• Key Procedural History: This lawsuit was filed in direct response to an accusation of patent infringement made by Defendant against Plaintiff on or about May 14, 2025, through Amazon's third-party enforcement process. The complaint notes that the parties were unable to resolve the matter, and Plaintiff opted out of Amazon's APEX program to seek a judicial declaration that considers invalidity defenses.

Case Timeline

Date	Event
2023-10-31	’617 Patent Priority Date
2025-02-25	’617 Patent Issue Date
2025-05-14	Defendant submits infringement complaint to Amazon
2025-05-30	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 12,220,617 - "RECHARGEABLE LUMINOUS BALL"

The Invention Explained

• Problem Addressed: The patent describes prior art luminous balls as suffering from drawbacks related to their power source. They either require regular replacement of batteries or use wireless charging, which is described as having low efficiency and high cost for replacing damaged components (’617 Patent, col. 1:17-25).
• The Patented Solution: The invention proposes a design for directly and conveniently recharging the ball. It consists of a luminous component (containing a battery, lamp, and charge port) that is secured within a cavity in the ball. This component is held in place by a "first cover cap" that is interference-fit with the cavity wall. This first cap features an opening, covered by a "second cover cap," which provides access to the charge port without having to remove the entire lighting assembly (’617 Patent, Abstract; col. 3:1-15).
• Technical Importance: The design aims to provide a rechargeable luminous ball with high charging efficiency and low usage cost by enabling direct, wired charging through a sealed, accessible port (’617 Patent, col. 2:20-25).

Key Claims at a Glance

• The complaint alleges non-infringement of "at least one claim" of the patent (Compl. ¶29). The patent contains one independent claim, Claim 1.
• Independent Claim 1 requires:
  • A ball with a plurality of cavities.
  • A luminous component comprising a luminous body, a battery, a lamp bead, and a charge port.
  • A first cover cap with a "luminous component fix groove" that is "interference-fit" with the luminous component.
  • The first cover cap also has an opening that is "interference-fit" with a second cover cap, with the charge port located below this opening.
  • The first cover cap is detachably connected to the cavity and "interference-fit with an inner wall of the cavity."
• The complaint does not specify any dependent claims but seeks a declaration of non-infringement and invalidity of all claims (Prayer for Relief ¶1-2).

III. The Accused Instrumentality

Product Identification

• The accused product is identified as a "Football" and "Non-Infringing Product," sold on Amazon under at least the ASIN B0F21J99GS (Compl. ¶3, ¶30).

Functionality and Market Context

• The complaint provides no technical description of the accused product's features or operation beyond its general identification as a "Football" (Compl. ¶3). The dispute's origin as an Amazon enforcement action suggests the product is a consumer good sold in the competitive e-commerce market, where product listings can be removed based on intellectual property complaints (Compl. ¶4, ¶17).

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or a detailed, element-by-element analysis of its non-infringement position. Instead, it makes broad assertions that its product does not infringe. The complaint avers that its "Non-Infringing Products do not infringe any claim of the '617 Patent under any recognized theory of liability" (Compl. ¶27) and that "Plaintiff does not perform all of the steps required by the claims of the '617 Patent" (Compl. ¶33).

No probative visual evidence provided in complaint.

Identified Points of Contention

Given the specificity of the patent claims and the generality of the complaint's denials, the infringement dispute may center on the following questions:

• Scope Questions: Does the term "ball" in the patent, which is described with an "exodermis, an interlayer, a yarn layer, and an inner liner layer" (’617 Patent, col. 6:8-12), read on the Plaintiff's accused "Football"? More critically, does the accused product possess the specific two-part cap structure recited in Claim 1, including a "first cover cap" with a "luminous component fix groove" and a separate "second cover cap"?
• Technical Questions: A key technical question may be whether the accused product utilizes an "interference-fit" to secure its components and seal the charging cavity, as required multiple times in Claim 1. The Plaintiff's non-infringement argument could be based on an alternative fastening or sealing mechanism (e.g., threading, adhesives, or a snap-fit that does not qualify as an interference-fit).

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis of claim construction disputes. However, based on the patent's text, the following terms may be central to the case.

The Term: "interference-fit"

• Context and Importance: This term appears three separate times in independent Claim 1, defining the relationship between: 1) the luminous component and its groove, 2) the second cover cap and its opening, and 3) the first cover cap and the cavity wall. The entire assembly's structural integrity and sealing depends on this limitation. Practitioners may focus on this term because a finding of non-infringement could arise if the accused product uses a different connection method.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which may support giving the term its plain and ordinary meaning in mechanical engineering, potentially encompassing a wide range of friction-based press-fits.
  • Evidence for a Narrower Interpretation: The specification links the interference-fit to specific functions, such as preventing liquid from entering to ensure "a certain degree of waterproofing" (’617 Patent, col. 3:5-10). A party could argue this functional context limits the term to fits that achieve a liquid-resistant seal, excluding looser connections.

The Term: "luminous component fix groove"

• Context and Importance: This term defines a specific structure on the "first cover cap" for holding the "luminous component". Its presence and form are likely to be a key point of comparison. A non-infringement argument could be that the accused product secures its light source via a different structure, or one that does not qualify as a "groove."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term could be interpreted broadly to mean any channel, slot, or recess on the cap that serves to locate or hold the luminous component.
  • Evidence for a Narrower Interpretation: The specification states the "luminous component is interference-fit with the luminous component fix groove" (’617 Patent, col. 3:3-5), and Figure 2 depicts the groove (4) as a feature that receives the main body of the luminous component. This may support a narrower construction requiring a structure that substantially conforms to and retains the luminous component via an interference-fit.

VI. Other Allegations

• Indirect Infringement: The Plaintiff preemptively denies all forms of infringement, "whether directly or indirectly, literally or under the doctrine of equivalents" (Compl. ¶31). The complaint also raises a potential divided infringement defense by alleging that "on information and belief, no single entity does" perform all the required steps (Compl. ¶33).
• Willful Infringement: This is not applicable, as the Plaintiff is the accused infringer. However, the Plaintiff does allege that the Defendant's infringement accusations are "objectively baseless" and constitute an "exceptional case" warranting an award of attorneys' fees under 35 U.S.C. § 285 (Compl. ¶35; Prayer for Relief ¶4-5).

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

• A central issue will be one of structural correspondence: Does the accused "Football" product contain the specific mechanical assembly recited in Claim 1, namely a two-part, nested cap system where both caps and the primary lighting module are secured via an "interference-fit", or does it employ a different design for housing and providing access to its rechargeable components?
• The outcome will also likely hinge on claim construction: Can the patentee (Defendant) persuade the court to adopt a construction of terms like "interference-fit" and "luminous component fix groove" that is broad enough to read on the accused product's design, or will the accused infringer (Plaintiff) successfully argue for a narrower definition that its product does not meet?
• A third key question is legal and equitable: Independent of the infringement result, the court will need to determine whether the Defendant's initial patent enforcement action on the Amazon platform was "objectively baseless," which could expose the Defendant to liability for the Plaintiff's attorneys' fees.