Aiming Tang v. Shanghai Jingteyi Keji Youxian Gongsi

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Aiming Tang (China)
  • Defendant: Shanghai Jingteyi Keji Youxian Gongsi, d/b/a JINGTEYI (China)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 1:25-cv-07179, N.D. Ill., 06/26/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant's operation of interactive e-commerce stores that target consumers in the United States, including Illinois, by offering shipping, accepting U.S. currency, and selling the accused products to Illinois residents.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce sales of certain towing devices infringe a patent related to a mechanical damping function for vehicle trailer hitches.
• Technical Context: The technology concerns accessories for vehicle towing, specifically trailer hitch assemblies designed to reduce noise, vibration, and wear by eliminating slack in the connection points.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or significant prosecution history related to the patent-in-suit.

Case Timeline

Date	Event
2022-03-08	’973 Patent Priority Date
2022-09-20	’973 Patent Issued
2025-06-26	Complaint Filed

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

U.S. Patent No. 11,446,973 - “TOWING DEVICE WITH DAMPING FUNCTION”

• Patent Identification: U.S. Patent No. 11,446,973, “TOWING DEVICE WITH DAMPING FUNCTION,” issued September 20, 2022.

The Invention Explained

• Problem Addressed: The patent’s background section describes an issue with prior art towing devices where a gap between the connecting pin and its corresponding hole allows the assembly to sway during use. This movement causes "collision continuously," resulting in "large noise" and abrasion to both the towing device and the vehicle body (’973 Patent, col. 1:25-29).
• The Patented Solution: The invention introduces a "cushion" (27) that is sleeved onto the "towing cantilever" (3), which is the bar that inserts into the vehicle's receiver. A "tightening bolt" (28) is then used to push this cushion against a fixed seat on the vehicle, filling the gap. This arrangement is intended to restrain axial movement, making the connection "steadier and more shock-absorbent" and reducing noise (’973 Patent, Abstract; col. 3:5-13).
• Technical Importance: This mechanical solution aims to improve towing safety and smoothness and prolong the service life of the equipment by proactively eliminating the play that causes shock and wear (’973 Patent, col. 3:11-19).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶26).
• The essential elements of independent Claim 1 include:
  • A towing main body with a towing cantilever and a vertical adjustment arm.
  • The towing cantilever is connected to the vertical adjustment arm at one end and has fixing holes at the other end for connection to a fixed seat on a vehicle.
  • A "cushion" sleeved on the towing cantilever, located between the fixing holes and the vertical adjustment arm.
  • A "tightening bolt" on one side of the cushion.
  • The tightening bolt can be rotated to "push the cushion" so that its end surface "is abutted against the fixed seat" on the vehicle.
• The complaint reserves the right to modify its infringement theory and potentially assert other claims (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

• The "Infringing Products" are identified as "Towing Device Products" sold by Defendant JINGTEYI (Compl. ¶1).

Functionality and Market Context

• The complaint alleges Defendant operates e-commerce stores, including on Amazon.com, to advertise and sell the Infringing Products to consumers in the United States (Compl. ¶¶2, 7, 16). These products are towing devices alleged to incorporate the patented invention (Compl. ¶14). The complaint contends that the existence of these products has hampered the Plaintiff's ability to enter and expand its market share (Compl. ¶1).

IV. Analysis of Infringement Allegations

The complaint alleges that the Infringing Products infringe at least Claim 1 of the ’973 Patent (Compl. ¶26). It states that a claim chart demonstrating this infringement is attached as Exhibit 3; however, this exhibit was not included with the complaint filing (Compl. ¶26). The complaint itself does not contain a narrative description of how the accused products meet the specific limitations of Claim 1. Instead, it makes general allegations that the Defendant manufactures, imports, and sells products that infringe the patent (Compl. ¶¶25, 27). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: The complaint's infringement allegations appear to rest entirely on the referenced but unattached Exhibit 3. A central question will be whether discovery provides evidence that the accused products actually contain the specific mechanism recited in Claim 1—namely, a movable "cushion" that is pushed by a "tightening bolt" to abut a fixed seat and thereby provide a damping function.
  • Technical Question: Assuming the accused products have some form of anti-rattle or stabilization feature, a key technical question will be whether that feature operates in the same way as the claimed invention. For instance, does the accused product's mechanism function by pushing a cushion to fill an axial gap as required by the claim, or does it achieve stabilization through a different technical approach?

V. Key Claim Terms for Construction

• The Term: "cushion"

• Context and Importance: This term is central to the invention's "damping function." Its construction will determine whether the claim covers any generic anti-rattle component or is limited to the specific structure described in the patent. Practitioners may focus on this term because the infringement analysis will depend on whether the accused product's corresponding feature can be characterized as a "cushion" that is "pushed" as the claim requires.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "cushion" itself is a general term, and the patent refers to it as comprising multiple "damping pieces," which could suggest some flexibility in its form (’973 Patent, col. 8:34-35).
  • Evidence for a Narrower Interpretation: The claims and specification provide significant structural and functional context. The "cushion" is "sleeved on the towing cantilever," "located between the fixing holes and the vertical adjustment arm," and is acted upon by a "tightening bolt" to be "abutted against the fixed seat" (’973 Patent, col. 8:1-10, Claim 1). This language may support a narrower construction limited to a component that performs this specific sequence of actions in this precise location.

• The Term: "tightening bolt"

• Context and Importance: This is the active element that enables the claimed damping function. The dispute may turn on whether the accused product's tightening mechanism, if any, meets the functional requirements associated with this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "bolt" is generic. The patent does not appear to limit it to a particular type of threaded fastener beyond its function.
  • Evidence for a Narrower Interpretation: The claim requires that the bolt "can be rotated to push the cushion" until the cushion is "abutted against the fixed seat" (’973 Patent, col. 8:5-10, Claim 1). This functional language suggests the term should be construed to mean a component that directly or indirectly imparts a compressive force on the cushion to achieve the claimed abutment, potentially excluding other types of fasteners or tension-based stabilizers.

VI. Other Allegations

• Indirect Infringement: The prayer for relief seeks to enjoin Defendant from "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl. ¶A.b). However, the complaint's factual allegations focus on direct infringement and do not plead specific facts, such as the provision of instructional materials, that would be necessary to support a claim for induced infringement.
• Willful Infringement: The complaint alleges that Defendant's infringement "has been and continues to be willful" (Compl. ¶30). The allegations are stated in a conclusory manner, asserting that Defendant acted "knowingly and willfully" without providing a specific factual basis for pre-suit knowledge of the patent or its infringement (Compl. ¶¶22, 25).

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

• A core issue will be one of evidentiary support: Given that the complaint's technical infringement theory relies on a missing exhibit, a threshold question is whether Plaintiff can produce evidence in discovery showing that the accused products contain a mechanism that performs the specific functions of the claimed "cushion" and "tightening bolt".
• The case will also likely involve a key question of claim scope: Can the term "cushion", as functionally defined by its interaction with the "tightening bolt" and "fixed seat", be construed broadly to cover various anti-rattle mechanisms, or will it be limited to the specific compressive, gap-filling structure detailed in the patent's embodiments? The answer will likely determine the outcome of the infringement analysis.