Taizhou Shengwan Home Furnishing Co Ltd v. Nnovative Closet Accessories LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Taizhou Shengwan Home Furnishing Co., Ltd. (China)
  • Defendant: NNovative Closet Accessories LLC (Florida)
  • Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:25-cv-10257, N.D. Ill., 08/27/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant conducts business nationwide via an Amazon.com storefront, including sales to Illinois residents, and the allegedly harmful intellectual property complaint filed with Amazon caused injury to Plaintiff's commerce within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its container product does not infringe Defendant’s patent related to stackable storage devices and/or that the patent is invalid, following Defendant's successful request to have Plaintiff's product removed from Amazon's marketplace for alleged infringement.
• Technical Context: The dispute centers on the design of modular, stackable storage containers, a product category significant in the market for organizing and displaying collectibles such as headwear.
• Key Procedural History: The litigation was precipitated by Defendant’s complaint to Amazon’s intellectual property enforcement program, which resulted in the removal of Plaintiff’s product listing. This action forms the basis for the "actual controversy" required for a declaratory judgment action.

Case Timeline

Date	Event
2017-07-27	’075 Patent Priority Date
2019-04-30	’075 Patent Issue Date
2025-07-18	Defendant submits IP complaint to Amazon against Plaintiff
2025-08-27	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 10,273,075 - "Stackable Storage Device for Headwear"

• Patent Identification: U.S. Patent No. 10,273,075, "Stackable Storage Device for Headwear," issued April 30, 2019.

The Invention Explained

• Problem Addressed: The patent’s background section identifies a need for an improved storage device for headwear, such as baseball caps, that are often collected. Existing solutions are described as inadequate because they either fail to protect caps from dust and dirt (e.g., hanging racks) or are structurally unsuited for being stacked while allowing convenient access to the contents (’075 Patent, col. 2:42-51).
• The Patented Solution: The invention is a modular, stackable container, typically transparent for display purposes, featuring a slidable interior drawer (’075 Patent, col. 2:34-41). The design includes specific structural features intended to enhance functionality when multiple units are stacked. For example, magnets in the door of a lower unit can adhere to the bottom of an upper unit to hold the door open for easy access (’075 Patent, col. 4:15-28). The design also incorporates internal flanges to prevent the drawer from tipping when extended and stops to prevent it from being pulled out completely (’075 Patent, col. 2:46-64).
• Technical Importance: The claimed solution integrates dust-free storage, collector-oriented display, convenient access, and modular stackability into a single product design (’075 Patent, col. 2:7-12).

Key Claims at a Glance

• The complaint broadly alleges non-infringement of "at least one claim" of the ’075 Patent (Compl. ¶24). Independent Claim 1 is representative of the core invention.
• Independent Claim 1 requires:
  • An elongated container with a top, bottom, side, and back surface, an opening, and a moveable door.
  • A specific geometry where the top surface is shorter than the bottom surface, and an end of each side surface "slopes down from the top surface to the bottom surface at an obtuse angle."
  • A slidable drawer located on the bottom surface inside the container.
  • A "horizontal flange" on each interior side surface, "positioned to contact the side walls of the drawer when the back wall of the drawer is raised."
• The complaint reserves the right to address any claims asserted by the Defendant (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

• Plaintiff’s "container product," also referred to as the "Non-Infringing Product," sold on Amazon under ASIN B0FB3229TJ (Compl. ¶¶4-5).

Functionality and Market Context

• The complaint describes the accused item as a "home furnishing product" but does not provide specific technical details regarding its structure, features, or operation (Compl. ¶8). The context of the dispute suggests it is a stackable storage box functionally similar to the device described in the ’075 Patent.
• The complaint alleges that the removal of the product's Amazon listing has caused "immediate and foreseeable harm to Plaintiff's business in Illinois and across the United States," indicating its commercial presence (Compl. ¶14).

IV. Analysis of Infringement Allegations

The complaint is for a declaratory judgment of non-infringement and therefore does not contain affirmative infringement allegations or a corresponding claim chart. Plaintiff states that it has attached a "non-infringement analysis" as Exhibit E demonstrating that its products do not practice any claim of the ’075 Patent; however, this exhibit was not included with the filed complaint (Compl. ¶29). Without this analysis or a description of the accused product's features, a detailed examination of the infringement dispute is not possible based on the provided documents.

Identified Points of Contention

Based on the specific language of the ’075 Patent's independent claims, the dispute over infringement will likely involve several distinct structural and functional elements.

• Scope Questions: A central question may be whether the accused product's structure meets the specific geometric limitations of Claim 1. For instance, does the accused product have a top surface shorter than its bottom surface, and do its side surfaces slope "at an obtuse angle" as claimed? A product with a simple rectangular or cuboid geometry may not read on this limitation.
• Technical Questions: The functional limitation of the "horizontal flange" presents another potential point of dispute. The claim requires the flange to be "positioned to contact the side walls of the drawer when the back wall of the drawer is raised." This raises the question of whether the accused product contains any internal structure that performs this specific anti-tipping function and, if so, whether it operates in the same way as claimed.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "a horizontal flange located on each side surface... and positioned to contact the side walls of the drawer when the back wall of the drawer is raised."

• Context and Importance: This term is critical because it defines a functional relationship between the container's internal geometry and the drawer. The infringement analysis will depend on whether the accused product has a structure that meets both the "horizontal flange" description and performs the specific function of contacting the drawer's side walls only "when the back wall... is raised." Practitioners may focus on this term to distinguish between a general-purpose guide rail and the specific anti-tipping mechanism described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "flange" itself is broad, and parties might argue it could encompass any ledge, rail, or protrusion on the interior wall that limits the drawer's movement.
  • Evidence for a Narrower Interpretation: The specification describes how the side walls of the drawer "come into contact with the flanges or rails that are featured on side surfaces of the container" specifically to "stop the upward movement of a portion of the drawer," preventing it from tipping downward when extended (’075 Patent, col. 2:56-64). This language could support a narrower construction requiring the structure to be specifically designed for and operative as an anti-tipping feature.

The Term: "an end of each of the side surfaces slopes down from the top surface to the bottom surface at an obtuse angle"

• Context and Importance: This geometric limitation defines the distinctive shape of the container's front opening. A determination of infringement could hinge on whether the accused product embodies this precise angular feature, as opposed to having a conventional vertical front face.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that any non-right-angle slope at the front of the container meets the "obtuse angle" limitation, as long as it is greater than 90 degrees relative to the vertical plane.
  • Evidence for a Narrower Interpretation: The specification links this shape to the functional benefit it provides when units are stacked, and it gives a specific example of "a 45 degree" slope (’075 Patent, col. 4:11-14). A party could argue the term should be construed in light of this disclosed embodiment and its functional purpose, potentially limiting it to similarly substantial slopes rather than minor chamfering.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement. As a declaratory judgment action brought by the accused infringer, its focus is on non-infringement and invalidity. However, Plaintiff requests that the court declare the case "exceptional" and award attorneys' fees pursuant to 35 U.S.C. § 285, alleging that Defendant's enforcement of the ’075 Patent through Amazon was "wrongful and anticompetitive" (Compl. ¶33, Prayer for Relief ¶4).

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

• A core issue will be one of structural correspondence: Does the accused product embody the specific, and arguably unconventional, geometric features recited in Claim 1, particularly the sloped front opening and the shorter top surface, or was it designed with a more standard configuration that avoids these limitations?
• A key evidentiary question will be one of functional operation: Does the accused product contain an internal "horizontal flange" or an equivalent structure that performs the claimed function of preventing the drawer from tipping by making contact only when the drawer's back wall is raised, or does it use a different mechanism—or no mechanism—for guiding the drawer?
• Beyond the technical merits, a central theme of the case appears to be the propriety of enforcement tactics: Plaintiff’s request for an "exceptional case" finding suggests that the dispute may extend beyond a simple infringement analysis to scrutinize the basis and impact of Defendant's intellectual property complaint on the Amazon platform.