DCT

1:25-cv-10427

Yangjiangshi Xicheng Trading Co Ltd v. Shenzhen Lanhe Tech Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-10427, N.D. Ill., 08/30/2025
  • Venue Allegations: Plaintiffs allege venue is proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiffs, who sell phone cases on Amazon, seek a declaratory judgment that their products do not infringe U.S. Patent No. 12,040,827 and that the patent is invalid.
  • Technical Context: The patent-in-suit relates to protective cases for electronic devices, such as smartphones, that incorporate a movable magnetic assembly to serve as both a stand and a means for magnetic coupling with wireless chargers.
  • Key Procedural History: The action was precipitated by Defendant's initiation of Amazon's Patent Evaluation Express (APEX) process, in which Defendant accused Plaintiffs' products of infringing the patent-in-suit. This process created a justiciable controversy, prompting Plaintiffs to file this declaratory judgment action to resolve the claims of infringement and validity.

Case Timeline

Date Event
2022-03-11 ’827 Patent - Earliest Priority Date
2024-07-16 ’827 Patent - Issue Date
2025-08-06 Defendant signs Amazon APEX Agreement alleging infringement
2025-08-13 Plaintiffs receive email from Amazon regarding infringement report
2025-08-30 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 12,040,827 - "Case for Electronic Device and Magnetic Assembly"

  • Patent Identification: U.S. Patent No. 12,040,827, "Case for Electronic Device and Magnetic Assembly," issued July 16, 2024 (’827 Patent).

The Invention Explained

  • Problem Addressed: The patent's background section notes that protective cases on electronic devices can negatively affect the magnetic alignment required for efficient wireless charging. It also notes the utility of a protective case that can double as a support or stand for the device ( Compl. Exhibit A, ’827 Patent, col. 1:25-38).
  • The Patented Solution: The invention is a case for an electronic device that includes a magnetic assembly. This assembly contains both a support member, which can move relative to the case to act as a stand, and a magnetic alignment member, which is connected to the support member to facilitate coupling with wireless chargers or other magnetic accessories (’827 Patent, Abstract; col. 2:40-50). The support member is designed to be rotatably connected to the case, allowing it to be folded flat or deployed at an angle (’827 Patent, col. 3:12-21).
  • Technical Importance: This design purports to integrate the functionality of a protective case, a viewing stand, and a magnetic charging-compatible accessory into a single unit.

Key Claims at a Glance

  • The complaint seeks a declaratory judgment regarding "each of the claims of the ’827 Patent" without specifying particular claims (Compl. Prayer for Relief ¶ a). Claim 1 is analyzed here as a representative independent claim.
  • Claim 1 Elements:
    • A case for an electronic device, comprising:
    • a side wall;
    • a back wall, connected with the side wall to define a receiving cavity for receiving the electronic device; and
    • a magnetic assembly, comprising:
      • a support member, connected with the side wall or the back wall, and capable of moving relative to the side wall or the back wall, so as to support the case; and
      • a magnetic alignment member, detachably or fixedly connected with the support member.
  • The complaint does not explicitly reserve the right to assert dependent claims but seeks judgment on "each of the claims" (Compl. Prayer for Relief ¶ a).

III. The Accused Instrumentality

Product Identification

  • Plaintiffs’ phone cases sold on Amazon under Amazon Standard Identification Numbers (ASINs) B0CPPGX63N, B0CPPDNH8C, B0F38DVM9Q, and B0F38GNPYL (Compl. ¶¶ 9-10).

Functionality and Market Context

  • The complaint identifies the products as "phone case[s]" but does not provide specific details regarding their features, materials, or technical operation (Compl. ¶¶ 9-10). The dispute arose from Defendant's assertion through the Amazon APEX process that these products infringe the ’827 Patent (Compl. ¶¶ 11-12).

IV. Analysis of Invalidity and Non-Infringement Claims

The complaint seeks declaratory judgments of both invalidity and non-infringement.

  • Non-Infringement Position: The complaint asserts that Plaintiffs' ASINs have not infringed and do not infringe any valid and enforceable claims of the ’827 Patent (Compl. ¶ 24). However, it does not provide a detailed factual or legal basis for this assertion, such as a claim-by-claim analysis or a description of the products' non-infringing functionality. The complaint does not provide sufficient detail for analysis of non-infringement.
  • Invalidity Position: In Count I, Plaintiffs allege that the claims of the ’827 Patent are invalid under 35 U.S.C. §§ 102 and/or 103 in view of prior art, specifically identifying Chinese Patent CN 214851387 U (Compl. ¶ 17). The complaint provides a side-by-side visual comparison of Figure 4 from the ’827 Patent and Figure 5 from the cited Chinese patent to support its invalidity contention (Compl. p. 4). This comparison suggests a structural similarity between the patented invention and the prior art reference, which will form the basis of Plaintiffs' anticipation or obviousness arguments.

V. Key Claim Terms for Construction

  • The Term: "support member"

    • Context and Importance: The definition of "support member" is central, as it is the component that is "capable of moving relative to the... back wall, so as to support the case." The scope of this term will determine what types of movable structures (e.g., rings, kickstands, hinged panels) are covered by the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language is broad, not limiting the "support member" to any particular shape. The specification describes it as having an "open annular structure" in one embodiment, but this is not a universal limitation (’827 Patent, col. 5:30-31).
      • Evidence for a Narrower Interpretation: The figures consistently depict the support member as a ring-like structure (e.g., element 21a in Fig. 1) that rotates away from the case body (’827 Patent, Figs. 1, 4). A defendant may argue that the invention is limited to such ring-shaped embodiments.

  • The Term: "magnetic alignment member"

    • Context and Importance: This element provides the magnetic functionality for wireless charging alignment. Its construction will be critical to determining infringement, particularly how it is "connected with the support member" and whether it must be a distinct component.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the member as including "a material being capable of coupling with a magnet, such as magnet, or iron," suggesting the term covers a wide range of materials and is not limited to a permanent magnet (’827 Patent, col. 3:46-48).
      • Evidence for a Narrower Interpretation: In several embodiments, the magnetic alignment member (24a) is shown as a separate component received within a groove (213a) of the support member (21a) (’827 Patent, col. 5:63-67; Fig. 2). A defendant could argue that this structural separation is a required feature, as opposed to a support member made of a magnetic material itself.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

This declaratory judgment action appears poised to center on the following questions for the court:

  • A central issue will be one of validity: Does the cited Chinese patent CN 214851387 U disclose, either expressly or inherently, all limitations of the asserted claims of the ’827 Patent, rendering them invalid as anticipated or obvious?
  • A key question of claim construction will be whether the term "support member" is limited to the ring-shaped structures depicted in the patent's embodiments or if it can be construed more broadly to cover other forms of movable stands.
  • An evidentiary question for any subsequent infringement counterclaim will be whether the Plaintiffs' accused phone cases, which are not detailed in the complaint, actually practice each limitation of the asserted claims, particularly the structure and relative movement of the "support member" and "magnetic alignment member."