DCT

1:25-cv-11154

Huang v. Shenzhen Zhaocheng Technology Co Ltd

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: William Huang (China)
    • Defendant: wolltex and the Individuals and Entities operating wolltex (Foreign Jurisdictions)
    • Plaintiff’s Counsel: Alioth Law
  • Case Identification: 1:25-cv-11154, N.D. Ill., 09/16/2025
  • Venue Allegations: Venue is alleged to be proper because Defendants do not reside in the United States and are therefore subject to venue in any judicial district. The complaint further alleges that Defendants target sales to consumers in Illinois through interactive e-commerce platforms.
  • Core Dispute: Plaintiff alleges that Defendants’ online sales of modular pet tents infringe one utility patent and two design patents related to combinable pet tent technology.
  • Technical Context: The technology at issue relates to modular, reconfigurable pet enclosures and play structures, a consumer product category within the broader pet supply market.
  • Key Procedural History: The complaint describes a developmental relationship among the patents, stating that U.S. Patent No. 11939786 integrated and combined ideas from prior design patents to protect the general concept of modular pet tents.

Case Timeline

Date Event
2020-06-30 '583 Patent Priority Date
2021-08-23 '526 Patent Priority Date
2022-11-29 '526 Patent Issue Date
2023-04-04 '583 Patent Issue Date
2023-08-21 '786 Patent Priority Date
2024-03-26 '786 Patent Issue Date
2025-09-16 Complaint Filing Date

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

U.S. Patent No. 11,939,786 - "Combinable Tent," issued March 26, 2024

The Invention Explained

  • Problem Addressed: The patent's background section notes that ordinary tents offer limited space and that existing combinable tents have restricted combination modes, particularly for the channels connecting tent structures, which limits creative assembly ('786 Patent, col. 1:11-24).
  • The Patented Solution: The invention is a modular tent system comprising distinct "tent modules" and "channel modules." The innovation lies in the connection mechanism: zipper assemblies at the ends of the channel modules are configured to allow channels to connect not only to tent modules but also to other channel modules, enabling the creation of extended "channel corridors" and more complex spatial arrangements ('786 Patent, col. 2:44-61; FIG. 2).
  • Technical Importance: This modular design approach allows end-users to construct a wider variety of custom play structures from a standard set of components ('786 Patent, col. 2:45-50).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('786 Patent, col. 6:4-41).
  • The essential elements of claim 1 include:
    • A plurality of tent modules and at least one channel module.
    • Each channel module comprises a channel and zipper assemblies at its two ends.
    • Each zipper assembly comprises a first zipper rack and a second zipper rack independent of each other, arranged along a circumferential direction of a port.
    • The zipper assembly includes specific components: a first slider on the first rack; a first retaining box and first top stopper on the first rack; and an insert pin and a second top stopper on the second rack.
    • The opening of each tent module is provided with a zipper rack matched with the channel's zipper assembly.
    • The first zipper rack of one module is configured to connect to the second zipper rack of an adjacent module.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Design Patent No. D971,526 - "Outdoor Pet Playpen Tent," issued November 29, 2022

The Invention Explained

  • Problem Addressed: The patent addresses the need for a new, original, and ornamental design for a pet tent.
  • The Patented Solution: The patent claims the specific ornamental design for a pet playpen tent as depicted in its figures ('526 Patent, Claim). The design consists of a multi-component structure featuring several distinct geometric modules—including cubes, a hexagonal prism, and a taller, conical tower—interconnected by mesh tunnels. The combination of these specific shapes and their arrangement creates the overall visual appearance of the patented design ('526 Patent, FIG. 1).

Key Claims at a Glance

  • The patent contains a single claim for "the ornamental design for an outdoor pet playpen tent, as shown and described."

Multi-Patent Capsule

  • Patent Identification: U.S. Design Patent No. D982,583, "Electronic Device," issued April 4, 2023.
  • Technology Synopsis: This patent claims the ornamental design for an electronic device, which the figures depict as a thin, multi-folding tablet or phone with visible hinge elements. The subject matter of the patented design is unrelated to pet products or tent structures ('583 Patent, FIGS. 1-3).
  • Asserted Claims: The single design claim for the ornamental design of an electronic device.
  • Accused Features: The complaint accuses Defendants' modular pet tents of infringing this design patent for an electronic device (Compl. ¶¶1, 16, 31).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "Infringing Products," which are described as modular pet tents (Compl. ¶1). These products are allegedly sold by Defendants under the alias "wolltex" and other unidentified entities through various "Online Marketplaces" (Compl. ¶¶1, 7).

Functionality and Market Context

  • The accused products are alleged to be sets of tents for pets that include "tent modules, channel modules, and zipper assemblies arranged to connect them" (Compl. ¶17). The complaint alleges that these products are sold through "fully interactive e-commerce store[s]" and are in "direct competition with the product sold by Plaintiff" (Compl. ¶¶1, 4). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’786 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A combinable tent, comprising a plurality of tent modules and at least one channel module connected to the tent modules... The Infringing Products are described as having "tent modules" and "channel modules." ¶17 col. 6:4-7
the at least one channel module comprises a channel and zipper assemblies arranged at two ends of the channel... The Infringing Products are described as having "zipper assemblies arranged to connect" the modules. ¶17 col. 6:15-17
wherein each of the zipper assemblies comprises a first zipper rack and a second zipper rack independent of each other... The complaint does not provide specific factual allegations regarding the structure of the zipper assemblies on the accused products. ¶17 col. 6:18-22
a first slider is arranged on the first zipper rack; a first retaining box is arranged at an end of the first zipper rack...an insert pin is arranged at an end of the second zipper rack... The complaint does not provide specific factual allegations regarding the individual components of the zipper assemblies on the accused products. ¶17 col. 6:25-34

Analysis of Design Patent Infringement Allegations

  • '526 Patent: The complaint alleges that the accused products are "substantially identical" to the design claimed in the '526 Patent (Compl. ¶16). For design patents, infringement is assessed from the perspective of an "ordinary observer." The core question for the court will be whether such an observer, familiar with prior art designs, would be deceived into believing the accused product is the same as the patented design. The complaint does not provide any visual comparisons to support its allegation.
  • '583 Patent: The complaint alleges that the accused pet tents are "substantially identical" to the design patents of the Plaintiff (Compl. ¶16), which includes the '583 Patent. This allegation presents a direct conflict with the subject matter of the '583 Patent itself, which claims a design for an electronic device.

Identified Points of Contention

  • Evidentiary Questions ('786 Patent): A central issue will be whether the Plaintiff can produce evidence that the accused products' connection mechanism meets every limitation of claim 1. The complaint's allegations are general and do not specify how the accused products meet the detailed claim requirements for the dual-track "zipper assemblies," including the specific arrangement of sliders, retaining boxes, and insert pins (Compl. ¶17).
  • Scope Questions ('526 Patent): The infringement analysis will depend on the visual comparison between the accused products and the specific ornamental features shown in the '526 Patent figures, including the particular shapes, proportions, and overall configuration of the modules and tunnels.
  • Subject Matter Mismatch ('583 Patent): A threshold issue is the basis for asserting a patent for an "Electronic Device" against accused products that are pet tents. This raises a fundamental question about the viability of this specific infringement claim as pleaded.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail to identify specific claim construction disputes. However, based on the technology of the '786 Patent, the following terms may become central to the case.

  • The Term: "zipper assemblies"

    • Context and Importance: This term defines the core connection mechanism that enables the modularity of the invention. Its construction will determine the scope of protection for the interconnectivity feature.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification uses the term generally to refer to the means of connection, which may support an interpretation that is not strictly limited to the precise embodiments shown ('786 Patent, col. 2:54-58).
      • Evidence for a Narrower Interpretation: Claim 1 itself recites a specific structure for the "zipper assemblies," including a "first zipper rack and a second zipper rack independent of each other" and other detailed components. This language, along with the detailed depiction in Figure 3, may support a narrower construction limited to this dual-track configuration ('786 Patent, col. 6:18-34; FIG. 3).

  • The Term: "independent of each other" (referring to the first and second zipper racks)

    • Context and Importance: This phrase is critical to defining the required relationship between the two zipper tracks on each connection port. Practitioners may focus on this term because it appears to be a key point of novelty.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party might argue "independent" simply means the two racks function separately to connect to their counterparts on an adjacent module, without requiring complete physical separation.
      • Evidence for a Narrower Interpretation: The depiction in Figure 3 shows two distinct, concentric annular zipper racks. A party could argue that "independent" requires this level of physical and structural separation, where one rack is radially inside the other ('786 Patent, FIG. 3; col. 4:50-53).

VI. Other Allegations

  • Indirect Infringement: The complaint includes a general allegation of indirect infringement (Compl. ¶15). It does not, however, plead specific facts to support the required elements of knowledge and intent, such as referencing defendant's product instructions, user manuals, or advertising that would encourage infringing acts.
  • Willful Infringement: Willfulness is alleged based on the assertion that Defendants acted "knowingly and intentionally or at least with reckless disregard or willful blindness" (Compl. ¶27). The complaint does not allege facts supporting pre-suit knowledge, such as prior notice of the asserted patents.

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

  1. Evidentiary Sufficiency: Can the plaintiff produce sufficient evidence to demonstrate that the accused products, allegedly sold by unidentified foreign entities via online marketplaces, incorporate the specific and detailed dual-zipper assembly structure required by every limitation of claim 1 of the '786 patent?
  2. Visual Identity: For the '526 design patent, is the overall ornamental appearance of the accused products "substantially the same" as the patented design, considering the specific shapes, proportions, and arrangement of modules and tunnels shown in the patent's figures?
  3. Pleading Validity: A foundational issue for the court will be to address the basis for asserting the '583 patent, which claims the ornamental design for an "Electronic Device," against products described and marketed as modular pet tents, raising questions about a potential pleading error.