DCT

1:25-cv-11201

Changtingxiantinghaoshengshangmaoyouxiangongsi v. Jiang

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00391, E.D. Va., 05/21/2025
  • Venue Allegations: Plaintiffs allege venue is proper under 35 U.S.C. § 293, which governs lawsuits against foreign patent owners who have not designated an agent for service of process within the United States.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their headwear organizer products do not infringe Defendant's patent for a baseball cap rack, and further that the patent is invalid.
  • Technical Context: The dispute centers on the mechanical design of consumer products for organizing and displaying baseball caps.
  • Key Procedural History: The complaint alleges that this action was precipitated by Defendant filing one or more complaints with Amazon, accusing Plaintiffs' products of infringing the patent-in-suit, thereby creating an actual controversy between the parties.

Case Timeline

Date Event
2024-08-05 ’071 Patent Priority Date
2025-02-11 ’071 Patent Issue Date
2025-05-21 Complaint Filing Date

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

U.S. Patent No. 12,220,071 - "HAT RACK FOR BASEBALL CAP"

  • Patent Identification: U.S. Patent No. 12,220,071, "HAT RACK FOR BASEBALL CAP," issued February 11, 2025 (the "’071 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section identifies shortcomings in prior art methods for storing baseball caps, noting that individual hooks take up space and are not secure, stacking makes caps inaccessible, and at least one prior art display stand has an "overly complex structure" (’071 Patent, col. 1:21-32).
  • The Patented Solution: The invention proposes a rack with a main body featuring a vertical row of "connection ports" designed to hold folded baseball caps securely (’071 Patent, Abstract). Each port has an upper and lower platform; the cap's top button is inserted and engages with a "limiting portion" on the upper platform, which interferes with the button to prevent the cap from falling off due to gravity (’071 Patent, col. 3:45-53). This design aims to provide a simple, reliable, and standardized storage method for a large number of caps.
  • Technical Importance: The claimed solution seeks to improve upon prior methods by creating a purpose-built structure that standardizes storage and uses a specific mechanical interference to reliably secure each cap (’071 Patent, col. 1:45-49).

Key Claims at a Glance

  • The complaint identifies Claim 1 as the sole independent claim asserted (’071 Patent, col. 6:32-52; Compl. ¶32).
  • The essential elements of independent Claim 1 include:
    • A main body with a vertical support surface containing a plurality of connection ports.
    • Each connection port having a lower support platform, an upper positioning platform, and a "limiting portion" on the bottom surface of the upper platform.
    • A specific configuration of "two of said main bodies disposed back to back."
    • "top ends of the main bodies are provided with a hook."
    • The hook having a "U-shaped opening" and a "bolt."
    • A specific assembly wherein "the upper ends of the two main bodies are fitted into the U-shaped opening" and connected via the "bolt."
  • The complaint notes that dependent Claims 2-9 are also at issue, as their infringement is contingent on infringement of Claim 1 (Compl. ¶48).

III. The Accused Instrumentality

Product Identification

  • The accused products are "headwear organizers and displays" sold by Plaintiffs on Amazon.com under various Amazon Standard Identification Numbers (ASINs), including B0DLFCX667 and B0DT6M8561 (Compl. ¶12, ¶22).

Functionality and Market Context

  • The complaint describes the products as being designed to organize and display baseball caps (Compl. ¶22). A key functional aspect highlighted for the purpose of non-infringement is the product's alleged construction as a "one body component" that does not contain "separable parts," a "separate hook component," or "two main bodies" (Compl. ¶43-46). The complaint provides an image showing the accused product as a single, vertically-oriented plastic strip with integral cap-holding features (Compl. p. 6). The complaint alleges the products are popular on Amazon, which is a critical sales channel for Plaintiffs (Compl. ¶23-25).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiffs' primary arguments for why their product does not meet the limitations of Claim 1.

’071 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
wherein there are two of said main bodies disposed back to back The product is a "one body component" and "does not contain two main bodies." ¶43, ¶45 col. 6:40-42
top ends of the main bodies are provided with a hook The product "does not contain a separate hook component." ¶44 col. 6:45-46
wherein the upper ends of the two main bodies are fitted into the U-shaped opening, and the lower end of the hook is provided with a bolt which cross both ends of the U-shaped opening... The product does not include this structure, as it allegedly lacks two main bodies or a separate hook with a U-shaped opening into which they could be fitted. ¶47 col. 6:48-52

Identified Points of Contention

The non-infringement arguments center on fundamental structural differences between the claimed invention and the accused product.

  • Scope Questions: A central dispute will be whether the claim term "two of said main bodies disposed back to back" can be interpreted to read on a single, integrally molded piece with two functional sides, as Plaintiffs allege their product to be (Compl. ¶43, ¶45).
  • Technical Questions: The complaint raises the question of whether the accused product's integrated structure can satisfy the claim's specific assembly requirements. For instance, what evidence exists that the accused product, alleged to be a single component, contains two distinct bodies that are "fitted into" a separate "hook" and connected by a "bolt" as recited in the claim (Compl. ¶47)?

V. Key Claim Terms for Construction

The Term: "two of said main bodies disposed back to back"

  • Context and Importance: This term is critical, as Plaintiffs' primary non-infringement argument is that their product is a single component, not an assembly of two bodies (Compl. ¶45). The construction of this phrase may determine the outcome of the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent discloses an embodiment with "two support surfaces... disposed back to back," which could be argued to support a functional interpretation rather than requiring two physically separate parts (’071 Patent, col. 4:64-65).
    • Evidence for a Narrower Interpretation: Claim 1 recites specific interactions between two distinct bodies, such as "an upper end of each of the main bodies is provided with a first through hole" and "the upper ends of the two main bodies are fitted into the U-shaped opening" of the hook (’071 Patent, col. 6:42-49). This language, particularly in conjunction with Figure 11 which shows two separate main bodies (1) and a hook (7) as distinct components, suggests a requirement for two physically separate and assemblable parts.

The Term: "hook"

  • Context and Importance: Plaintiffs argue their product lacks a "separate hook component" (Compl. ¶44). If "hook" is construed to require a separate component that is attached to the main bodies as described in the claim, then an integrated hanging feature may not infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that any feature performing the function of hanging the device constitutes a "hook" under a plain and ordinary meaning.
    • Evidence for a Narrower Interpretation: Claim 1 provides significant structural context, describing a hook with a "U-shaped opening" and a "bolt" that connects to the "two main bodies" (’071 Patent, col. 6:45-52). Embodiment Three and its corresponding Figure 11 explicitly detail and depict the hook (7) as a separate part from the main bodies (1), which are "embed[ded]" into its opening (’071 Patent, col. 5:37-44). This intrinsic evidence may support a narrower construction requiring a multi-part, assembled structure.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement. Instead, it includes a count for invalidity of the ’071 Patent under 35 U.S.C. §§ 102 and 103, citing U.S. Patent No. 5,240,123 (Hawk) and U.S. Patent Publication 2012/0037671 (Lueth) as prior art (Compl. ¶62-68). Plaintiffs also seek a finding that the case is exceptional under 35 U.S.C. § 285, alleging Defendant’s infringement complaints to Amazon were baseless and made with an intent to harm Plaintiffs' business (Compl. ¶50, ¶55).

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

The resolution of this declaratory judgment action will likely depend on the court's interpretation of specific structural limitations in Claim 1.

  • A core issue will be one of structural identity: Can the claim phrase "two of said main bodies disposed back to back," which is part of a detailed description of a multi-component assembly, be construed to read on a product that is allegedly a single, integrally molded component?
  • A related question is one of component relationship: Does the accused product's design meet the claim's specific recitation of "two main bodies" being "fitted into" a separate "hook" and secured by a "bolt," or is there a fundamental mismatch between the claimed multi-part assembly and the accused product's alleged single-piece construction?