Huang v. Shenzhen Zhaocheng Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: William Huang (Individual)
  • Defendant: Neatki and the Individuals and Entities operating Neatki (Foreign Jurisdictions)
  • Plaintiff’s Counsel: Alioth Law
• Case Identification: 1:25-cv-11241, N.D. Ill., 09/18/2025
• Venue Allegations: Venue is alleged to be proper because Defendants are not U.S. residents, making venue appropriate in any judicial district, and because Defendants allegedly target sales to consumers in Illinois.
• Core Dispute: Plaintiff alleges that Defendant’s modular pet tent products infringe one utility patent and two design patents related to combinable, modular tent structures.
• Technical Context: The technology at issue involves modular tents and connecting tunnels, primarily for pets, which can be combined in various configurations to create customizable play spaces.
• Key Procedural History: The complaint describes a patent family relationship, stating that U.S. Design Patent No. D971,526 was the "prototype," U.S. Design Patent No. D982,583 was a continuation-in-part, and U.S. Patent No. 11,939,786 is a utility patent that "integrated the ideas" from the prior design patents. This prosecution history may become relevant to claim construction and potential estoppel arguments.

Case Timeline

Date	Event
2020-06-30	Earliest Priority Date Asserted (’583 Patent)
2021-08-23	Priority Date (’526 Patent)
2022-11-29	’526 Patent Issued
2023-04-04	’583 Patent Issued
2023-08-21	Priority Date (’786 Patent)
2024-03-26	’786 Patent Issued
2025-09-18	Complaint Filed

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

U.S. Patent No. 11,939,786 - "Combinable Tent"

The Invention Explained

• Problem Addressed: The patent's background section identifies a deficiency in prior art tents, noting that conventional tents offer limited space and that existing combinable versions have restricted combination modes, particularly regarding the channels used to connect tent structures (’786 Patent, col. 1:10-24).
• The Patented Solution: The invention is a modular tent system comprising "tent modules" and "channel modules" that connect them. The core inventive concept appears to be the specific design of the "zipper assemblies" located at both ends of each channel module. This design allegedly allows not only for connection between a channel and a tent but also for direct connection between two channel modules, enabling the creation of extended corridors and more complex spatial arrangements (’786 Patent, Abstract; col. 2:50-61).
• Technical Importance: The claimed solution provides a standardized and versatile connection system that increases the modularity and creative potential of such play structures beyond simple tent-to-tunnel connections (’786 Patent, col. 2:45-48).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶17).
• The essential elements of independent claim 1 include:
  • A plurality of tent modules and at least one channel module.
  • The channel module comprising a channel and "zipper assemblies" at both ends.
  • Each zipper assembly comprising a "first zipper rack" and a "second zipper rack" that are "independent of each other."
  • A specific configuration for the first zipper rack (slider, retaining box, top stopper) and the second zipper rack (insert pin, top stopper).
  • The tent modules having a matching "first zipper rack or/and a second zipper rack."
  • The first zipper rack of one module being 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"

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture, not its utility. The complaint positions this patent as the "earliest idea" and "prototype" for Plaintiff's product line (Compl. ¶10).
• The Patented Solution: The patent claims the specific ornamental design for a multi-component pet playpen tent (’526 Patent, Claim). As illustrated in the figures, the claimed design consists of a combination of differently shaped modules—including cubic, hexagonal, triangular prism, and conical tower shapes—interconnected by tunnels to form a distinct overall visual impression (’526 Patent, Fig. 1).
• Technical Importance: The unique aesthetic created by the combination of geometric forms and their spatial arrangement constitutes the protected design, which the complaint suggests is a key market differentiator for Plaintiff's products (Compl. ¶12).

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" (’526 Patent, Claim). The complaint asserts infringement of this claimed design (Compl. ¶16).

U.S. Design Patent No. D982,583 - "Electronic Device"

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 what appears to be a large, foldable or multi-panel electronic display device (’583 Patent, Figs. 1-3). The complaint, however, identifies this patent as part of a set of "tents for pets" and alleges it is a continuation-in-part of the ’526 Patent covering a pet playpen (Compl. ¶9, ¶10). This presents a notable discrepancy between the subject matter of the patent and the allegations in the complaint.
• Asserted Claims: The patent claims "The ornamental design for an electronic device, as shown and described" (’583 Patent, Claim).
• Accused Features: The complaint accuses Defendants' pet tents of infringing this design patent for an electronic device (Compl. ¶1, ¶16).

III. The Accused Instrumentality

Product Identification

• The accused products are identified as modular pet tents sold by Defendants through "Online Marketplaces" under various aliases (Compl. ¶1, ¶4, ¶17).

Functionality and Market Context

• The complaint describes the accused products as a "set of tents for pets to play that contains tent modules and channels that could be freely assembled with the zippers" (Compl. ¶18). It is alleged that these products directly compete with Plaintiff's products and are "substantially identical" to them, causing consumer confusion (Compl. ¶1, ¶16). Exhibit 4, referenced by the complaint, allegedly shows Defendants' e-commerce stores on online platforms offering the accused products for sale (Compl. ¶5).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or detailed infringement analysis. The infringement theory is based on generalized allegations.

’786 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a plurality of tent modules	The accused products are alleged to have "tent modules."	¶17	col. 6:1-2
at least one channel module connected to the tent modules	The accused products are alleged to have "channel modules."	¶17	col. 6:3-4
the at least one channel module comprises... zipper assemblies arranged at two ends of the channel...	The accused products are alleged to have "zipper assemblies arranged to connect" the modules.	¶17	col. 6:13-15

• Identified Points of Contention:
  • Evidentiary Question: The complaint offers a conclusory allegation that the accused products contain the claimed modules and "zipper assemblies" (Compl. ¶17). A primary point of contention will be whether the accused products' zippers meet the detailed structural limitations of the "zipper assemblies" recited in Claim 1, which require a specific two-part structure comprising independent first and second zipper racks with distinct components (’786 Patent, col. 6:16-32).
  • Doctrine of Equivalents: The complaint explicitly pleads infringement under the doctrine of equivalents (Compl. ¶18). This suggests a potential dispute over whether the accused product's connection mechanism, if not literally infringing, performs substantially the same function (connecting modules) in substantially the same way (via a dual-track zipper system) to achieve substantially the same result (a versatile, inter-connectable modular tent system).

’526 Patent Infringement Allegations

• Infringement Allegation Summary: The complaint alleges that the accused products are "substantially identical" to the design claimed in the ’526 Patent and are likely to cause consumer confusion (Compl. ¶16). The legal test for design patent infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design.
• Identified Points of Contention: The analysis will turn on a visual comparison between the accused product and the design depicted in the ’526 Patent's figures. The key question will be whether the overall ornamental appearance of the accused product, including the specific shapes of its modules and their arrangement, is substantially the same as the claimed design.

V. Key Claim Terms for Construction

The Term: "zipper assemblies"

• Context and Importance: This term and its dependent clauses describe the core connection mechanism of the invention. The definition of what constitutes the claimed "assembly" will be central to determining the scope of the claim and whether the accused products infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Parties may point to more general statements in the specification, such as the goal of implementing "interconnection and intercommunication... by the zipper assemblies arranged at the ports," to argue for a broader meaning that is not strictly limited to the depicted embodiment (’786 Patent, col. 2:52-56).
  • Evidence for a Narrower Interpretation: Claim 1 itself provides a detailed definition, requiring each assembly to comprise "a first zipper rack and a second zipper rack independent of each other" with specific components (’786 Patent, col. 6:16-32). This explicit language, along with detailed depictions in Figure 3 and its accompanying description, could be used to argue that the term is limited to this specific dual-track structure (’786 Patent, col. 4:45-67).

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory 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 instructional materials or advertisements that encourage infringing assembly.
• Willful Infringement: The complaint alleges that Defendants' infringement was "willful, intentional, purposeful" and undertaken with "reckless disregard or willful blindness to Plaintiff's rights" (Compl. ¶27, ¶32). The complaint does not allege facts supporting pre-suit knowledge of the patents; the basis for willfulness appears to rest on notice provided by the filing of the lawsuit itself.

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

• A threshold issue appears to be one of pleading sufficiency, particularly concerning the assertion of U.S. Design Patent No. D982,583. The complaint accuses a modular pet tent of infringing a design patent that expressly claims an "Electronic Device," presenting a fundamental mismatch that may be subject to early challenge.
• For the utility patent, a key technical question will be one of structural correspondence: does the accused product's connection mechanism embody the specific, two-part "independent" zipper rack structure required by Claim 1 of the ’786 patent, or does it utilize a more conventional connection system that falls outside the literal scope of the claim?
• For the design patents, the central question is one of visual identity: is the overall ornamental appearance of the accused modular tent "substantially the same" as the specific combination of module shapes and arrangement claimed in the ’526 patent, such that it would deceive an ordinary observer familiar with the prior art?