DCT

1:25-cv-12095

XYZ Corp v. Individuals Corps Ltd

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Shenzhen Peishi Advertising Media Co. Ltd. v. The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule "A", 1:25-cv-12095, N.D. Ill., 11/10/2025
  • Venue Allegations: Venue is asserted on the basis that Defendants are not residents of the United States and are subject to personal jurisdiction in the district, having engaged in infringing activities by advertising, offering to sell, and selling products to consumers in the Northern District of Illinois.
  • Core Dispute: Plaintiff alleges that Defendants’ automatic smoker products, sold through online marketplace stores, infringe a patent related to an automatic ignition system for such devices.
  • Technical Context: The technology concerns consumer electronic devices designed to impart smoke flavor to food and beverages, a market segment where convenience and ease of use are significant features.
  • Key Procedural History: The complaint alleges Plaintiff acquired the patent-in-suit via assignment from the sole inventor. The complaint frames the dispute as part of a broader effort to combat online infringers who allegedly operate under multiple seller aliases to conceal their identities. The complaint's joinder theory rests on the allegation that all accused products are functionally identical in the ways relevant to the patent.

Case Timeline

Date Event
2024-09-14 ’440 Patent Priority Date
2025-06-10 ’440 Patent Issue Date
2025-11-10 Complaint Filing Date

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

U.S. Patent No. 12,324,440 - "Automatic Smoker"

  • Patent Identification: U.S. Patent No. 12,324,440, "Automatic Smoker," issued June 10, 2025 (the "’440 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section notes that conventional smokers typically require the user to place a combustion medium (e.g., wood chips) into a chamber and ignite it with an external heat source, a process described as potentially inconvenient (’440 Patent, col. 1:19-25).
  • The Patented Solution: The invention is an automatic smoker with a self-contained ignition system (’440 Patent, col. 1:29-31). The core of the solution is an "automatic igniter" that includes an "ignition needle" positioned inside an air inlet port (’440 Patent, col. 1:39-44). This placement puts the ignition source in an "upwind position," which, when activated, uses the incoming airflow to promote and accelerate the combustion of the medium, making ignition easier and quicker (’440 Patent, col. 4:30-38). The overall assembly is designed to be detachable for cleaning and loading (’440 Patent, col. 3:26-30).
  • Technical Importance: The invention aims to improve user convenience and safety by integrating the ignition mechanism directly into the device, eliminating the need for external lighters or torches (’440 Patent, col. 1:19-25, col. 3:32-34).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (Compl. ¶17, ¶42).
  • Essential elements of Claim 1 include:
    • A smoker body, a pipe with a combustion chamber, and a base, which are detachably assembled.
    • The smoker body comprising a casing (housing and bottom cover) with a mounting cavity and an air inlet hole.
    • A thermal insulation cover connected to the bottom cover, configured to open or close the combustion chamber, and having its own air inlet port.
    • An automatic igniter arranged in the mounting cavity, comprising an ignition needle that penetrates the bottom cover.
    • The ignition needle is specifically accommodated in the air inlet port, with a gap formed between the bottom cover and the side wall of the port.
    • The ignition needle extends into the combustion chamber to ignite a combustion medium.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "automatic smoker products" sold by the various Defendants through their online stores on the Amazon marketplace (Compl. ¶6, ¶18).

Functionality and Market Context

  • The complaint alleges that the Accused Products are functionally identical in all ways relevant to the ’440 Patent (Compl. ¶24). Specific infringing features are alleged to include "a specific circuit board common to all of the Accused Products sold by all Defendants, a fan in the same housing as the circuit board and battery wherein the fan is not centered in the housing, identical wiring schematis, and other claimed components" (Compl. ¶24). The complaint provides a visual of the Plaintiff's own product, which it states embodies the ’440 Patent and is sold on the same e-commerce platform as the accused devices (Compl. ¶15, Figure 1). Figure 1 of the complaint shows a cylindrical electronic device branded "SMOKPUB," packaged for sale as a cocktail smoker (Compl. ¶15). The complaint alleges these products are competitive with Plaintiff's own product and erode its market share (Compl. ¶44, ¶56).

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed mapping of accused product functionalities to the specific limitations of Claim 1. It makes the general allegation that "the Accused Products include every limitation of Claim 1" (Compl. ¶42). The most specific factual allegations regarding the infringing nature of the products are that they share identical components relevant to the patent, including a specific circuit board, fan, and wiring (Compl. ¶24). A detailed claim chart cannot be constructed from the allegations in the complaint.

Identified Points of Contention

  • Evidentiary Questions: A primary question will be whether Plaintiff can produce evidence demonstrating that the products sold by each of the numerous, unrelated Defendants are, as alleged, "the same in all respects relevant to the patent" (Compl. ¶24). The case may turn on whether discovery reveals that each accused product contains the specific structural arrangement recited in Claim 1, such as the ignition needle, its placement within the air inlet port, and the claimed "gap."
  • Scope Questions: The complaint's theory appears to be one of literal infringement. A potential point of contention may arise if the accused products achieve automatic ignition through a mechanism that is structurally different from the specific configuration claimed, raising the question of whether those alternative designs fall within the scope of the claim language.

V. Key Claim Terms for Construction

The Term: "an automatic igniter"

  • Context and Importance: This term is central to the invention, as it distinguishes the patented device from prior art requiring external ignition. The scope of "automatic igniter" will be critical to the infringement analysis, determining what range of self-contained ignition mechanisms is covered by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not limit the igniter to a specific technology (e.g., electric spark, heating element), which may support an interpretation covering any igniter that is integral to the device and operates without a separate, external heat source.
    • Evidence for a Narrower Interpretation: The claim recites that the igniter "comprises an ignition needle," and the specification describes this needle in a specific structural relationship with other components, such as being installed in an air inlet port and generating an "electric spark" (’440 Patent, col. 4:10-13, col. 4:26-28). A defendant may argue that the term should be limited to the specific electric-spark-generating needle structure disclosed as the only embodiment.

The Term: "a gap is formed between the bottom cover and a side wall of the air inlet port"

  • Context and Importance: This structural limitation appears key to the claimed invention's functionality of using airflow to promote combustion. Practitioners may focus on this term because infringement will depend on whether an accused product possesses this specific spatial relationship, which is described as "enabling the air entering from the air inlet hole 120 to enter the combustion chamber 20" (’440 Patent, col. 4:13-17).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue that any physical separation between the bottom cover and the port's side wall that allows for the passage of air meets this limitation, regardless of its precise dimensions or shape.
    • Evidence for a Narrower Interpretation: A defendant could argue that the term must be construed in light of the figures (e.g., Fig. 7, 9) and the functional requirement described in the specification, potentially limiting the scope to a gap of a particular configuration necessary to create the "upwind" ignition effect (’440 Patent, col. 4:30-38). An accused product that introduces air through a different channel or lacks a distinct gap in this location may be argued to fall outside the claim's scope.

VI. Other Allegations

Indirect Infringement

  • The complaint makes conclusory references to direct and/or indirect infringement (Compl. ¶36, ¶39). However, it does not plead specific facts, such as the existence of instructive user manuals or components with no substantial non-infringing use, that would be required to support claims for induced or contributory infringement.

Willful Infringement

  • The complaint alleges that Defendants acted "knowingly and willfully" (Compl. ¶36, ¶39). The basis for this allegation appears to be the general assertion that Defendants operate as part of a "swarm of other infringers" using tactics to evade enforcement, and that Plaintiff has an "anti-infringement program" (Compl. ¶29, ¶30). The complaint does not allege that any specific Defendant received pre-suit notice of the ’440 Patent.

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

  • A core issue will be one of evidentiary proof: Given the complaint's joinder of numerous anonymous online sellers, a central question is whether Plaintiff can establish that the structurally diverse products sold by each Defendant are, as alleged, functionally identical and practice every specific structural limitation of Claim 1, including the precise configuration of the "automatic igniter" and the claimed "gap."
  • The case may also hinge on claim construction: The outcome will likely depend on whether the term "automatic igniter" is construed broadly to cover any self-contained ignition system, or narrowly limited to the specific electric spark needle embodiment described in the patent. The interpretation of the required "gap" will similarly be crucial in determining the scope of the claim.