DCT
1:25-cv-13387
XYZ Corp v. Individuals Corps Ltd
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Peishi Advertising Media Co., Ltd. (Peoples Republic of China)
- Defendant: [Redacted]
- Plaintiff’s Counsel: Bayramoglu Law Offices LLC
- Case Identification: 1:25-cv-13387, N.D. Ill., 11/26/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district and has engaged in infringing activities by advertising, offering to sell, and shipping infringing products to consumers within the Northern District of Illinois.
- Core Dispute: Plaintiff alleges that Defendant’s automatic smoker products infringe a patent related to an automated ignition system for a combustion medium.
- Technical Context: The technology relates to handheld or portable smokers used to add smoky flavor to food and beverages, focusing on improving the convenience and reliability of igniting the combustible material (e.g., wood chips).
- Key Procedural History: The filing is a Second Amended Complaint, indicating prior amendments to the pleadings in this matter. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2024-09-14 | Patent Priority Date (U.S. 12,324,440) |
| 2025-06-10 | Patent Issue Date (U.S. 12,324,440) |
| 2025-11-26 | 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 a user to place a combustion medium into a chamber and ignite it with an external heat source, which can be inconvenient to operate (’440 Patent, col. 1:21-25).
- The Patented Solution: The invention is an automatic smoker with an integrated igniter. The core inventive concept appears to be the specific placement of an “ignition needle” within an “air inlet port” that feeds air into the combustion chamber (’440 Patent, col. 2:35-44). This positions the igniter in an “upwind position,” so that when it activates, the incoming airflow promotes combustion, enabling the igniter to light the combustion medium “more easily and quickly” (’440 Patent, Abstract).
- Technical Importance: The claimed configuration aims to automate the ignition process, enhancing user convenience and potentially improving the reliability of starting the smoking process (’440 Patent, col. 1:21-25).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 (’440 Patent, Compl. ¶32).
- Independent Claim 1 of the ’440 Patent recites the following essential elements:
- An automatic smoker comprising a smoker body, a pipe with a combustion chamber, and a base.
- The smoker body includes a casing with a bottom cover that has an “air inlet hole.”
- A “thermal insulation cover” is connected to the bottom cover and has an “air inlet port.”
- An “automatic igniter” includes an “ignition needle.”
- The ignition needle penetrates the bottom cover and is “accommodated in the air inlet port.”
- A “gap is formed between the bottom cover and a side wall of the air inlet 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 "Accused Products" are identified as unauthorized smoker devices sold by Defendant through at least one e-commerce store on the Amazon platform (Compl. ¶¶6, 18).
Functionality and Market Context
- The complaint alleges the Accused Products are automatic smokers that incorporate the patented design (Compl. ¶¶16, 31). A screenshot provided in the complaint shows the Defendant’s product listing on an online platform (Compl. ¶21, Ex. 2). This visual depicts a small, cylindrical device marketed as a smoker. The complaint alleges that the success of Plaintiff's own commercial product has resulted in significant infringement by online sellers like the Defendant (Compl. ¶21).
IV. Analysis of Infringement Allegations
The complaint does not provide a detailed claim chart or technical breakdown of the Accused Products. It makes a general allegation that the products sold by Defendant incorporate each element of at least Claim 1 of the ’440 Patent (Compl. ¶¶31-32).
’440 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a casing comprising a housing and a bottom cover...the bottom cover is defined with an air inlet hole | The complaint alleges the Accused Products possess the claimed casing and bottom cover structure. | ¶¶31-32 | col. 13:54-59 |
| a thermal insulation cover, arranged on one side of the bottom cover...and the thermal insulation cover is defined with an air inlet port | The complaint alleges the Accused Products include a thermal insulation cover with an air inlet port. | ¶¶31-32 | col. 13:60-64 |
| an automatic igniter...comprises an ignition needle | The complaint alleges the Accused Products contain an automatic igniter with an ignition needle. | ¶¶31-32 | col. 13:65-col. 14:2 |
| the ignition needle penetrates the bottom cover and is accommodated in the air inlet port | The complaint alleges the Accused Products are configured with an ignition needle positioned within the air inlet port. | ¶¶31-32 | col. 14:1-3 |
| a gap is formed between the bottom cover and a side wall of the air inlet port | The complaint alleges the Accused Products possess the claimed gap for airflow. | ¶¶31-32 | col. 14:3-5 |
| the ignition needle extends into the combustion chamber and is configured to ignite a combustion medium | The complaint alleges the ignition needle in the Accused Products extends into the combustion chamber to perform ignition. | ¶¶31-32 | col. 14:6-8 |
- Identified Points of Contention:
- Evidentiary Questions: A central dispute will likely concern the internal construction of the Accused Products. The complaint makes conclusory allegations of infringement without providing technical evidence (e.g., from a teardown or internal schematics) demonstrating the presence of each claimed element, such as the specific "thermal insulation cover," the "ignition needle" being "accommodated in the air inlet port," or the claimed "gap" for airflow.
- Technical Questions: What evidence does the complaint provide that the Accused Product’s ignition system relies on the claimed “upwind” configuration for enhanced combustion, as opposed to a simpler arrangement where a heating element is merely placed in proximity to the combustible material? The complaint does not offer sufficient detail for analysis of this functional aspect.
V. Key Claim Terms for Construction
The Term: "accommodated in the air inlet port"
- Context and Importance: This term is critical to defining the structural relationship between the ignition needle and the airflow path. Its construction will determine whether the claim requires the needle to be physically enclosed by the port structure or merely positioned within its general vicinity.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain meaning of "accommodated in" could suggest being placed within the area of the port without requiring full structural enclosure.
- Evidence for a Narrower Interpretation: The specification repeatedly states the ignition needle is "installed in the air inlet port" (’440 Patent, col. 4:11-12) and shows it passing through the center of the port structure in figures like FIG. 7. This may support an interpretation requiring the needle to be physically situated within and guided by the port's side walls.
The Term: "a gap is formed between the bottom cover and a side wall of the air inlet port"
- Context and Importance: This limitation defines a specific pathway for airflow around the ignition needle. Infringement will depend on whether the Accused Products have this precise structural feature for this function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any space allowing air to flow past the needle meets this limitation, even if not an explicitly designed "gap."
- Evidence for a Narrower Interpretation: The patent explains that this gap enables "air entering from the air inlet hole...to enter the combustion chamber...from the air inlet port" (’440 Patent, col. 4:14-18). This functional language suggests the gap is a deliberate design feature intended to facilitate airflow, potentially pointing toward a narrower construction that excludes incidental spacing.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing reference to products that infringe "indirectly" (Compl. ¶27), but it does not plead specific facts to support claims of induced or contributory infringement. The sole count in the complaint is for direct patent infringement (Compl. p. 9).
- Willful Infringement: Plaintiff alleges Defendant has acted "knowingly and willfully" (Compl. ¶30). The complaint bases this on general allegations about the nature of online counterfeiters and the success of Plaintiff's own product, rather than on specific facts demonstrating Defendant's pre-suit knowledge of the ’440 Patent (Compl. ¶¶7, 21).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of evidentiary proof: Can the Plaintiff, through discovery, demonstrate that the internal mechanics of the Accused Products map onto every element of Claim 1? The case may depend on technical evidence from a product teardown to establish the precise location of the igniter relative to the air intake structures.
- The dispute may also center on definitional scope: How will the court construe the term "accommodated in the air inlet port"? A narrow construction requiring the ignition needle to be physically enclosed by the port's structure could create a significant hurdle for the infringement case, whereas a broader reading could encompass a wider range of designs.
- A third key question is one of functionality: Does the Accused Product's design achieve ignition through the claimed "upwind" airflow mechanism, or does it utilize a fundamentally different technical method? The answer will be crucial in determining whether the Accused Product practices the patented invention.