DCT

1:26-cv-00125

Shenzhenshiriduoyukejiyouxiangongsi v. Marvel Technology China Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00125, N.D. Ill., 01/07/2026
  • Venue Allegations: Plaintiffs allege venue is proper because the Defendant is not a resident of the United States, and therefore may be sued in any judicial district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their photo booth stands do not infringe two of the Defendant’s patents and that those patents are invalid, following Defendant's patent enforcement actions on Amazon.com that led to the delisting of Plaintiffs' products.
  • Technical Context: The technology concerns ring lamp supports for cameras and smart devices, a product category significant in the markets for social media content creation, vlogging, and amateur photography.
  • Key Procedural History: The complaint alleges a pattern of conduct wherein the Defendant asserted infringement of the '842 Patent against Plaintiffs' products via Amazon's internal reporting system, leading to their delisting. After Plaintiffs successfully appealed and had the products relisted, Defendant allegedly declined to use Amazon's neutral evaluation process (APEX). Instead, Defendant is alleged to have asserted a different patent, the '722 Patent, against the same products, triggering another delisting cycle.

Case Timeline

Date Event
2023-11-07 '722 Patent Priority Date
2024-01-25 '842 Patent Priority Date
2025-02-18 '842 Patent Issue Date
2025-08-14 Marvel begins asserting '842 Patent on Amazon
2025-09-24 Amazon relists products accused of infringing '842 Patent
2025-10-21 '722 Patent Issue Date
2025-12-04 Marvel begins asserting '722 Patent on Amazon
2025-12-22 Amazon relists most products accused of infringing '722 Patent
2026-01-07 Complaint Filing Date

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

U.S. Patent No. 12,228,842 - *"RING LAMP SUPPORT FOR SHOOTING DEVICE"*

  • Issued: February 18, 2025 (’842 Patent)

The Invention Explained

  • Problem Addressed: The patent's background describes prior art shooting devices with supplemental lighting as having limited functionality, often just a simple on/off switch, resulting in monotonous lighting and a "poor user experience" (’842 Patent, col. 1:24-34).
  • The Patented Solution: The invention is a support for a shooting terminal that integrates an adjustable light source. The core structure is a "fixing piece" that holds the shooting terminal (e.g., a smartphone), which itself consists of a top shell, a limiting frame, and a bottom shell. A ring-shaped light is disposed on the periphery of this fixing piece, allowing the light and the terminal to be adjusted together while offering control over color temperature, brightness, and other parameters via a circuit board (’842 Patent, col. 1:41-54, Abstract).
  • Technical Importance: By mechanically and electronically integrating an adjustable light source with the device holder, the invention provides for more consistent and controllable lighting as a user repositions the camera, a key consideration for content creators (’842 Patent, col. 2:62-col. 3:5).

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claims 1, 6, and 9 (Compl. ¶34).
  • Independent Claim 1 requires, among other elements:
    • A fixing piece comprising a top shell, a limiting frame, and a bottom shell.
    • A shooting terminal disposed in the limiting frame.
    • A ring-shaped first light emitting piece.
    • A hollow portion of the ring-shaped first light emitting piece is clamped between the top shell and the bottom shell.
  • Independent Claim 6 requires, among other elements:
    • A support bracket, a universal adjusting piece, a first light emitting piece, and a fixing piece.
    • A support rod connected to the fixing piece through the universal adjusting piece.
    • The first light emitting piece comprises at least one USB interface electrically connected to the shooting terminal.
    • A bottom shell of the fixing piece defines a notch, and a connecting wire passes through the notch to connect the terminal to the USB interface.
  • Independent Claim 9 requires, among other elements:
    • A first light emitting piece and a second light emitting piece.
    • The first light emitting piece comprises at least one USB interface electrically connected to a shooting terminal.
    • A bottom shell of the fixing piece defines a notch, and a connecting wire passes through the notch to connect the terminal to the USB interface.
  • The complaint does not explicitly reserve the right to assert non-infringement of dependent claims.

U.S. Patent No. 12,449,722 - *"RING LAMP SUPPORT FOR SHOOTING TERMINAL"*

  • Issued: October 21, 2025 (’722 Patent)

The Invention Explained

  • Problem Addressed: The patent identifies a need to simplify the adjustment of shooting devices. Prior art systems often require separate mechanisms to adjust for pitch, rotation, and landscape/portrait orientation, which increases assembly workload, production cost, and adjustment time for the user (’722 Patent, col. 1:38-52).
  • The Patented Solution: The invention proposes a single "universal adjusting piece," such as a shapeable coiled pipe or a ball-and-socket joint, that connects the main support bracket to the piece that fixes the shooting terminal. This single joint is designed to enable multi-dimensional adjustments, thereby simplifying the device's overall structure and improving adjustment efficiency (’722 Patent, Abstract; col. 2:53-65).
  • Technical Importance: This design consolidates multiple adjustment functions into a single mechanical interface, potentially making the support faster and more intuitive to operate in dynamic shooting environments.

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claim 1 (Compl. ¶75).
  • Independent Claim 1 requires, among other elements:
    • A support bracket, a universal adjusting piece, a first light emitting piece, and a fixing piece.
    • The universal adjusting piece is connected between the support bracket and the fixing piece.
    • The fixing piece comprises a top shell, a limiting frame, and abutting pieces.
    • The abutting pieces are connected with the limiting frame and abut against a rear side of the shooting terminal.
  • The complaint does not explicitly reserve the right to assert non-infringement of dependent claims.

III. The Accused Instrumentality

Product Identification

  • The "Disputed Photo Stands" sold by the Plaintiffs on Amazon.com under the storefront names "RDYMONKEY," "ROOMEDAL," and "ZLPOWER" (Compl. ¶¶3, 6, 8, 10). The complaint groups the products into three categories: "Accused Multi-Light Stands," "Accused Single-Light Stands," and "Accused Square Multi-Light Stands" (Compl. ¶¶29, 65).

Functionality and Market Context

  • The products are described as "photo booth stands" and "ring lamp support for a shooting device" (Compl. ¶¶3, 25, 61). Their function is to hold a device like a smartphone or tablet for photography or videography while providing illumination. The complaint alleges that Amazon.com is the Plaintiffs' "primary sales channel," and the dispute arose from Defendant’s use of Amazon’s intellectual property reporting procedures to have Plaintiffs' product listings removed (Compl. ¶¶4, 21-22, 63-64).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiffs' stated reasons why their products do not meet certain claim limitations.

'842 Patent Infringement Allegations

Claim Element (from Independent Claim 1, 6, or 9) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a hollow portion of the ring-shaped first light emitting piece is clamped between the top shell and the bottom shell (Claim 1) The Accused Multi-Light and Single-Light Stands do not include a hollow portion of a light emitting piece clamped between a top and bottom shell. ¶36, ¶37 col. 12:1-4
a second end of the support rod is connected to the fixing piece through the universal adjusting piece (Claim 6) The Accused Single-Light Stands do not include a universal adjusting piece connecting a support rod to a fixing piece. ¶45 col. 12:35-41
a connecting wire connecting the shooting terminal to the at least one USB interface passes through the notch (Claims 6 & 9) The Accused Multi-Light Stands are not sold with a shooting terminal or a connecting wire for this purpose. Plaintiffs further allege they do not instruct users to create such a configuration. ¶41, ¶42, ¶43 col. 12:35-41; col. 14:4-10
a second light emitting piece... wherein the second light emitting piece is disposed on the support body (Claim 9) The Accused Single-Light Stands do not include a second light emitting piece located in the support body. ¶47 col. 13:1-22

'722 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
the universal adjusting piece is connected between the support bracket and the fixing piece The Accused Multi-Light, Single-Light, and Square Multi-Light Stands do not include a universal adjusting piece connected between a support bracket and a fixing piece. ¶77, ¶78, ¶79 col. 12:1-6
the abutting pieces are connected with the limiting frame and abut against a rear side of the shooting terminal The Accused Multi-Light, Single-Light, and Square Multi-Light Stands do not include abutting pieces as required by the claim. ¶81, ¶82, ¶83 col. 12:12-20
  • Identified Points of Contention: The non-infringement arguments presented in the complaint are based on categorical assertions that the accused products entirely lack specific, physical structures recited in the independent claims. This suggests the core of the dispute may not be subtle claim interpretation, but rather a direct comparison of the accused products' physical construction against the claim language. The dispute over claims 6 and 9 of the ’842 Patent also raises the question of whether infringement can be established for a system claim when not all components (e.g., the "connecting wire") are sold with the accused product.

V. Key Claim Terms for Construction

  • The Term: "universal adjusting piece" (’722 Patent, Claim 1)

  • Context and Importance: Plaintiffs' non-infringement defense against the ’722 Patent hinges on the assertion that their products lack this component entirely (Compl. ¶¶77-79). The scope of this term is therefore central to the dispute. Practitioners may focus on this term because its definition will determine whether the adjustment mechanisms on the accused products, whatever they may be, fall within the claim's scope.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification discloses that the term can encompass different structures, stating it "is a shapeable coiled pipe, or, the universal adjusting piece comprises a ball head and a rotating collet" (’722 Patent, col. 2:2-5). A party could argue this language supports a functional definition covering any single component that enables multi-dimensional adjustment.
    • Evidence for a Narrower Interpretation: The specification only provides two distinct examples (coiled pipe, ball-and-socket). A party could argue the term should be limited to these disclosed embodiments and their structural equivalents, potentially excluding other types of joints or hinges.

  • The Term: "clamped between" (’842 Patent, Claim 1)

  • Context and Importance: This limitation is the basis for Plaintiffs' non-infringement argument against claim 1 of the ’842 Patent (Compl. ¶¶36-37). Whether the accused products' light-holding mechanism constitutes "clamping" will be a dispositive issue for this claim.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The detailed description uses the word "sandwiched" to describe the relationship between the light emitting piece and the top and bottom shells (’842 Patent, col. 9:1-4). This may support an interpretation that covers any configuration where the light is held between the two shell components, regardless of the precise fastening method.
    • Evidence for a Narrower Interpretation: The term "clamped" itself suggests the application of a compressive force or a specific fastening action, which could be construed more narrowly than merely being "sandwiched" or positioned between two parts. The specific locking mechanisms shown in the patent's figures could be used to argue for a more limited structural meaning.

VI. Other Allegations

  • Indirect Infringement: In its non-infringement allegations regarding the '842 Patent, the complaint preemptively addresses indirect infringement. It alleges that because Plaintiffs do not instruct users to connect a shooting terminal to the light's USB interface or pass a wire through a notch, they do not induce infringement of claims 6 or 9 (Compl. ¶¶42-43).

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

  • A primary issue will be one of structural correspondence: Do the accused photo stands physically incorporate the specific mechanical components recited in the independent claims—such as the "clamped hollow portion" ('842 Patent), the "universal adjusting piece," and the "abutting pieces" ('722 Patent)—or are these elements demonstrably absent from the accused products as Plaintiffs allege?
  • For certain claims of the '842 Patent, a key question will be one of product configuration: Does the claim language requiring a "connecting wire" between the light and a "shooting terminal" necessitate that these components be sold together as a single commercial product, or can liability arise if the accused stand is merely designed for use with a customer’s separately-provided terminal and wire?
  • A significant non-patent issue that may influence the litigation's context is whether Defendant's alleged strategy—filing serial, ex parte infringement reports on an e-commerce platform while declining to use that platform's neutral adjudication mechanism (APEX)—constitutes tortious interference with Plaintiffs' business relations, particularly if the underlying infringement claims are ultimately found to be without merit.