DCT
6:25-cv-03053
Dongguan Zhaorui Industrial Technology Co Ltd v. Uriah Products LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Zhaorui Industrial Technology Co., Ltd. et al. (China)
- Defendant: Uriah Products, LLC (Missouri)
- Plaintiff’s Counsel: AVEK IP, LLC; Glacier Law LLP
- Case Identification: 6:25-cv-03053, W.D. Mo., 03/11/2025
- Venue Allegations: Venue is alleged to be proper in the Western District of Missouri because Defendant Uriah Products, LLC resides in the district.
- Core Dispute: Plaintiffs, a group of product manufacturers and sellers, seek a declaratory judgment that their adjustable trailer hitch products do not infringe Defendant’s patent, and that the patent is invalid.
- Technical Context: The technology concerns adjustable trailer hitch assemblies, which allow a user to change the vertical height of a trailer ball to match different trailer and vehicle combinations.
- Key Procedural History: This declaratory judgment action was initiated by Plaintiffs following infringement complaints filed by the Defendant with Amazon.com, which resulted in the removal of Plaintiffs' product listings. The patent-in-suit, U.S. Patent No. 10,857,846, was the subject of an ex parte reexamination, which concluded on August 12, 2024, with the confirmation of the patentability of all original claims 1-16.
Case Timeline
| Date | Event |
|---|---|
| 2017-04-11 | Priority Date for U.S. Patent No. 10,857,846 |
| 2020-12-08 | Issue Date for U.S. Patent No. 10,857,846 |
| 2024-08-12 | Reexamination Certificate for '846 Patent Issued |
| 2025-03-11 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,857,846 - Adjustable Hitch Assembly
Issued Dec. 8, 2020
The Invention Explained
- Problem Addressed: The patent background section situates the invention in the field of "ball and socket type hitch apparatus" for land vehicles, implying a need for improved designs in this area ('846 Patent, col. 1:13-15).
- The Patented Solution: The patent describes an adjustable hitch assembly featuring two main components: an L-shaped hitch bracket and a vertically-adjustable C-shaped mounting block ('846 Patent, Abstract; col. 1:56-62). The L-shaped bracket has a horizontal drawbar (for insertion into a vehicle's receiver tube) and a vertical "tenon portion." The C-shaped mounting block, which holds the hitch ball(s), is designed with a "slotted mortise hole" that slides vertically along the tenon, allowing its height to be adjusted and secured with pins ('846 Patent, col. 3:35-44).
- Technical Importance: The design aims to provide a robust, highly adjustable hitch, with the specification noting embodiments that provide significant drop/rise capability (e.g., a six-inch drop and six-and-three-quarters-inch rise) while withstanding high tensile loads ('846 Patent, col. 2:58-62; col. 5:1-6).
Key Claims at a Glance
- The complaint focuses its non-infringement analysis on Independent Claim 1.
- Essential elements of Independent Claim 1 include:
- An L-shaped "hitch bracket" with a horizontal drawbar and a vertical "tenon portion."
- A "vertically-adjustable hitch-ball mounting block" comprising a web and arms with "in-turned flanges...which collectively define a slotted mortise hole" for receiving the tenon.
- The web of the mounting block defining a "rear wall for the slotted mortise hole" and being "formed with a generally vertical through hole."
- A hitch ball with a "cylindrical shank base" that is received in the through hole.
- The "rear wall for [the] slotted mortise hole" being "formed with a pin-receiving hole into the through hole and adapted for a pin to secure the hitch ball."
- The complaint does not explicitly reserve the right to assert dependent claims, but the invalidity count appears to challenge all claims (Compl. ¶¶ 34-35).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are various models of adjustable trailer hitches sold by the plaintiffs, including the "Soki&Koer," "OCTORA," "ANTBAY," "CAMPX," "TOPBEE," and "VOMAVEX" brands (Compl. ¶¶ 23-28).
Functionality and Market Context
- The products are adjustable trailer hitches sold on Amazon.com (Compl. ¶2). The complaint alleges that Defendant's infringement assertions to Amazon led to the removal of these product listings, causing financial harm to Plaintiffs (Compl. ¶5, ¶18). The core of Plaintiffs' non-infringement argument is that their products achieve adjustability and hitch ball mounting through structures that are fundamentally different from those required by the claims of the ’846 Patent (Compl. ¶19).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiffs' allegations regarding how their products fail to meet the limitations of Claim 1 of the ’846 Patent.
'846 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| in-turned flanges on the arms spaced away from the web which collectively define a slotted mortise hole | The mounting blocks on Plaintiffs' products allegedly do not have the claimed "in-turned flanges" that are required to form the "slotted mortise hole." One accused product is depicted in an annotated photograph to show an "arm" that allegedly lacks this feature. | ¶23(1); ¶27(1) | col. 5:35-41 |
| said rear wall for slotted mortise hole of the vertically-adjustable hitch-ball mounting block is formed with a pin-receiving hole into the through hole and adapted for a pin to secure the hitch ball | The mounting blocks on Plaintiffs' products allegedly lack a "pin-receiving hole" in the rear wall for securing the hitch ball. The complaint alleges the products use alternative methods, such as a lock washer or compression fittings. An annotated photo shows an accused product's rear wall, which is alleged to lack the required hole. | ¶24(1)-(2); ¶25(1)-(2) | col. 5:55-58 |
| the hitch ball comprises a cylindrical shank base that transitions into a neck which in turn transitions into a ball head | Plaintiffs allege that in some products, the hitch balls are permanently affixed to the mounting block, which they contend eliminates the need for the pin-receiving structure described in the patent. | ¶23(2) | col. 5:49-51 |
- Identified Points of Contention:
- Structural Questions: The central dispute appears to be a structural one. Do the accused products, which possess some form of channel for vertical adjustment, contain the specific "in-turned flanges" required to form the "slotted mortise hole" as claimed? The complaint's annotated photograph of the TOPBEE hitch highlights the product's "arm," alleging it lacks the claimed flanges (Compl. p. 8).
- Functional Questions: A key question is whether the methods used by the accused products to secure the hitch ball (e.g., "lock washer," "compression fittings") are functionally and structurally different from the claimed "pin-receiving hole...adapted for a pin to secure the hitch ball." An annotated photograph of the ANTBAY hitch points to a "Lock Washer" as the securing mechanism (Compl. p. 7).
V. Key Claim Terms for Construction
The Term: "slotted mortise hole"
Context and Importance: This term is central to the structure of the claimed mounting block. Plaintiffs repeatedly allege their products lack the "slotted mortise hole" as defined in the patent (Compl. ¶19, ¶23(1), ¶26(1)). The construction of this term will determine whether the channels in the accused products fall within the scope of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Narrower Interpretation: The specification explicitly links the term to a specific structure: "...the vertically-adjustable hitch-ball mounting block comprises a web, arms extending out of the web, and in-turned flanges on the arms spaced away from the web which collectively define a slotted mortise hole..." ('846 Patent, col. 5:35-39). This language may support an interpretation requiring the presence of all listed components, including "in-turned flanges."
- Evidence for a Broader Interpretation: A party might argue that "slotted mortise hole" should be given a broader meaning encompassing any channel that performs the function of receiving the tenon for sliding adjustment. However, the patent's detailed description of this structure may limit the viability of a significantly broader construction.
The Term: "pin-receiving hole"
Context and Importance: This term defines how the hitch ball is secured to the mounting block. Plaintiffs' primary non-infringement argument is that their products use different securing mechanisms (Compl. ¶19, ¶24, ¶25). Practitioners may focus on this term because if it is construed to only cover a hole for a literal pin, the non-infringement argument for products using lock washers appears strong.
Intrinsic evidence for Interpretation:
- Evidence for a Narrower Interpretation: Claim 1 requires a "pin-receiving hole...adapted for a pin to secure the hitch ball" ('846 Patent, col. 5:57-58). Dependent claims further detail the use of a "threaded fastener" acting as the pin ('846 Patent, col. 6:13-22). This context may support a construction limited to structures that secure the ball via a pin-like fastener passing through the rear wall.
- Evidence for a Broader Interpretation: A party could argue that the term should be understood more functionally to mean any aperture that facilitates securing the hitch ball. The complaint's allegations that some products use "compression fittings" (Compl. ¶28(2)) suggests a factual dispute over whether any part of that mechanism could be characterized as a "pin-receiving hole."
VI. Other Allegations
- Indirect Infringement: The complaint does not contain allegations regarding indirect infringement.
- Willful Infringement: The complaint does not allege willful patent infringement. However, in its separate tort-based counts, the Plaintiffs allege that Defendant's conduct in filing complaints with Amazon was "willful, wanton, and malicious" (Compl. ¶44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A Core Definitional Question: Can the term "slotted mortise hole," which the patent defines as being formed by specific "in-turned flanges," be construed to read on the accused products' mounting channels, which Plaintiffs allege lack these flanges? The outcome will likely depend on whether the court views "in-turned flanges" as an essential structural requirement or merely part of a preferred embodiment.
- A Question of Structural and Functional Difference: Does the claimed "pin-receiving hole" for securing the hitch ball require a structure for a literal pin, or can it be interpreted to cover the alternative "lock washer" and "compression fitting" mechanisms alleged to be used in the accused products?
- The Impact of Reexamination on Invalidity: Plaintiffs have challenged the patent's validity based on prior art (Compl. ¶¶ 32-36). A crucial issue will be the extent to which the prior ex parte reexamination, which confirmed the patentability of all claims, impacts this challenge. The court will have to consider whether the prior art now cited by Plaintiffs is the same as or cumulative to the art already considered by the USPTO during that proceeding.