DCT

2:25-cv-06641

Shenzhen Jisu Technology Co Ltd v. Individuals Corps Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-06641, D.N.J., 06/02/2025
  • Venue Allegations: Venue is alleged based on Defendants structuring their business to target consumers in the United States, including New Jersey, through interactive e-commerce stores that ship to the state and accept payment in U.S. dollars.
  • Core Dispute: Plaintiff alleges that Defendants’ e-commerce stores sell unauthorized products that infringe a patent related to a mechanical rack for displaying rugs.
  • Technical Context: The dispute arises at the intersection of modern e-commerce, where anonymous sellers operate on large platforms, and patent law governing mechanical devices.
  • Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or licensing history concerning the patent-in-suit. It notes that Plaintiff has an "anti-infringement program that involves investigating suspicious websites and online marketplace listings."

Case Timeline

Date Event
1913-03-19 Patent '050 Priority Date
1913-07-22 Patent '050 Issue Date
2025-06-02 Complaint Filing Date

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

U.S. Patent No. 1,068,050 - "Rack for Displaying Rugs"

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty of lifting and displaying heavy rugs and carpets for inspection by customers in a retail environment. (’050 Patent, col. 1:11-20).
  • The Patented Solution: The invention claims to solve this problem with a rotatable, vertically adjustable display rack. The core of the solution is a hoisting mechanism, comprising a system of fixed and movable pulleys and a cable, which provides increased leverage to an operator for raising and lowering a rug-supporting arm. (’050 Patent, col. 2:30-43; Fig. 1). A gravity-operated pawl is included to lock the arm in its raised, full display position. (’050 Patent, col. 1:26-27).
  • Technical Importance: The design's compact hoisting arrangement was intended to permit multiple racks to be installed close to one another, thereby maximizing the number of rugs that could be displayed within a finite retail space. (’050 Patent, col. 3:71-77).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted. The patent contains one claim, which is an independent claim.
  • The essential elements of the single claim include:
    • A rug retaining T-shaped arm.
    • A pivotal I-shaped upright with a stud on its front face.
    • A first hanger fixed to the upright with multiple independent sheaves.
    • A second hanger carried by the arm with multiple independent sheaves positioned below and parallel to the first hanger's sheaves.
    • A cable secured to the first hanger and passing over the sheaves of both hangers to increase leverage.
    • A fork-shaped movable block embracing the upright's front flange.
    • A bar connecting the movable hanger to the block and a brace connecting the arm to the block.
    • A gravity-operated pawl on the block that cooperates with the stud on the upright to hold the arm in a display position.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Unauthorized Products" (Compl. ¶2) sold by Defendants through e-commerce stores on platforms such as Amazon, eBay, Temu, and Walmart (Compl. ¶10). Defendants operate these stores under the "Seller Aliases" listed in Schedule A, which was not included in the provided document. (Compl. ¶2).

Functionality and Market Context

  • The complaint does not provide a technical description of the "Unauthorized Products." It alleges that they "embody Plaintiff's Patent" and are "substantially similar to, or at least a colorable imitation of the claimed design of Plaintiff's Patent." (Compl. ¶8, ¶26). The complaint contains a redacted image labeled "Figure 1: Plaintiff's Products," but it does not depict the accused products directly. (Compl. p. 4). Another visual reference describes "screenshot printouts showing active listings of the Unauthorized Products" in Exhibit 2, which was not provided. (Compl. ¶10).
  • The complaint alleges that the success of Plaintiff's own products has led to significant infringement by Defendants, who allegedly use anonymity and multiple storefronts to target U.S. consumers and evade enforcement. (Compl. ¶3, ¶10).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of a design patent and refers to a "claims chart attached as Exhibit 3" to support this allegation (Compl. ¶6, ¶26). However, this exhibit is not provided, and the only patent document available for analysis is U.S. Patent No. 1,068,050, a utility patent. The complaint does not contain allegations mapping the accused products to the specific limitations of the utility patent's claim. Therefore, a claim chart cannot be constructed, and the infringement theory must be summarized from the complaint's narrative.

The complaint’s infringement theory is based on the test for design patent infringement. It alleges that the "Unauthorized Products are substantially similar to, or at least a colorable imitation of the claimed design of Plaintiff's Patent" (Compl. ¶26). The complaint alleges that Defendants have directly infringed "by making, using, importing, selling, and/or offering to sell infringing goods in the United States without authorization or license from Plaintiff." (Compl. ¶27).

  • Identified Points of Contention:
    • Legal Question: A fundamental conflict exists between the complaint's allegations of design patent infringement (Compl. ¶6, ¶26) and the provided utility patent. This raises a threshold question as to which patent is actually being asserted and whether the complaint properly states a claim for infringement.
    • Scope Question: A primary issue is whether the "Unauthorized Products," which are sold via e-commerce marketplaces, could be found to practice the specific mechanical combination claimed in a 1913 patent for a large-scale "Rack for Displaying Rugs."
    • Technical Question: The complaint provides no technical evidence or description to suggest that the "Unauthorized Products" contain the specific structures recited in the '050 patent's claim, such as a "pivotal I-shaped upright," a "fork-shaped movable block," or a "gravity operated pawl."

V. Key Claim Terms for Construction

  • The Term: "rug retaining T-shaped arm"

    • Context and Importance: This term defines the primary component for holding the displayed article. Its construction will be critical for determining the scope of the claim, particularly as the complaint provides no information on the nature of the "Unauthorized Products" or what they are designed to hold.
    • Intrinsic Evidence for a Broader Interpretation: The specification refers to the display of "carpets, rugs and the like," which may support an argument that the arm is not limited to holding only literal rugs. (’050 Patent, col. 1:14).
    • Intrinsic Evidence for a Narrower Interpretation: The specification describes and Figure 1 depicts a specific T-beam structure with "spurs or pins 8" for securing the article, which could support a narrower construction requiring these features. (’050 Patent, col. 1:51-56).

  • The Term: "pivotal I-shaped upright"

    • Context and Importance: This term describes the main structural support of the entire apparatus. Practitioners may focus on this term because there is no allegation that the accused e-commerce products incorporate any feature resembling a large, pivoting I-beam.
    • Intrinsic Evidence for a Broader Interpretation: A party might argue that "upright" should be construed broadly to mean any vertical support member, and "I-shaped" is merely an exemplary embodiment.
    • Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly and specifically refers to an "I-beam" and the claim recites an "I-shaped upright," suggesting the specific cross-sectional profile is a required limitation. (’050 Patent, col. 1:40-41).

VI. Other Allegations

  • Indirect Infringement: The complaint makes a passing reference to "Aiding, abetting, contributing to, or otherwise assisting anyone in infringing" in its prayer for relief but does not plead specific facts to support a claim for either induced or contributory infringement against the Defendants. (Compl. Prayer for Relief ¶1(b)). The core allegations are directed to Defendants' own acts of making, using, and selling. (Compl. ¶27).
  • Willful Infringement: Willfulness is alleged based on Defendants "knowingly and willfully" infringing in "active concert." (Compl. ¶22, ¶30). The factual support for this claim appears to be the alleged pattern of conduct used to evade intellectual property enforcement, such as operating under fictitious "Seller Aliases," using fraudulent registration information, and operating from offshore locations. (Compl. ¶3, ¶17-19).

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

  • A central issue will be one of legal and factual coherence: the complaint alleges infringement of a design patent, but the only patent provided is a utility patent from 1913. The court will first need to resolve this fundamental discrepancy regarding the intellectual property at issue and whether the accused online consumer products could plausibly infringe the claims of a patent for a large, mechanical rug display rack.
  • A key evidentiary question will be one of pleading sufficiency: the complaint's infringement allegations rely on a "claims chart" (Exhibit 3) that was not provided and fail to map the accused products to the specific limitations of the provided patent's claim. This raises the question of whether the infringement count meets the plausibility standard required by federal pleading rules.
  • A dispositive question may be one of claim scope: even if the legal and procedural hurdles are overcome, the case will likely turn on whether claim terms like "pivotal I-shaped upright" and "rug retaining T-shaped arm" can be construed broadly enough to read on the undescribed "Unauthorized Products" sold by Defendants.