DCT

2:25-cv-15740

Shanghai Qianzhuo Network Technology Co Ltd v. Lufranco

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-15740, D.N.J., 09/17/2025
  • Venue Allegations: Venue is based on the Defendant’s residence within the District of New Jersey.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their pet feeding trays do not infringe Defendant’s patent and/or that the patent is invalid, in response to Defendant’s infringement complaints on e-commerce platforms.
  • Technical Context: The dispute centers on pet toys designed to combine claw grooming, via an abrasive surface, with enrichment features like scent or treat cavities.
  • Key Procedural History: The action was precipitated by Defendant lodging infringement complaints with Amazon and Walmart, which resulted in the removal of Plaintiffs' product listings. The complaint notes that specific limitations in the asserted patent claims were added during prosecution to distinguish prior art, a factor that may influence claim construction.

Case Timeline

Date Event
2019-01-02 U.S. Patent No. 11,930,789 Priority Date
2024-03-19 U.S. Patent No. 11,930,789 Issue Date
2025-03-XX Defendant lodges first Amazon complaint against Plaintiffs' "M Tray"
2025-04-03 Defendant threatens legal action against Plaintiffs' representative
2025-09-17 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,930,789 - "PET TOY"

  • Patent Identification: U.S. Patent No. 11,930,789, "PET TOY," issued March 19, 2024 (the “’789 Patent”).

The Invention Explained

  • Problem Addressed: The patent background describes a need for pet toys that provide multiple benefits, combining amusement and enrichment with practical grooming and dental hygiene functions. (’789 Patent, col. 1:11-29).
  • The Patented Solution: The invention is a multi-purpose pet toy that features a body with pad surfaces for adhering abrasive material to dull a pet's claws, an internal cavity for holding treats, and separate "scent receptacles" to encourage play. (’789 Patent, Abstract; col. 2:15-18; col. 3:1-5). Certain embodiments also include guard projections to prevent the abrasive surface from scratching floors and handles for interactive play. (’789 Patent, col. 2:61-67).
  • Technical Importance: The claimed invention seeks to integrate passive grooming (claw filing) with behavioral enrichment (treats, scents, and play) into a single device. (’789 Patent, col. 2:15-28).

Key Claims at a Glance

  • The complaint identifies independent claims 1 and 18 as being at issue (Compl. ¶36).
  • Independent Claim 1 requires, among other elements:
    • A body with various faces and sides.
    • At least one face having both "a pad surface for adhering an abrasive material" and "one or more substantially circular scent cavities."
    • An "internal central cavity" and an "aperture" for access.
    • At least one "handle, made of an elastic material" that includes grooves configured to clean pet teeth.
  • Independent Claim 18 requires, among other elements:
    • A body with various faces and sides.
    • At least one face having both "a pad surface for adhering an abrasive material" and "a guard projection extending in a perpendicular direction with respect to the pad surface" configured to prevent the abrasive from contacting a flat surface.
    • An "internal central cavity" and an "aperture" for access.
    • At least one "handle" for grasping the toy.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two accused products: the "Flat Tray" and the "M Tray" (Compl. ¶¶ 20, 21).

Functionality and Market Context

  • The products are described as "dog feeding tray[s]" sold by Plaintiffs on e-commerce platforms such as Amazon and Walmart (Compl. ¶¶ 14, 20, 31).
  • Visual evidence in the complaint shows the Flat Tray as a flat, oval-shaped board with a textured, presumably abrasive, top surface and a single, central rectangular cavity. An image of the Flat Tray shows its dark, textured surface and central rectangular cutout (Compl. ¶20).
  • The M Tray is depicted as having a similar overall design but with a more complex, multi-level rectangular cavity in its center (Compl. ¶21).
  • Plaintiffs allege that Defendant's infringement complaints to third-party e-commerce platforms resulted in the removal of the Flat Tray and M Tray products, causing lost sales and damage to their business (Compl. ¶¶ 47, 48).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiffs' primary arguments for why their products do not meet specific limitations of the asserted claims.

’789 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
one or more substantially circular scent cavities configured to receive a scent material The Flat Tray and M Tray products are alleged to have a single central cavity that is rectangular, not "substantially circular." The complaint includes a photograph of the Flat Tray highlighting its rectangular cavity (Compl. ¶52). ¶¶ 50-53 col. 3:1-5
Claim Element (from Independent Claim 18) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a guard projection extending in a perpendicular direction with respect to the pad surface and configured to prevent the abrasive material from contacting a flat surface... The Flat Tray and M Tray are alleged to be flat and to lack any perpendicular projections designed to prevent the abrasive surface from contacting a surface on which the tray is placed. A photograph depicts the flat profile of the Flat Tray (Compl. ¶56). ¶¶ 54-59 col. 2:61-67
  • Identified Points of Contention:
    • Scope Questions: The dispute raises the question of whether the claim term "substantially circular" can be interpreted to cover the "rectangular" cavities present in the accused trays. Plaintiffs also contend that their products' flat design does not include the "guard projection" required by Claim 18, raising a question about the presence of a claimed physical structure.
    • Technical Questions: A central technical question is whether the single, central feeding cavity in the accused products performs the function of the "scent cavities" as described in the patent, especially when the patent specification depicts the scent cavities as distinct features separate from the main central cavity (’789 Patent, Fig. 1). Another question is whether any part of the accused trays, such as their outer edge, could be argued to function as the claimed "guard projection."

V. Key Claim Terms for Construction

  • The Term: "substantially circular scent cavities" (Claim 1)

  • Context and Importance: This term is central to the non-infringement argument for Claim 1. Plaintiffs allege their products have a single rectangular cavity, which they argue falls outside the scope of "substantially circular" (Compl. ¶¶ 52, 53). The case may turn on whether this term is broad enough to read on a rectangular shape.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A defendant could argue that the modifier "substantially" allows for deviation from a perfect circle.
    • Evidence for a Narrower Interpretation: The specification describes and depicts "generally circular cavities or scent receptacles 60 formed at the corners of the upper face," suggesting they are distinct, numerous, and located at the periphery, unlike the single, central, rectangular cavity in the accused products (’789 Patent, col. 3:1-4; Fig. 1). This suggests the "scent cavities" are structurally and functionally different from the "internal central cavity 70" for treats (’789 Patent, col. 3:6-13).

  • The Term: "a guard projection extending in a perpendicular direction with respect to the pad surface" (Claim 18)

  • Context and Importance: This limitation is the basis for Plaintiffs' non-infringement argument regarding Claim 18. They assert their products are flat and lack any such structure (Compl. ¶¶ 54, 56). Practitioners may focus on this term because the complaint alleges it was added during prosecution to overcome prior art, which could support a narrower construction under the doctrine of prosecution history estoppel (Compl. ¶¶ 42, 45).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A defendant might argue that the thickness of the tray's body itself creates a raised edge that functions as a "guard projection" by minimally elevating the central abrasive pad.
    • Evidence for a Narrower Interpretation: The specification describes "guard projections 50 which extend slightly above the respective upper pad surface 40... to prevent the abrasive material... from contacting and marring a flat surface" (’789 Patent, col. 2:61-66). The patent figures show these as distinct, raised ridges encircling the pad surface, a structure absent from the accused products as depicted in the complaint (Compl. ¶56).

VI. Other Allegations

  • The complaint does not provide sufficient detail for analysis of patent-specific allegations such as indirect or willful infringement by the Plaintiffs. Instead, it makes allegations of tortious interference against the Defendant for allegedly making baseless infringement accusations to third-party platforms (Compl. ¶¶ 66-77).

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

  • A core issue will be one of definitional scope: can the term "substantially circular scent cavities," which the patent specification depicts as small, peripheral features, be construed to cover the single, central, rectangular feeding cavity of the accused products?
  • A second key issue will be one of prosecution history and structural presence: given that the "guard projection" limitation was allegedly added to overcome prior art, does any feature of the accused flat trays meet this limitation, or is the claim scope narrowed such that it requires the distinct, raised ridges shown in the patent's figures?
  • Finally, the viability of the Plaintiffs' tortious interference claim will likely depend on the objective reasonableness of the Defendant's infringement position. A finding of clear non-infringement on the patent claims may support the argument that the Defendant's e-commerce complaints were made without a reasonable basis.