DCT
3:24-cv-10544
Suzhou Hupan Network Technology Co Ltd v. Accession Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Suzhou Hupan Network Technology Co., Ltd. (and nine other entities) (China)
- Defendant: Accession Inc. (New Jersey)
- Plaintiff’s Counsel: Peckar & Abramson, P.C.; Glacier Law LLP
- Case Identification: 3:24-cv-10544, D.N.J., 11/16/2024
- Venue Allegations: Venue is based on Defendant being a New Jersey corporation with its principal place of business in Cream Ridge, New Jersey, within the judicial district.
- Core Dispute: Plaintiffs, a group of e-commerce sellers, seek a declaratory judgment that their sliding door security bars do not infringe Defendant's patent on an adjustable lock, and that the patent is invalid, following Defendant's infringement complaints on the Amazon marketplace.
- Technical Context: The technology concerns mechanical, adjustable security bars used to block the movement of sliding doors and windows.
- Key Procedural History: The action arises from Defendant's pre-suit enforcement activities, including filing infringement complaints via Amazon's reporting tool and sending demand letters to Plaintiffs, which prompted Plaintiffs to file this action for a judicial declaration of non-infringement and invalidity.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-29 | ’195 Patent Priority Date |
| 2014-10-21 | ’195 Patent Issue Date |
| 2024-08-24 | First Amazon infringement notices received by Plaintiffs |
| 2024-10-09 | Subsequent Amazon infringement notices received by Plaintiffs |
| 2024-11-08 | Demand letters received by Plaintiffs from Defendant's attorney |
| 2024-11-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 8,864,195, “Adjustable Sliding Door, Window, or Panel Lock,” issued October 21, 2014. (Compl. ¶21; ’195 Patent, cover page).
The Invention Explained
- Problem Addressed: The patent addresses the difficulty of securing sliding glass doors, particularly when a pet-door insert is used, as this prevents the door's built-in lock from engaging. Common solutions, such as a wooden dowel, are described as inconvenient, non-adjustable, and potentially insufficient to create a weather-tight seal. (’195 Patent, col. 1:24-65).
- The Patented Solution: The invention is a telescoping lock that wedges between a stationary door frame and the movable door. It consists of an inner barrel that slides within an outer barrel. The length can be set with a coarse adjustment (a pin through aligned holes in both barrels) and then fine-tuned by rotating the outer barrel, which is threaded onto a mounting component, to apply precise pressure and secure the door. (’195 Patent, Abstract; col. 2:9-28).
- Technical Importance: The design aims to provide a "portable adjustable...door lock that requires no drilling or tools" and allows for a "superior sealing capability" through its fine-adjustment feature. (’195 Patent, col. 2:1-5).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of all claims, focusing on independent claims 1 and 17. (Compl. ¶¶ 27, 34).
- Independent Claim 1 includes these essential elements:
- A portable length adjustable wedge device with a first barrel and a slideably received second barrel.
- Means for incrementally adjusting and fixing the length of the second barrel within the first.
- Means for securing the second end of the second barrel in a freely rotatable manner at a fixed position.
- Fine adjustment means for securing the first barrel to a frame, allowing rotation to extend the device's overall length.
- Independent Claim 17 includes these essential elements:
- A mounting bracket for installation on a door or window frame.
- A male threaded mounting component hingeably attached to the bracket.
- An outer barrel with internal threads to engage the mounting component.
- Major adjustment means including an inner telescoping barrel with holes.
- Locking pin means to fix the barrels' relative positions.
- Means for releasably securing the end of the inner barrel.
- The complaint also seeks a declaration of non-infringement for dependent claims 2-16 and 18-19. (Compl. ¶33).
III. The Accused Instrumentality
Product Identification
- The "Sliding Lock" or "Sliding Door Security Bar" products sold by the Plaintiffs on the Amazon marketplace. (Compl. ¶¶ 5-14).
Functionality and Market Context
- The accused products are security bars designed to be placed in the track of a sliding door or window to prevent it from opening. (Compl., p. 8). The complaint alleges that these products function by simple abutment, where the ends of the bar are wedged against the door and frame, without being attached or mounted via a bracket. (Compl. ¶¶ 29-30). A photograph in the complaint shows a bar braced inside a sliding door track without any visible mounting hardware. (Compl., p. 8). The Amazon marketplace is identified as the Plaintiffs' "primary sales channel into the United States." (Compl. ¶19).
IV. Analysis of Infringement Allegations
The complaint alleges non-infringement based on the absence of key structural elements required by the asserted independent claims.
’195 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| means for securing said second end of said second barrel in a freely rotatable manner while at a fixed position... | Plaintiffs' products lack this element. The complaint alleges this is a means-plus-function limitation that must be construed to include the structure disclosed in the patent, specifically "a retaining cup with a lower semicircular portion," which the accused products do not have. An annotated patent drawing is provided to illustrate this allegedly missing component. (Compl., p. 7). | ¶¶ 28-29 | col. 8:26-34 |
| Claim Element (from Independent Claim 17) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mounting bracket for installation on one of a fixed or opposing movable frame of a sliding door, sliding panel, or sliding window frame. | Plaintiffs' products allegedly lack such a mounting bracket. The complaint states the products are not installed "on" the frame but instead "merely abut against the frame." | ¶30 | col. 12:26-29 |
Identified Points of Contention
- Scope Questions:
- A central dispute will be the construction of the "means for securing..." limitation in Claim 1. The question for the court is whether, under 35 U.S.C. § 112(f), this term is limited to the "retaining cup" structure disclosed in the patent's specification (’195 Patent, FIGS. 36-37B) and its equivalents, as Plaintiffs contend. (Compl. ¶28).
- For Claim 17, a key question is whether the end of the Plaintiffs' simple pressure-fit bar constitutes a "mounting bracket for installation on" a frame, or if that term requires a separate, attachable component as depicted in the patent (’195 Patent, FIGS. 3-11).
- Technical Questions: What evidence demonstrates how the accused products are secured in place? The infringement analysis will depend on whether they are simply wedged, as alleged by Plaintiffs, or if some component could be argued to function as a "mounting bracket" or the "means for securing." (Compl. ¶¶ 29-30).
V. Key Claim Terms for Construction
The Term: "means for securing said second end of said second barrel in a freely rotatable manner while at a fixed position" (Claim 1)
- Context and Importance: Plaintiffs identify this as a means-plus-function term under 35 U.S.C. § 112(f). (Compl. ¶28). Its scope is therefore not defined by the words alone, but by the corresponding structure disclosed in the specification. The entire non-infringement argument for Claim 1 hinges on the court's definition of this required structure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Narrower Interpretation: The complaint argues the required structure is "a retaining cup with a lower semicircular portion." (Compl. ¶28). The patent specification describes and depicts this structure as "retaining cup 107" having "retention horns or tabs 27," a "lower semicircular portion 30," and a "backing plate 29." (’195 Patent, col. 5:56-6:4; FIGS. 36-39). The lack of disclosed alternative structures for this function may support a narrow interpretation limited to this cup-like structure and its equivalents.
The Term: "mounting bracket" (Claim 17)
- Context and Importance: Plaintiffs' non-infringement argument for Claim 17 depends on the assertion that their products lack a "mounting bracket." (Compl. ¶30). The construction of this term is therefore critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a standalone definition, which could allow a party to argue that any part of the device that facilitates its placement against the frame meets the definition.
- Evidence for a Narrower Interpretation: The specification consistently illustrates the "mounting bracket 101" as a distinct component that is first installed on the door frame channel (e.g., via adhesive strips or screws) and includes a "mounting hinge bar 11" to which the rest of the lock assembly is "hingeably attached." (’195 Patent, col. 4:47-65; FIGS. 3-11). This suggests the term requires a separate, affixed component, which may support Plaintiffs' position that their simple abutment-style bars do not have one.
VI. Other Allegations
The complaint includes a second count seeking a declaratory judgment that all claims of the ’195 Patent are invalid.
Anticipation and Obviousness (§§ 102/103)
- The complaint alleges that claims 1-19 are invalid as anticipated or obvious in light of seven cited prior art references: U.S. Patent Nos. 4,792,168; 4,295,676; 4,461,502; 4,639,023; 5,509,235; GB Patent No. 1,115,902; and U.S. Patent App. Pub. No. 2009/0267356. (Compl. ¶¶ 37-45). The complaint attaches these references as exhibits but does not provide a detailed analysis or claim chart mapping them to the ’195 Patent’s claims.
Indefiniteness (§ 112)
- The complaint alleges the claims are invalid for indefiniteness on two grounds:
- The term "relatively dimensioned" is alleged to be ambiguous because it "does not specify the exact relationship or proportion between the components." (Compl. ¶47).
- The "means for securing..." language in Claim 1 is alleged to lack sufficient written description and be indefinite because its phrasing is "convoluted" and uses ambiguous alternatives ("attached or mounted or connected"). (Compl. ¶48).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears poised to turn on three central questions for the court:
A core issue will be one of claim construction: Is the "means for securing" limitation in Claim 1 governed by § 112(f) and, if so, is its scope limited to the specific "retaining cup" structure shown in the patent? The answer will likely determine the outcome of infringement for Claim 1.
A second issue will be a mixed question of law and fact: Does the term "mounting bracket" in Claim 17 require a separate, physically attached component as illustrated in the patent's embodiments, or can it be construed to read on the end of a simple pressure-fit bar?
A key evidentiary question will be the validity of the patent: Can Plaintiffs meet their burden of proving by clear and convincing evidence that the claims are indefinite or were anticipated or rendered obvious by the seven prior art references cited in the complaint?