DCT
2:25-cv-02198
Shaoshan Zhangzhu Trading Co Ltd v. Arthur Lih
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shaoshan Zhangzhu Trading Co., Ltd. and six other affiliated entities (People's Republic of China)
- Defendant: Arthur Lih and Life Vac LLC (New York)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02198, E.D.N.Y., 04/21/2025
- Venue Allegations: Venue is alleged to be proper in the Eastern District of New York because the Defendants reside in the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their Choking Rescue Devices do not infringe U.S. Patent No. 11,478,115 and that the patent is invalid.
- Technical Context: The complaint addresses technology for choking rescue suction devices, while the patent-in-suit is directed to autonomous robotic floor cleaners.
- Key Procedural History: This declaratory judgment action was filed after Plaintiffs received notifications from Amazon.com, prompted by Defendants, alleging that Plaintiffs' products infringe the patent-in-suit, which resulted in the removal of Plaintiffs' product listings. The complaint also includes an invalidity challenge based on two prior art patents.
Case Timeline
| Date | Event |
|---|---|
| 1984-07-19 | 'Garth' Prior Art Patent (U.S. 4,643,719) Filed |
| 1987-02-17 | 'Garth' Prior Art Patent Issued |
| 1989-05-04 | 'Edward' Prior Art Patent (U.S. 4,971,053) Filed |
| 1990-11-20 | 'Edward' Prior Art Patent Issued |
| 2019-12-03 | '115 Patent Priority Date |
| 2022-10-25 | '115 Patent Issue Date |
| 2025-04-12 | Amazon Notifies Plaintiffs of Product Removal |
| 2025-04-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,478,115 - Autonomous Traveling Cleaner
(Issued Oct. 25, 2022)
The Invention Explained
- Problem Addressed: The patent's background section describes a problem with known industrial autonomous traveling cleaners that often leave uncleaned areas near walls and obstacles because their turning radius prevents them from cleaning close to edges. This can also lead to inefficient cleaning paths and premature battery depletion (’115 Patent, col. 1:40-43).
- The Patented Solution: The invention is an autonomous floor cleaner with an "elongated profile" and a laterally extendable "extension nozzle." This design allows the main body of the cleaner to travel at a safe distance from a wall while the extension nozzle cleans the floor area immediately adjacent to the wall. The extension nozzle is also designed to be pivotable, allowing it to move rearward upon contact with an obstacle to avoid damage (’115 Patent, Abstract; col. 2:4-14).
- Technical Importance: This approach seeks to improve the cleaning efficiency and coverage of autonomous cleaners, particularly in environments with many walls, corners, and narrow passageways (’115 Patent, col. 1:44-45).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1 and 12 (Compl. ¶31).
- Independent Claim 1 recites:
- An autonomous traveling cleaner that travels and cleans a target surface.
- A "driving force transmitter" for moving the cleaner.
- A "suction nozzle" with a "first rotary brush".
- An "extension nozzle" that is "extendable laterally" and includes a "second rotary brush".
- A "collection box" for collecting suctioned matter.
- The cleaner has an "elongated profile".
- The extension nozzle is switchable between a retracted "first posture" and a laterally protruding "second posture".
- In the second posture, the extension nozzle is "pivotable in a direction opposite to the traveling direction".
- In the second posture, the extension nozzle has a "protruding end" that is "aligned with an end of a turning range" of the cleaner.
- The complaint notes that dependent claims cannot be infringed if the independent claims from which they depend are not infringed (Compl. ¶36).
III. The Accused Instrumentality
Product Identification
- The accused products are identified as "Choking Rescue Device" sold by Plaintiffs under various names, including "Aodenn" and "Dlilidi" (Compl. ¶¶1, 4-10).
Functionality and Market Context
- The complaint describes the accused product as a "choking intervention device for clearing an object obstructing a breathing passage" which includes a "bellows assembly and a removable facemask" (Compl. ¶27).
- The core of the Plaintiffs' non-infringement argument is that their device's "relief valve" is "fully embedded within the bellows base," making it an internal component, as opposed to being on an external surface (Compl. ¶32). The complaint includes a photograph illustrating this embedded valve (Compl. p. 7).
- Plaintiffs allege that the Amazon marketplace is their "primary sales channel into the United States" and that the removal of their products causes "immediate and irreparable harm" (Compl. ¶25).
IV. Analysis of Infringement Allegations
The complaint's non-infringement allegations are presented in a narrative format. The central argument is that the accused Choking Rescue Device's relief valve is internal, whereas the patent supposedly requires an external valve (Compl. ¶32). However, the asserted claims of the ’115 Patent are directed to an autonomous cleaner and do not recite a "relief valve." The image provided in the complaint shows the accused device's allegedly non-infringing internal valve (Compl. p. 7).
'115 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an extension nozzle extendable laterally with respect to the traveling direction and including a second rotary brush | The complaint does not allege that the Choking Rescue Device, a medical suction device, has a laterally extendable nozzle or a rotary brush. The allegations center on the location of a "relief valve." | ¶32 | col. 17:26-31 |
| the autonomous traveling cleaner has an elongated profile having a larger dimension in the traveling direction than in a width direction | The complaint does not contain allegations regarding the physical profile or dimensions of the Choking Rescue Device in the context of infringement. | ¶¶4-10 | col. 17:36-40 |
| the extension nozzle in the second posture is pivotable in a direction opposite to the traveling direction | The complaint does not allege that any component of the Choking Rescue Device is pivotable in a direction opposite to a direction of travel. | ¶32 | col. 17:50-52 |
| the extension nozzle in the second posture has a protruding end in the width direction to be aligned with an end of a turning range of the autonomous traveling cleaner | The complaint makes no allegations that the Choking Rescue Device, which is not a traveling device, has a protruding end aligned with a turning range. | ¶32 | col. 17:53-59 |
- Identified Points of Contention:
- Applicability Question: A threshold issue is whether the '115 Patent, directed to an "autonomous traveling cleaner," is applicable to the accused "Choking Rescue Device." The complaint does not explain how a medical suction device could read on claims for a robotic floor cleaner.
- Technical Question: The complaint’s primary non-infringement argument focuses on the term "disposed on" and the location of a "relief valve" (Compl. ¶32). These terms and features do not appear in the asserted independent claims of the '115 Patent. This raises the question of whether the non-infringement allegations in the complaint correspond to the actual patent-in-suit.
V. Key Claim Terms for Construction
The complaint's argument concerning the term "disposed on" (Compl. ¶32) does not map to the asserted claims of the provided '115 Patent. Analysis of terms from the actual patent that would likely be dispositive in a relevant dispute is provided below.
The Term: "extension nozzle"
Context and Importance: This term appears in nearly every claim and is the central feature of the invention. Its definition—what constitutes an "extension" versus the main "suction nozzle"—is critical to determining the boundary between the claimed invention and the prior art.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the nozzle as "extendable laterally" and capable of being in a "retracted posture" or a "lateral cleaning posture," suggesting the term could cover any secondary suction component that moves relative to the main body to widen the cleaning path (’115 Patent, col. 2:54-58).
- Evidence for a Narrower Interpretation: The figures and detailed description show a specific embodiment where the "extension nozzle" (19) is a distinct assembly that pivots on a multi-part holder (31, 32) and contains its own rotary brush (19A). A party could argue the term is limited to a structure with these characteristics (’115 Patent, Figs. 14-15; col. 13:6-12).
The Term: "aligned with an end of a turning range"
Context and Importance: This limitation defines the precise spatial relationship between the extended nozzle and the cleaner's main body during operation. Practitioners may focus on this term because it quantifies the functional benefit of the invention and infringement will depend on specific measurements and operational data.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the alignment is "generally (or substantially)," which may support an interpretation that does not require perfect or constant alignment throughout a turn (’115 Patent, col. 15:26-28).
- Evidence for a Narrower Interpretation: Figure 16 illustrates a specific geometric relationship where the protruding end (19E) of the nozzle follows a path co-extensive with the outer turning range (R1) of the cleaner body. This could support a narrower construction requiring the nozzle tip to precisely track the outermost path of the cleaner during a turn (’115 Patent, Fig. 16; col. 15:41-48).
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing reference to non-infringement "indirectly" but offers no specific factual allegations to support or rebut claims of induced or contributory infringement (Compl. ¶38).
- Willful Infringement: As a declaratory judgment complaint filed by the accused infringer, it does not contain allegations of willful infringement against the patent holder.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue is one of fundamental applicability: can the claims of the '115 Patent, which are directed exclusively to an "autonomous traveling cleaner," be construed to read on the accused "Choking Rescue Device"? The significant and apparent mismatch in technology between the patent and the accused product is a threshold question for the court.
- A secondary issue is one of pleading sufficiency: the complaint's non-infringement arguments (e.g., regarding a "relief valve" and the term "disposed on") and its invalidity arguments (citing prior art for suction masks and aspirators) appear to correspond to a different patent than the '115 Patent identified in the action. The viability of the case may depend on whether these discrepancies can be resolved through amendment.
- An evidentiary question for the invalidity claim will be whether the cited prior art for medical aspirators ('Garth' and 'Edward') can be considered analogous art to the field of autonomous robotic cleaners, a determination necessary to sustain an obviousness challenge.