DCT

1:23-cv-02605

Jiangsu Huari Webbing Leather Co Ltd v. Joes

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-02605, S.D.N.Y., 03/29/2023
  • Venue Allegations: Plaintiff alleges venue is proper because the numerous defendants, primarily online retailers, actively market and have either sold and shipped accused products into the Southern District of New York or have demonstrated the willingness and ability to do so.
  • Core Dispute: Plaintiff alleges that Defendants’ "Hanging Exercise Products," which are backyard obstacle course systems, infringe a patent related to an adjustable mounting assembly for hanging exercise equipment from a flat belt.
  • Technical Context: The technology concerns consumer recreational equipment, specifically modular obstacle courses popularized by television shows like "American Ninja Warrior," where adjustability is a key feature for user customization.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date Event
2019-03-22 U.S. Patent No. 11,478,673 Priority Date
2020-03-21 U.S. Patent No. 11,478,673 Application Filing Date
2022-10-25 U.S. Patent No. 11,478,673 Issue Date
2023-03-29 Complaint Filing Date

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

U.S. Patent No. 11,478,673 - "Walking Flat Belt Having Hanging Exercise Means"

The patent-in-suit is U.S. Patent No. 11,478,673, issued October 25, 2022 ('673 Patent).

The Invention Explained

  • Problem Addressed: The patent's background section describes prior art outdoor exercise equipment where hanging obstacles are attached to a main sling belt at fixed, non-adjustable positions, typically by sewing loops into the belt. This prevents a user from freely choosing the distance between obstacles to suit their specific exercise needs or desired difficulty level (’673 Patent, col. 1:34-44).
  • The Patented Solution: The invention provides a mounting system that allows for adjustable positioning of obstacles. The solution centers on a specific type of buckle—described as "日" shaped (resembling the Chinese character for "sun," i.e., a rectangle with a central crossbar)—and a short "flat strap." This buckle assembly holds the obstacle and can be slid along the main sling belt and secured at a user-selected position, offering customizability (’673 Patent, Abstract; col. 1:56-62). The detailed description illustrates this mechanism, showing how the flat strap loops through the buckle's partitioned sections to create a secure but movable attachment point (’673 Patent, col. 3:12-21; Fig. 3).
  • Technical Importance: This approach provides modularity and user-configurability to a class of consumer exercise equipment where fixed configurations were previously standard (’673 Patent, col. 2:31-38).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (’673 Patent, col. 4:1-18; Compl. ¶17).
  • Claim 1 requires:
    • A system comprising a mounting member, a sling body, a hanging obstacle, and a connecting member.
    • The mounting member includes a "rectangular shaped buckle" and a "flat strap."
    • The buckle has a "mouthpiece element" and a "partition element" located within it.
    • The two ends of the partition element are connected with the vertical members of the mouthpiece to form "one integral piece."
    • This partition element divides the buckle's enclosed area into a first and second connection area.
    • The flat strap is threaded through this partitioned buckle: passing through the first area, over the partition, through the second area, and connected to its other end.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Hanging Exercise Products" sold by the various Defendants, who are primarily online retailers on platforms such as Amazon.com and eBay.com (Compl. ¶1, ¶4, ¶7). The products are described as "backyard obstacle courses" (Compl. ¶13).

Functionality and Market Context

The complaint alleges that these products are "similar products to the walking flat belt having hanging exercise means" claimed by the patent (Compl. ¶1). It further alleges that the Defendants "actively manufacture, market, and distribute" these products, which are covered by the ’673 Patent (Compl. ¶24). The complaint suggests these products compete directly with the Plaintiff's own offerings in the market for "American Ninja Warrior"-inspired equipment (Compl. ¶13).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, five representative claim charts (Exhibits C-G) that allegedly detail how the accused products meet every element of Claim 1 (Compl. ¶20). In the absence of these exhibits, the infringement theory must be summarized from the complaint's narrative allegations.

The complaint asserts that a review of the Defendants' products, sold via their respective websites, establishes infringement of Claim 1 (Compl. ¶19). The core allegation is that the accused "Hanging Exercise Products" possess a structure that is "substantially similar" and "interchangeable" with the structures recited in the patent's claims and depicted in the representative (but unattached) claim charts (Compl. ¶21-22). The infringement claim therefore rests on an allegation of direct structural correspondence between the mounting hardware on the accused products and the limitations of Claim 1.

  • Identified Points of Contention:
    • Evidentiary Question: The complaint makes broad allegations against a large number of products sold by different, unidentified vendors. A central issue will be evidentiary: what is the precise structure of the buckle and strap assembly used in each of the accused products, and does that specific structure map onto every limitation of Claim 1?
    • Scope Questions: The infringement analysis will likely focus on the specific geometry recited in the claim. A key question for the court may be whether the accused products' buckles meet the definition of a "rectangular shaped buckle" containing a "partition element" that is connected to the vertical members to form "one integral piece" (’673 Patent, col. 4:6-10). Any structural deviation in the accused products from this specific configuration could form the basis of a non-infringement defense.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail to identify specific claim construction disputes. However, based on the claim language and the technology, the following terms may become central to the case.

  • The Term: "one integral piece"
  • Context and Importance: This term appears in Claim 1 and describes the construction of the rectangular buckle, stating that the central partition element and the outer frame are connected to form a single piece (’673 Patent, col. 4:9-10). Practitioners may focus on this term because its construction will determine whether the claim covers buckles manufactured from multiple components that are later joined (e.g., by welding) versus only those formed from a single, continuous piece of material (e.g., by casting or molding).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not explicitly define "integral piece" or limit the manufacturing method. A party could argue that as long as the components are permanently and rigidly connected to function as a single unit, they form an "integral piece."
    • Evidence for a Narrower Interpretation: The specification states that "two ends of the partition plate 6 are integrally connected with the mouthpiece 5" (’673 Patent, col. 3:9-10). A party might argue that the common technical meaning of "integrally connected" implies formation from a single, unitary part, distinguishing it from an assembly of separate parts.

VI. Other Allegations

  • Willful Infringement: The complaint alleges that Defendants' infringement is willful and deliberate (Compl. ¶32). This allegation is made "upon information and belief" and is conditioned on future discovery showing that Defendants acted with "full knowledge of the ‘673 patent" (Compl. ¶31). The complaint does not plead specific facts indicating pre-suit knowledge of the patent by any of the Defendants.

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

  • A primary issue will be one of structural correspondence: Can the Plaintiff produce evidence demonstrating that the mounting hardware on each of the numerous accused products, sold by different online vendors, contains the specific geometry required by Claim 1—namely, a "rectangular shaped buckle" with a partition element connected to form "one integral piece"?
  • The case may also hinge on a question of definitional scope: How will the court construe the term "one integral piece"? The interpretation of this term could be dispositive, determining whether the claim is limited to buckles manufactured as a single, unitary component or if it can also read on multi-part assemblies that are permanently joined together.