DCT
1:23-cv-04578
Shen Zhen You Yu Ku Ke Ji You Xian Gong Si v. Jiangsu Huari Webbing Leather Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shen Zhen You Yu Ku Ke Ji You Xian Gong Si (China)
- Defendant: Jiangsu Huari Webbing Leather Co., Ltd. (China)
- Plaintiff’s Counsel: Rosenbaum & Segall, P.C.
- Case Identification: 1:23-cv-04578, S.D.N.Y., 05/31/2023
- Venue Allegations: Venue is asserted on the basis that a substantial part of the events, including Defendant’s sales and prior legal actions, occurred in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Jugader" brand obstacle course products do not infringe Defendant’s patent related to adjustable mounting systems for hanging exercise equipment.
- Technical Context: The technology concerns outdoor recreational and exercise equipment, specifically slackline-style obstacle courses where various hanging elements (rings, bars) are attached to a primary webbing strap.
- Key Procedural History: The action was filed in response to infringement complaints Defendant allegedly made to Amazon.com against Plaintiff. The complaint also notes that Defendant previously filed and then dismissed a separate infringement lawsuit involving the same patent (23-cv-2605) after a temporary restraining order was not continued.
Case Timeline
| Date | Event |
|---|---|
| 2019-03-22 | '673 Patent Priority Date |
| 2022-10-25 | '673 Patent Issued |
| 2023-05-11 | Defendant allegedly reports Plaintiff to Amazon.com |
| 2023-05-31 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 11,478,673, “Walking Flat Belt Having Hanging Exercise Means,” issued October 25, 2022.
The Invention Explained
- Problem Addressed: The patent describes a problem with prior art outdoor exercise equipment where the mounting positions for hanging obstacles are fixed, typically by sewing loops into a main strap. This prevents users from adjusting the distance between obstacles to suit their own needs or exercise purposes (’673 Patent, col. 1:35-44).
- The Patented Solution: The invention provides an adjustable mounting system. It uses a special buckle, described as being "日" shaped (the Chinese character for "sun"), which has a central partition element. This buckle is attached to a short "buckle flat strap," which in turn is mounted onto the main "sling body" (the primary webbing line). This design allows the entire mounting member assembly to slide along the main sling body, enabling a user to "freely choose the distance between the hanging objects" (’673 Patent, Abstract; col. 2:27-40). The specific path the strap takes through the buckle is a key feature of the claimed design (’673 Patent, col. 3:11-18).
- Technical Importance: The invention provides adjustability and customization for a popular category of consumer exercise equipment, allowing one product to be adapted for users of different sizes and skill levels (’673 Patent, col. 2:33-40).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of Claim 1, the sole independent claim of the '673 Patent (Compl. ¶14, 25).
- Essential elements of Independent Claim 1 include:
- A walking flat belt, comprising a mounting member, a sling body, a hanging obstacle, and a connecting member.
- The mounting member is mounted to the sling body.
- The mounting member comprises a rectangular shaped buckle and a flat strap to receive the buckle.
- The buckle includes a mouthpiece element and a partition element.
- The partition element divides the buckle's enclosed area into a first connection area and a second connection area.
- One end of the flat strap passes through the first connection area, then passes over the partition element, and then passes through the second connection area, and is connected with another end of the flat strap.
- The complaint does not explicitly reserve the right to assert non-infringement of dependent claims, but the prayer for relief requests a declaration of non-infringement of "any claim" of the patent (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
- The "Jugader Products," specifically model numbers AD0502, AD0402, and A0401, which are described as "Ninja Warrior Obstacle Course" products (Compl. ¶4, 15).
Functionality and Market Context
- The products are outdoor obstacle courses for children, sold on Amazon.com, consisting of a webbing line to which various hanging obstacles like swings, ladders, and rings are attached (Compl. ¶4, 15). The complaint includes an image from an Amazon product listing showing the fully assembled product in use (Compl. ¶15). The core of the non-infringement allegation rests on the specific design of the buckle and strap assembly used to attach these obstacles (Compl. ¶16). The complaint provides a detailed line drawing of the accused buckle design to illustrate its non-infringing configuration (Compl. ¶16). This drawing shows a buckle with an integrated strap used for attachment (Compl. ¶16).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint pleads for a declaratory judgment of non-infringement. The following table summarizes the plaintiff's key non-infringement contentions against Claim 1.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (Plaintiff's Contentions) | Complaint Citation | Patent Citation |
|---|---|---|---|
| a sling body | Plaintiff alleges the accused product does not include a distinct "sling body" component as claimed, asserting this limitation is not met. | ¶16, ¶25 | col. 4:36 |
| [the mounting member comprises] a flat strap to receive the rectangular shaped buckle | Plaintiff alleges the accused product's buckle and strap are an integrated unit, not a separate "flat strap" that "receive[s]" the buckle as recited in the claim. | ¶16, ¶25 | col. 4:44-45 |
| wherein one end of the flat strap passes through the first connection area, then passes over the partition element and then passes through the second connection area, and is connected with another end of the flat strap | Plaintiff alleges the accused product does not have a flat strap that is threaded in this specific manner, contending this entire functional limitation is absent. The provided drawing illustrates a different configuration. | ¶16, ¶25 | col. 4:13-19 |
Identified Points of Contention
- Structural Questions: The central dispute appears to be whether the accused "Jugader Product" has the distinct components required by Claim 1. The complaint alleges the product lacks a "sling body" and that its buckle/strap mechanism is a single integrated part, not a buckle that "receive[s]" a separate "flat strap" (Compl. ¶16, 25). An image in the complaint contrasts the accused product with a depiction of the patentee's product, highlighting the alleged structural differences (Compl. ¶17).
- Functional Questions: A key question will be whether the strap configuration in the accused product, as depicted in the complaint's drawing (Compl. ¶16), performs the function of passing through a first area, over a partition, and through a second area as claimed. The complaint's position is that it does not, representing a fundamental operational difference (Compl. ¶16).
V. Key Claim Terms for Construction
The Term: "sling body"
Context and Importance: Plaintiff explicitly alleges the accused product "does not include a sling body" (Compl. ¶16). The definition of this term will be critical. If "sling body" is construed to mean a main webbing line that is structurally distinct from the mounting member's own strap, it may support Plaintiff's non-infringement argument. If it is construed more broadly to encompass any primary strap to which obstacles are attached, the analysis may shift.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent repeatedly refers to the "sling body 1" as the main belt onto which other components are mounted, suggesting it is the primary structural element of the apparatus ('673 Patent, col. 3:2-3).
- Evidence for a Narrower Interpretation: Claim 1 recites the "sling body" and the "mounting member" as separate elements of the overall "walking flat belt." The "mounting member" is further defined as comprising its own "flat strap". This structure may suggest that the "sling body" must be a component separate from the "flat strap" of the "mounting member".
The Term: "a flat strap to receive the rectangular shaped buckle"
Context and Importance: This phrase is central to the mechanical relationship between the buckle and its strap. Practitioners may focus on this term because the plaintiff's drawing of the accused product appears to show an integrated buckle-and-strap piece, rather than a separate strap that is threaded into or "receives" the buckle (Compl. ¶16).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "mounting member 2" as including both the "buckle 3 and a buckle flat strap 4" ('673 Patent, col. 3:4-6), which could be read to mean these are simply the components of the member, without a strict requirement of separability.
- Evidence for a Narrower Interpretation: The claim language "a flat strap to receive the... buckle" suggests an action or relationship where the strap is the receiving element and the buckle is the received element. The detailed description explains that one end of the "buckle flat strap 4 passes through the first connection area 7" of the buckle, which supports the interpretation of two interacting but distinct parts ('673 Patent, col. 3:11-15).
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for both itself (direct) and its customers (indirect) (Compl. ¶27). The factual basis is simply a denial that any infringing activity occurs, thereby precluding liability for inducement or contributory infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural identity: Does the accused product's integrated buckle-and-strap component meet the claim limitations requiring a distinct "sling body" and a "mounting member" which itself comprises a "flat strap" that "receive[s]" a buckle? The court will need to determine if the claims require physically separate parts or if a single, integrated component can satisfy multiple limitations.
- A key question of infringement analysis will be whether the path of the strap in the accused product is functionally and structurally the same as the claimed path: "passes through the first connection area, then passes over the partition element and then passes through the second connection area." The plaintiff's provided diagrams suggest a direct factual dispute on this point.