DCT
1:24-cv-04579
Yue v. Hanna
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wenyong Yue, Huizhoushi Huifangyuan Nongye Keji Youxian Gongsi a/k/a Botail, and yidiandian Shenzhen wenhuachuanmeiyouxiangongsi a/k/a Cool Essential (P.R. China)
- Defendant: John Nashed Hanna, Reaction Labs LLC a/k/a Lup (Texas), and Amazon.com, Inc. (New York)
- Plaintiff’s Counsel: Lance Liu, Esq.
- Case Identification: 2:24-cv-04579, S.D.N.Y., 06/15/2024
- Venue Allegations: Venue is based on Amazon’s business presence, distribution centers, and stock trading within the judicial district, as well as the offering for sale of the accused products to consumers in New York.
- Core Dispute: Plaintiff alleges that Defendants’ magnetic data cables infringe its patent, filed this suit after Defendants used their own, later-filed patent to have Plaintiff’s products removed from Amazon’s e-commerce platform.
- Technical Context: The technology concerns self-organizing data cables that use integrated magnetic materials to allow for neat coiling and storage, addressing the common problem of tangled cables.
- Key Procedural History: The central conflict arises from a priority dispute between the Plaintiff's '703 Patent and the Defendants' '881 Patent. The complaint alleges that Amazon, at the behest of Defendants, blocked Plaintiff's e-commerce stores for infringing the '881 Patent. Plaintiff contends that the '881 Patent is not entitled to its claimed provisional priority date, and therefore Plaintiff's '703 Patent has an earlier effective filing date and is prior art to the '881 Patent. Plaintiff seeks a declaratory judgment of non-infringement and invalidity of the '881 Patent, in addition to asserting its own '703 Patent against Defendants' products.
Case Timeline
| Date | Event |
|---|---|
| 2023-01-27 | Defendants' '881 Patent claims priority to '006 Provisional Application filing date |
| 2023-04-11 | Plaintiff's '703 Patent claims priority to Chinese Application filing date |
| 2023-04-18 | Plaintiff's '703 Patent U.S. application filing date |
| 2023-06-22 | Defendants' '881 Patent U.S. application filing date |
| 2023-09-12 | Plaintiff's '703 Patent issue date |
| 2024-04-30 | Defendants' '881 Patent issue date |
| 2024-05-29 | Date of first alleged Amazon infringement complaint filed by Defendants against Plaintiffs |
| 2024-06-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,756,703 - "Magnetic Data Cable," issued September 12, 2023
The Invention Explained
- Problem Addressed: The patent's background describes conventional data cables as being inconvenient to store, becoming easily entwined, and looking messy, which occupies unnecessary space ('703 Patent, col. 1:8-17). Previous solutions using discrete magnet blocks or rings are described as tedious to wind and limited by the fixed positions of the magnets ('703 Patent, col. 1:44-55).
- The Patented Solution: The invention is a data cable with a "wrapping material layer" that itself contains a "magnetic material layer" distributed continuously along the cable's length ('703 Patent, Abstract; col. 2:5-8). This integral magnetic property allows the cable to be wound into coils where adjacent loops are held together by magnetic attraction, facilitating easy and flexible storage ('703 Patent, col. 2:34-44). FIG. 1 shows a cross-section of the cable, illustrating the cable core (1), the wrapping material layer (2), the magnetic material layer (3), and an outer protective layer (5).
- Technical Importance: This design purports to offer a more convenient storage solution than prior art cables that relied on spaced-apart magnets, as the continuous magnetic layer allows for flexible adjustment of the coil diameter and ensures a consistent magnetic attraction effect along the cable's length ('703 Patent, col. 2:44-59).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2 and 4 (Compl. ¶7, ¶34).
- Independent Claim 1: A magnetic data cable comprising:
- a cable body and data connectors
- the data connectors are respectively connected to two ends of the cable body
- the cable body comprises a cable core and a wrapping material layer wrapped around the cable core
- at least one layer of the wrapping material layer is a magnetic material layer
- wherein the magnetic material layer is directly wrapped around an outer side of the cable core
- the magnetic material layer is formed by extruding and molding of a mixture of plastic and magnetic powder
- the wrapping material layer further comprises an outer protective layer wrapped around an outer side of the magnetic material layer
III. The Accused Instrumentality
Product Identification
The accused products are the "Lup's Magnetic Data Cable" sold by Defendants Hanna, Lup, and Amazon (Compl. ¶7, ¶34).
Functionality and Market Context
The complaint alleges these are magnetic data cables offered for sale on Amazon (Compl. ¶5). The product's advertised functionality, as shown in a complaint visual, is that "Magnetic attraction makes lūp easy to coil and stow" and that it "is essentially self-organizing" (Compl. ¶7). A product image shows the cable coiled neatly, appearing to hold its shape via magnetic forces (Compl. ¶7). The complaint alleges these products are "competing magnetic data cables" to the Plaintiffs' own products (Compl. ¶7).
IV. Analysis of Infringement Allegations
’703 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A magnetic data cable, comprising: a cable body and data connectors; the data connectors are respectively connected to two ends of the cable body | The accused product is a data cable with connectors at each end. A complaint visual depicts the "Lup's Magnetic Data Cable" with connectors. | ¶7 | col. 3:60-64 |
| the cable body comprises a cable core and a wrapping material layer wrapped around the cable core | The complaint alleges the accused product is a magnetic data cable which necessarily includes a cable core for data transmission and a wrapping layer or sheath. | ¶7 | col. 3:64-65 |
| at least one layer of the wrapping material layer is a magnetic material layer | The accused product is marketed as a "Magnetic Data Cable" where "Magnetic attraction makes lūp easy to coil and stow." This suggests the presence of a magnetic layer. | ¶7 | col. 4:1-2 |
| wherein the magnetic material layer is directly wrapped around an outer side of the cable core | The complaint does not provide sufficient detail for analysis of the internal structure of the accused cable. | ¶7 | col. 5:1-2 |
| the magnetic material layer is formed by extruding and molding of a mixture of plastic and magnetic powder | The complaint does not provide any specific evidence regarding the manufacturing process of the accused product's magnetic layer. | ¶7 | col. 5:2-4 |
| the wrapping material layer further comprises an outer protective layer wrapped around an outer side of the magnetic material layer | A complaint visual shows the accused cable with a visible outer surface that could be construed as a protective layer. | ¶7 | col. 5:5-7 |
- Identified Points of Contention:
- Technical Questions: A primary evidentiary question is whether the accused "Lup" cable is manufactured using the specific process required by claim 1: "extruding and molding of a mixture of plastic and magnetic powder." The complaint provides no direct evidence on this point, instead relying on the product's external appearance and marketing claims.
- Scope Questions: The analysis may turn on whether the accused product's standard outer cable sheath can be considered an "outer protective layer" that is distinct from, and "wrapped around," the "magnetic material layer" as required by the claim structure. The complaint does not detail the layered construction of the accused product.
V. Key Claim Terms for Construction
The Term: "magnetic material layer is formed by extruding and molding of a mixture of plastic and magnetic powder"
- Context and Importance: This process-defined product limitation appears to be a central feature of the invention. Practitioners may focus on this term because infringement will require evidence that the accused product is made by this specific manufacturing method, which may be difficult for the plaintiff to prove without discovery.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue this term should not be overly constrained, covering any functionally similar integrated magnetic layer. However, the claim language is quite specific, limiting such arguments.
- Evidence for a Narrower Interpretation: The specification explicitly states, "The magnetic material layer is formed by extruding and molding of a mixture of plastic and magnetic powder" ('703 Patent, col. 3:65-col. 4:1; col. 2:10-13). This explicit definition strongly suggests the term should be limited to the specific process recited.
The Term: "outer protective layer"
- Context and Importance: The claim requires this layer to be a distinct component from the magnetic material layer. The construction of this term is important because if the magnetic layer itself is the outermost layer of the cable, or if it is co-extruded as a single layer with a protective plastic, infringement may be avoided.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the outer protective layer as enhancing "toughness" and preventing the cable "from breaking" ('703 Patent, col. 4:5-8). This functional language could support interpreting any durable outer sheath as meeting the limitation.
- Evidence for a Narrower Interpretation: Claim 2, a dependent claim, specifies the outer protective layer is a "woven mesh layer formed by weaving a braided fabric" ('703 Patent, col. 5:8-10). A defendant could argue this specific embodiment informs a narrower construction of "outer protective layer" in the independent claim, requiring more than just a standard plastic coating.
VI. Other Allegations
- Indirect Infringement: The complaint makes a general allegation of direct and/or indirect infringement (Compl. ¶33), but does not plead specific facts to support a claim for either induced or contributory infringement, such as identifying specific instructions or components for infringement.
- Willful Infringement: Willfulness is alleged based on Defendants' own activities in the same technical space, including prosecuting their own '881 Patent and filing complaints with Amazon (Compl. ¶¶7, 24). Plaintiff alleges Defendants "knew or should have known" that the '703 Patent had an earlier effective filing date, and that by allowing their own infringing products to be sold while blocking Plaintiffs' products, their infringement was willful (Compl. ¶¶24, 37).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of priority and validity: is the Defendants' '881 Patent entitled to its provisional application's filing date? The resolution of this question, which the complaint argues turns on whether the provisional application provides adequate written description for the '881 claims, will determine which patent is prior art to the other.
- A key evidentiary question will be one of infringement proof: can the Plaintiff demonstrate that the accused Lup cable contains a "magnetic material layer formed by extruding and molding of a mixture of plastic and magnetic powder"? The complaint currently lacks direct evidence on this specific manufacturing process limitation, which will likely be a focus of discovery.
- The case will also involve a question of definitional scope: does the accused cable's external sheath constitute an "outer protective layer" separate from and wrapped around a "magnetic material layer" as required by the specific structure of Claim 1, or is it a single, undifferentiated component?