Shenzhen Wenchuangfu Electronic Plastic Product Co Ltd v. Markic

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SHENZHEN WENCHUANGFU ELECTRONIC PLASTIC PRODUCT CO., LTD. (People's Republic of China)
  • Defendant: JURE MARKIC (Slovenia)
  • Plaintiff’s Counsel: Hodgson Russ LLP
• Case Identification: 1:25-cv-01321, W.D.N.Y., 12/05/2025
• Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the events giving rise to the claims occurred in the district, and Defendant, through his company, conducts business in New York.
• Core Dispute: Plaintiff seeks a declaratory judgment that Defendant's patent is invalid and unenforceable, and that Plaintiff's products do not infringe, following Defendant's accusation of infringement through Amazon's Patent Evaluation Express (APEX) program.
• Technical Context: The dispute concerns automated, light-sensitive doors for animal enclosures, such as chicken coops, a product category serving the consumer and small-scale agriculture markets.
• Key Procedural History: The action was precipitated by Defendant's November 2025 complaint filed via Amazon's APEX program, which accused Plaintiff's products of infringing the patent-in-suit. This complaint is a pre-emptive action by the accused party seeking to invalidate the patent and obtain a judgment of non-infringement.

Case Timeline

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

U.S. Patent No. 12,070,016 - "Automated Light-Sensitive Configurable Animal Door"

• Patent Identification: U.S. Patent No. 12,070,016, "Automated Light-Sensitive Configurable Animal Door," issued August 27, 2024 (the "’016 Patent").

The Invention Explained

• Problem Addressed: The patent addresses the inconvenience and risk associated with manually operated chicken coop doors, which require owners to be present at specific times each day and can expose livestock to predators or harsh weather if not operated correctly (’016 Patent, col. 1:11-32).
• The Patented Solution: The invention is an automated animal door unit that uses a motor-driven sprocket to move a door plate. The sprocket’s teeth engage with a series of guide holes running vertically along the door plate, converting the motor's rotational motion into the linear motion required to open or close the door (’016 Patent, col. 7:4-13). This mechanism is described as more robust and less prone to wear than pulley or rope systems and is housed within a module case containing a light sensor and control circuitry to automate operation based on ambient light levels (’016 Patent, col. 2:61-65; col. 7:13-24).
• Technical Importance: The claimed direct-drive sprocket mechanism provides a potentially more reliable alternative to rope-and-pulley systems, which may fray or fail to close due to insufficient gravitational force or minor obstructions (’016 Patent, col. 7:15-24).

Key Claims at a Glance

• The complaint states that Defendant accused Plaintiff's products of infringing independent claim 1 (Compl. ¶19).
• The essential elements of independent claim 1 are:
  • An animal door unit comprising an entrance made of at least one panel.
  • A door plate with a plurality of guide holes, configurable between an open state (not traversing the entrance) and a retracted, or closed, state (traversing the entrance).
  • A motor.
  • A sprocket that is in rotational communication with the motor.
  • The sprocket interfaces with the guide holes on the door plate, such that the sprocket's rotation induces linear movement in the door plate.
• The complaint does not mention the assertion of any dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Accused Products" as automated chicken coop doors sold by the Plaintiff on Amazon.com under Amazon Standard Identification Numbers (ASINs) B0DHVDZ744, B0DP2CX9VW, B0D6RGYJ9Q, and B0CWXWX52L (Compl. ¶19).

Functionality and Market Context

• The complaint does not provide any technical description of the Accused Products' features or method of operation. It identifies them only as "automated chicken coop doors" (Compl. ¶3). The complaint alleges that Plaintiff manufactures and sells these products directly to customers through e-commerce marketplaces (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint is for a declaratory judgment of non-infringement, invalidity, and unenforceability. The infringement allegations summarized below are those made by the Defendant against the Plaintiff via the Amazon APEX program, as reported in the Plaintiff's complaint (Compl. ¶¶2, 19). The complaint itself does not provide a detailed infringement theory or a feature-by-feature mapping of the Accused Products to the patent's claims.

’016 Patent Infringement Allegations

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: Because the complaint provides no technical details about the Accused Products, the central infringement question is factual: do the Accused Products actually practice each element of claim 1, particularly the claimed sprocket-and-guide-hole mechanism for inducing linear motion?
  • Technical Questions: The complaint's primary focus is on invalidity and unenforceability rather than non-infringement. The key technical question for the court, antecedent to any infringement analysis, will be whether the ’016 Patent is valid in the first place, based on the prior art allegations raised by the Plaintiff.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of potential claim construction disputes. Its arguments focus on invalidity and unenforceability, not on the interpretation of specific claim terms.

VI. Other Allegations

The complaint's primary causes of action are for declaratory judgments of patent invalidity and unenforceability, rather than direct infringement.

• Invalidity (35 U.S.C. §§ 102/103): The complaint alleges that the ’016 Patent is invalid because products covered by claim 1 were publicly disclosed, offered for sale, or sold more than one year prior to the patent's earliest effective filing date (Compl. ¶¶20-21, 25). This allegation points to a potential statutory bar under 35 U.S.C. § 102. The complaint specifically identifies the Defendant's own "Run-Tiger's model T40 product" as an example of such a prior sale or disclosure (Compl. ¶30).
• Unenforceability (Inequitable Conduct): Plaintiff alleges that the ’016 Patent is unenforceable due to inequitable conduct (Compl. ¶30). The basis for this claim is the allegation that the Defendant, as the inventor, knew about his own company's prior commercial sales of the "model T40 product," knew this information was material to patentability, and deliberately withheld this information from the U.S. Patent and Trademark Office with the specific intent to deceive the patent examiner (Compl. ¶30).

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

This declaratory judgment action appears poised to center on the validity and enforceability of the ’016 Patent, rather than on a technical dispute over infringement. The key questions for the case are:

• A key evidentiary question will be one of prior art: can the Plaintiff produce sufficient evidence to demonstrate that the Defendant's "Run-Tiger's model T40 product" or other products were publicly disclosed or on sale more than one year before the patent's priority date and that these products embodied the invention claimed in the ’016 Patent?
• A central issue will be one of intent and materiality: to prove inequitable conduct, can the Plaintiff establish by clear and convincing evidence that the Defendant knew his prior product sales were material to patentability and intentionally withheld this information from the patent office with a specific intent to deceive? The outcome of this question could render the entire patent unenforceable.