DCT
2:25-cv-00615
Fu v. Allriver Direct
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Qianming Fu (People's Republic of China)
- Defendant: Allriver-Direct et al. (Foreign Jurisdictions)
- Plaintiff’s Counsel: Alioth Law
- Case Identification: 2:25-cv-00615, W.D. Pa., 05/06/2025
- Venue Allegations: Venue is alleged to be proper because the defendants are foreign entities subject to venue in any judicial district. The complaint also alleges defendants solicit and transact business in the Western District of Pennsylvania through online marketplaces.
- Core Dispute: Plaintiff alleges that Defendants’ online sales of storage devices infringe its patent for a wall-mountable storage unit that uses elastic elements to retain contents.
- Technical Context: The technology relates to home organization products, specifically corner-mounted or wall-mounted storage solutions designed to prevent items from falling out.
- Key Procedural History: The complaint is structured as an action against numerous, allegedly related e-commerce sellers operating under various aliases on platforms like Amazon and Temu. Plaintiff alleges these sellers are part of a coordinated infringement scheme and conceals their identities, a fact pattern common in e-commerce patent enforcement actions.
Case Timeline
| Date | Event |
|---|---|
| 2024-04-16 | U.S. Patent No. 12,144,420 B1 Priority Date |
| 2024-11-19 | U.S. Patent No. 12,144,420 B1 Issue Date |
| 2025-05-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,144,420 - "STORAGE DEVICE"
- Patent Identification: U.S. Patent No. 12,144,420, titled "STORAGE DEVICE", issued on November 19, 2024 (the "'420 Patent").
The Invention Explained
- Problem Addressed: The patent identifies a safety hazard in prior art storage devices where articles are "prone to falling" (’420 Patent, col. 1:13-16).
- The Patented Solution: The invention is a storage device comprising a top "mounting component," a bottom "storage component," and "at least one elastic piece" connected between them (’420 Patent, col. 3:22-29). These elastic pieces form a protective, flexible barrier that encloses a storage space, preventing items from falling out while allowing a user to deform the barrier to create an "entrance" for access (’420 Patent, col. 5:1-5). The overall structure is often configured for mounting in a corner (’420 Patent, col. 6:21-25).
- Technical Importance: The design aims to improve the safety and reliability of open-front storage units by adding a flexible retaining system.
Key Claims at a Glance
- The complaint’s infringement allegations focus on independent claim 1 (Compl. ¶30).
- The essential elements of Claim 1 include:
- A mounting component, a storage component, and at least one elastic piece.
- The mounting and storage components are mounted on wall surfaces at intervals in a gravity direction.
- The elastic piece connects the two components and, together with them, encloses a storage space.
- The elastic piece is deformable by an external force to create an entrance to the space.
- The mounting and storage components are foldable structures.
- The mounting and storage components are each "symmetrical and is foldable along a perpendicular bisector perpendicular to an outer side edge thereof."
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "storage device" products sold by the defendants on online marketplaces, including Amazon and Temu (Compl. ¶1).
Functionality and Market Context
- The complaint alleges the accused products are wall-mounted storage organizers that feature top and bottom structural components connected by multiple vertical elastic bands (Compl. ¶30). The complaint includes a photograph of an accused product, described as a wall-mounted storage unit filled with stuffed animals and restrained by vertical elastic bands, allegedly sold by "Defendant 1" (Compl. p. 9). Plaintiff alleges these products are sold through pseudo-anonymous online storefronts in direct competition with the patent owner, causing market harm and price erosion (Compl. ¶5.d, ¶39).
IV. Analysis of Infringement Allegations
'420 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A storage device, comprising: a mounting component, a storage component, and at least one elastic piece | The accused product has a mounting component, a storage component, and elastic pieces connecting the components. | ¶30 | col. 3:22-24 |
| wherein the mounting component and the storage component are mounted on wall surfaces at intervals in a gravity direction | The accused product's mounting and storage components are mounted on wall surfaces. | ¶30 | col. 3:25-27 |
| the at least one elastic piece is connected between the mounting component and the storage component | Elastic pieces in the accused product connect the mounting component and the storage component. | ¶30 | col. 3:27-29 |
| the at least one elastic piece, the mounting component, and the storage component are enclosed to define a storage space | The components of the accused product are alleged to combine to form a storage area. | ¶30 | col. 5:1-3 |
| under driving of an external force, the at least one elastic piece is deformed to define an entrance of the storage space | The elastic pieces of the accused product are alleged to deform to allow access to the storage space. | ¶30 | col. 5:3-5 |
| wherein the mounting component and the storage component are foldable structures | The accused product's mounting and storage components are alleged to be foldable. | ¶30 | col. 5:38-39 |
| wherein the mounting component is symmetrical and is foldable along a perpendicular bisector perpendicular to an outer side edge thereof; the storage component is symmetrical and is foldable along a perpendicular bisector perpendicular to an outer side edge thereof | The accused product's mounting and storage components are alleged to be "symmetrical and foldable." | ¶30 | col. 5:44-49 |
- Identified Points of Contention:
- Scope Questions: Claim 1 recites a highly specific geometric limitation: that the components are "symmetrical and is foldable along a perpendicular bisector perpendicular to an outer side edge thereof." The complaint alleges the accused products are "symmetrical and foldable" (Compl. ¶30), but does not specify if they meet this precise geometric constraint. This raises the question of whether the plaintiff can prove literal infringement or must rely on its alternative theory of infringement under the doctrine of equivalents (Compl. ¶31, ¶54).
- Technical Questions: The complaint's infringement chart provides conclusory statements mapping product features to claim elements. A key evidentiary question will be what proof exists to demonstrate that the accused products actually meet each limitation, particularly the specific "foldable" and "symmetrical" requirements of Claim 1.
V. Key Claim Terms for Construction
- The Term: "symmetrical and is foldable along a perpendicular bisector perpendicular to an outer side edge thereof"
- Context and Importance: This term appears in Claim 1 and sets a specific geometric and functional constraint on the mounting and storage components. Practitioners may focus on this term because its narrow, technical language may be a significant hurdle for proving literal infringement if the accused products do not precisely match this description. The plaintiff’s pleading of the doctrine of equivalents suggests this term is a potential point of dispute (Compl. ¶31).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the specification’s disclosure of various overall shapes for the components, such as "fan-shaped, right-angled triangle, or rectangular" (’420 Patent, col. 6:2-4), suggests the invention is not limited to a single, rigid geometry.
- Evidence for a Narrower Interpretation: A party would point to the plain and specific language of the claim itself, arguing that terms like "perpendicular bisector" have precise geometric meanings that must be met. The detailed description of this feature provides a specific embodiment that could be used to argue for a narrow construction (’420 Patent, col. 5:44-49).
VI. Other Allegations
- Indirect Infringement: The complaint makes a general allegation of indirect infringement (Compl. ¶28), but does not plead specific facts to support the knowledge and intent elements, such as referencing user manuals or advertising that instructs on an infringing use.
- Willful Infringement: Willfulness is alleged based on the assertion that defendants are "aware of Plaintiff and the Asserted Patent" and act with "reckless disregard or willful blindness" (Compl. ¶10.h, ¶14, ¶49). This alleges pre-suit knowledge as the basis for willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: can the accused products be proven to meet the highly specific geometric requirements of Claim 1 that the components be "symmetrical and...foldable along a perpendicular bisector perpendicular to an outer side edge thereof," or will the case turn entirely on whether the products are infringing under the doctrine of equivalents?
A threshold procedural question will be one of proper joinder: will the court permit the case to proceed against a large group of allegedly separate, pseudo-anonymous online sellers as a single action under 35 U.S.C. § 299? The plaintiff's ability to demonstrate that the various accused products are the "same" and arise from the "same transaction, occurrence, or series of transactions" will be critical.